Download Risk, uncertainty and the institutional geographies of

Risk, uncertainty and the institutional geographies of
adaptation to future flooding in England
Christian Kuklicke, Helmholtz Centre for Environmental Research – UFZ, Department Urban
and Environmental Sociology, Permoserstraße 15, 04318 Leipzig , GERMANY. Email:
[email protected]
David Demeritt, King’s College London, Department of Geography, Strand, London WC2R
2LS, UNITED KINGDOM. Email: [email protected]
Abstract: This paper explores how the institutional geographies of flood risk management
shape, and in turn are then reciprocally reshaped by, the way that uncertainties about
climate change are framed as calculable risks to inform adaptation planning and risk-based
policymaking. Combining key informant interviews (n=18) with documentary analysis, it
focuses on how uncertainties about future peak flood flows and sea level rises are
accounted for in long term strategic planning processes to adapt inland and coastal flood
risk management to climate change. In the first case the poorly understood impacts of
future climate change were represented with a simplistic adjustment to peak flow estimates,
which proved institutionally robust in spurring local authorities to make precautionary
allowances for climate change, at least in part because its scientific limitations were only
partly acknowledged. By contrast in the second case, greater scientific confidence led to
successively more elaborate guidance on how to represent the science, which in turn
contributed to significant decisional uncertainties about whether and how the uncertain
effects of future sea level rise would be taken into account in adaptation planning.
Comparative analysis of these two cases then informs some wider reflections about climate
change adaptation and the institutional appetites for uncertainty information.
key words: climate change; flood risk management; risk-based regulation; uncertainty
Introduction
While the scientific challenges involved in assessing the impacts of future climate
change are enormous, the institutional challenges involved in using that science for
policymaking are arguably even greater. A growing body of work has highlighted the
difficulties of reconciling the supply of climate science with the demand for research that is
useful, useable, and used by policymakers (Dilling and Lemos, 2011; Sarewitz and Pielke Jr.,
2007; Tang and Dessai, 2012). Others have pointed to the institutional boundary-work
involved in the construction of science and its use in policymaking and political debate
(Demeritt, 2001; Lövbrand, 2011; Shackley and Wynne, 1996). For instance, it is often
assumed that adaptation policymaking requires more accurate and detailed predictions
about future climate changes. To this end, the UK Research Council’s Living with
Environmental Change Strategy has promised to “strengthen the evidence base for policy,
ECPR conference 'Regulatory Governance between Global and Local'
Barcelona, 17 June 2014
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
by addressing the uncertainties about the impacts of environmental change” (LWEC
Partnership, 2011, p.3). However, the assumption here that reducing scientific uncertainties
is necessary for developing robust climate policy is widely contested (Demeritt, 2006; Dessai
et al., 2009; Prins et al., 2010), and there is an increasingly vocal debate in the climate
science community about the priority and policy relevance of reducing scientific
uncertainties about future climate change (Brown and Wilby, 2012; Mearns, 2010; Meyer,
2012).
In this study, we explore how uncertainties about climate change and adaptation to it
are framed by those involved in Flood and Coastal Erosion Risk Management (FCERM) in
England. The term ‘frame’ here relates to schemas of interpretation that organize
environmental understanding and guide whether and how individuals, organizations, and
societies act in response. Framing is not simply a matter of individual cognition. Rather its
authority and practice are socially—and geographically—conditioned. In different
institutional settings, scientific uncertainties about climate change have alternatively been
downplayed to protect the authority of science-based policies (Shackley and Wynne, 1996),
amplified to reject the need for any action (Oreskes and Conway, 2010), and mobilized as a
rationale for immediate precautionary action (Stern, 2006) or for further research to resolve
them (LWEC Partnership, 2011). Our aim in this paper is to understand whether, how, and
with what wider effects these framings are shaped by the institutional demands of FCERM
and how in turn they may influence those arrangements and the associated norms and
practices of risk-based policymaking in England.
The significance of such institutional geographies has been highlighted by several
distinct, and to date somewhat disconnected, strands of recent work in human geography.
Geographers of science have emphasized the ways in which scientific knowledge is shaped
by its location and the spaces and settings of its practice and circulation (Livingstone, 2003;
Powell, 2007). Such claims have given rise to calls for a more ‘critical’ physical geography
that would explicitly consider how “institutional structures affect the types of biophysical
knowledges” it produces (Tadaki et al., 2012, p.581). Similar claims have been made in the
policy mobilities literature, which emphasises the contingency of policy ideas and the ways
in which their form, application, acceptance, and impact depend on specific institutional
geographies (McCann and Ward, 2013; Peck, 2011).
As an area of science-based policymaking, our empirical case of long-term planning to
adapt FCERM to climate change provides an opportunity to bring these two strands of
geographical work into closer conversation with each other and with a third on the political
geographies of risk and risk-based governance. The strategy for managing flood risks in
England is explicitly ‘risk-based’. That is, governance of the external risks posed by flooding
is itself organized and conducted through risk and the use of various risk instruments and
technologies, like risk mapping and risk-based prioritization, to calibrate management
interventions based on explicit consideration of the probability and consequences of
potential harms (Krieger, 2013). Such risk-based methods provide a means for those
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responsible to define, measure, and make transparent the limits of what they can-- and
cannot be-- expected to achieve; both in terms of managing external threats to security, but
also the various accompanying institutional ‘risks’ arising as a consequence of action (or
inaction) discharging those responsibilities, such as legal liability, political challenge,
reputational damage, or financial loss (Power et al., 2009; Rothstein, 2006). Our paper
explores the challenges posed by uncertainty to making risk an organizing principle for
FCERM. We are particularly concerned with how efforts to manage the institutional risks of
risk-based policymaking reciprocally influence the efforts by those involved to account for
the limits of their knowledge and for decisions they must take in the face of those
uncertainties.
The paper is organized as follows. After describing our data and methods, we define
our conceptual approach to understanding risk, uncertainty, and governance. An
institutional overview of FCERM in England then sets up two empirical case studies of how
climate change uncertainties about peak flood flows and sea level rise are accounted for in
FCERM. In the first case the poorly understood impacts of future climate change were
represented with a simple precautionary adjustment to peak flow estimates, which proved
institutionally robust, at least in part because its scientific limitations were only partly
acknowledged. By contrast in the second case, greater scientific confidence led to
successively more elaborate guidance on how to represent the science, which in turn
contributed to significant decisional uncertainties about whether and how the uncertain
effects of future sea level rise would be taken into account in FCERM. Comparative analysis
of these two cases then informs some wider reflections about climate change adaptation
and the institutional appetites for uncertainty information.
Case study design and methodology
Our case study used a mixed methods approach combining policy document analysis
with key informant interviews conducted in the summer of 2011. Whereas policy
documents disclose the formal basis by which climate change considerations are
incorporated into FCERM, interviews illuminate the informal processes and ‘backstage’
understandings shaping the design and implementation of those policies and of the science
underwriting them. To exploit these complementarities and the potential for source
triangulation to enhance the validity of analysis, research proceeded iteratively, with data
collection interspersed with periods of analysis.
The sample frame for the interviews targeted informants involved in FCERM at both
the operational (n=9) and strategic policymaking (n=3) levels as well as scientists (n=6)
involved in providing technical advice on climate change and its implications for flooding. In
addition to informants from the Department for Environment, Farming and Rural Affairs
(Defra) and the Department for Communities & Local Government, interviews were
conducted with Environment Agency (EA) staff involved in both strategic policymaking and
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operational FCERM as well as with informants from local authorities selected from across
the EA’s Southwest and Thames Valley regions to represent urban, rural, and coastal areas
exposed to flood risk.
Risk, uncertainty and governance
Risk is a generative concept whose meaning and significance are understood in a
variety of different ways. The sociologist Ulrich Beck (1992) famously theorized that new
incalculable risks like climate change are triggering a more reflexive phase of modernization
concerned with the risks created by modernity itself. For their part geographers have built
on a distinguished tradition of hazards research to consider questions of vulnerability,
resilience, and the adaptive capacity of individuals, organizations, and society as a whole to
cope with external threats to their security (Adger and Brown, 2009).
Instead of a real thing-in-itself, other theorists define risk, along with uncertainty,
ambiguity, ignorance, surprise and indeterminacy, as a term for qualifying our knowledge
about the world and its dynamics (Stirling, 2007; Wynne, 1992). Thus Knight (1921)
classically distinguished risk, where the probability and impacts of an event occurring are
known in advance so that expected gains and losses can be calculated precisely as the
monetized product of the two, from uncertainty, where the range of possibilities is known,
but not the precise probability or consequences of their occurring.
A number of other conceptual traditions approach risk as a practical way of being-inthe-world and of relating to its future unfolding. For Luhmann (2005), risk is about choice
and decision-making in the face of a future that is not simply uncertain, in the technical
sense of being difficult to definitively forecast, but fundamentally indeterminate insofar as it
is shaped reflexively through an open horizon of choices. For Foucaultians, technologies of
risk make the future governable through “calculations about probable futures in the present
followed by interventions into the present in order to control that potential future” (Rose,
2001, p.7). Building on that tradition, recent work in geography has explored how the
potentially disastrous consequences of climate change are rendered governable through
anticipatory risk assessment and pre-emptive risk management, which transform climate
change from a matter of fate to a calculable risk to be managed through conscious policy
choices taken in the face of uncertainty (Lövbrand et al., 2009; Oels, 2013; Webb, 2011).
Alongside this concern with the governance of risks to society, there is also increasing
academic interest in the ways in which governance itself is now being re-organized through
risk (Borraz, 2008; Huber and Rothstein, 2013; Hutter, 2010). Risk is a key tool for so-called
‘better regulation’ (Löfstedt, 2007). Risk appraisals provide the basis for allocating resources
and for prioritizing regulatory interventions by government, while risk-based safety
standards and risk-based enforcement focus policy-making and implementation efforts on
the most serious potential harms, rather than seeking to eliminate risk completely, which is
disproportionately costly to achieve and can distract attention from more serious problems.
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For their proponents, ‘risk-based’ approaches provide a more efficient and rational way of
organizing governance (OECD, 2010). Others, however, see risk-based approaches as
emerging in response to audit and accountability pressures and to new public management
practices of assessing organizational performance in terms of measurable successes and
failures (Power et al., 2009; Rothstein et al., 2006). In this context risk serves to deflect
blame for adverse outcomes by reframing them in terms of acceptable risks that institutions
could not reasonably be expected to prevent (Huber and Rothstein, 2013). From that
perspective, the increasing salience of risk for governance does not reflect, as Beck (1992)
might have it, a response to the external threats to society from climate change, so much as
one to the institutional challenges of governance itself.
As we discuss in the next two sections, this neo-institutionalist approach to risk
governance suggests some new ways to think about the well-recognized paradigm shift in
flood management from engineering flood defences to more-risk based approaches to
managing the hazards posed by flooding and coastal erosion (Butler and Pidgeon, 2011;
Johnson and Priest, 2008; Krieger, 2013; Porter and Demeritt, 2012).
Flood and coastal erosion risk management in England
Recent years have seen substantial changes to the framework and strategy for
managing flooding in England. Under the 2010 Flood and Water Management Act, Defra has
“overall national responsibility for policy” and for allocating central government funding for
FCERM. As a non-departmental public body, the Environment Agency (EA) has long had an
operational role in flood management as the delivery agent for government policy, but the
Act gave it a new strategic role as well. The EA is now “responsible for taking a strategic
overview of the management of all sources of flooding and coastal erosion“ in addition to its
“operational responsibility for managing the risk of flooding from main rivers, reservoirs,
estuaries and the sea, as well as being a coastal erosion risk management authority“ (Defra,
2013) The EA also plays an important role in spatial planning as a statutory consultee on
planning decisions where flooding is an issue. The Act also created ‘lead local flood
authorities’, typically county councils or unitary local authorities, responsible for “local flood
risk management in their areas …[and] for managing the risk of flooding from surface water,
groundwater, and ordinary watercourses” (Defra, 2013), as well as imposing various duties
on highway authorities, water companies, internal drainage boards, and reservoir owners,
among others.
The FCERM strategy being pursued by these agencies in England is explicitly riskbased. Rejecting the traditional emphasis on engineering flood defences to prevent flooding
as “not sustainable” (Defra 2009b: para 60), Defra’s ‘Making Space for Water’ strategy
accepts the inevitability of flooding and seeks to manage the wider strategic trade-offs
between minimizing its probability and consequences as against other competing policy
imperatives, such as the promotion of economic development and brownfield regeneration,
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conservation of wetlands and coastal habitats, and reduction in taxes and public
expenditure. Its strategy makes more explicit than ever before that there “is no right to be
protected from the effects of flooding or erosion and generally no entitlement to any
particular standard of defence“ (Defra, 2009a, p.10), unlike in many other European
countries where there is. Rather, in England‘s risk-based approach to FCERM, policymaking
and implementation are more discretionary and flexible. Different policy measures, yielding
different standards of protection, are applied depending on the balance of costs and
benefits involved in any given case:
To take account of this variability and the permissive nature of its investment,
Government promotes nationally consistent approaches to the assessment and
management of flood and coastal erosion risk, rather than to set national standards for
protection which would be inappropriate and unaffordable in some areas (Defra,
2009a, p.10).
In this context, managing flooding as a risk is about much more than reducing the
probability and consequences of its occurrence. The concept and instruments of risk help to
organize the very conduct of FCERM itself. Risk calculations serve to define the limits of
state protections against flooding, to focus resources on meeting those standards, and to
devolve responsibility for dealing with the ‘residual’ risks “of an event occurring that is more
extreme than the defence structures were designed to cope with” (Defra, 2009b, p.64) onto
those exposing themselves to it. The emergence of such risk-based approaches to governing
flood hazards thus mirrors their widespread uptake across other policy domains in Britain
(Huber, 2009; Hutter, 2010).
With risk assessment so central to FCERM policy formulation and implementation,
Defra has gone to some length to define—and publicly legitimate—the basic procedures for
how it should be done. Lead flood management authorities are required to ensure
“effective public participation and consultation” throughout the appraisal process (Defra,
2009a, p.36). These requirements reflect the widespread hope that opening up risk
assessment and management to external participation will improve both their quality and
public acceptability by promoting a “sound understanding of local issues” and thereby
ensuring that FCERM decisions reflect an “understanding of local people’s preference”
(Chilvers, 2009; Defra, 2009a, p.36). Opening up risk appraisal to participation makes lead
flood management authorities “accountable for the decisions they make and transparent in
the way they take and communicate these decisions” (Defra, 2009a, p.36), but at the same
time it also exposes them to the institutional risk that their legitimacy will be challenged.
To build trust and manage that second order risk to the management of the first order
risks to society from flooding and coastal erosion, risk assessment follows rigid protocols
designed to rule out subjective bias and personal discretion, deflect external scrutiny, and
close off possible grounds for complaint. Standardizing administrative procedures in this
way creates what Porter (1995, p.90) calls a “technology of trust” in which reliance on
mechanically objective procedures substitutes for personally trusting relationships. But this
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reliance tends to render associated promises of accountability and openness vague and
insubstantial, insofar as external challenges to authority are deferred by reference to the
observance of standard operating procedures. Thus queries about the Defra (2009a, p.28)
requirement that the cost-effectiveness of all publicly funded FCERM schemes be assessed
over a 100 year time horizon are met with references to HM Treasury’s (2003) Green Book
on cost-benefit analysis methods, while detailed technical guidance on such contentious
issues as intangible environmental impacts and the valuation of human life (EA, 2010),
serves to pre-empt long-standing controversies over the very application of cost-benefit
analysis to environmental risk management.
Defra (2009a) guidance defines risk in the classical sense as a mathematical product of
the estimated probability and impacts of flooding and coastal erosion. At the same time, it
also acknowledges the inherent uncertainties involved in predicting “these intermittent,
variable, highly uncertain and sometimes extreme natural phenomena” (Defra, 2009a,
p.20). Such epistemic limitations are no bar to incorporating uncertain processes within a
risk-based management framework. Defra (2009a, p.20) requires “operating authorities
…[to] make assessments of probability from past events and project forward using available
information on climate change and other uncertainties”
Traditionally, such assessments have been derived statistically, based on return
periods calculated from historically observed flood frequencies, sometimes supplemented
through regionalizing methods, such as those used in the EA endorsed Flood Estimation
Handbook (Institute of Hydrology, 1999), to substitute space for time and amass a longer
time series of flood events by comparing their observed frequency on catchments with
similar characteristics. But with climate change altering the boundary conditions controlling
flood frequency, such methods are increasingly problematic (Milly et al., 2008). At the same
time, the technical challenges in assessing the full cascade of uncertainties involved in
delineating areas at risk of flooding under future climate change scenarios remain enormous
(Cloke et al., 2010; Lane et al., 2011), and so for reasons of cost, complexity, and
administrative consistency, the Environment Agency’s first national Flood Map simply
ignored the added risks from climate change rather than acknowledge uncertainties that
might have been used to challenge its advice on planning applications (Porter and Demeritt,
2012). Rapid developments in the underlying science of climate change risk assessment
mean that response is no longer necessary, nor particularly credible. But as we discuss in
the next section, assessing the uncertain impacts of climate change on flood risks involved
some institutional uncertainties of its own.
Managing uncertainty and the institutional risks of climate change assessment
Climate change is likely to alter the risks to society from flooding and coastal erosion
through two distinct physical processes. First, changes in the hydrological cycle may alter
the frequency of inland flooding and through feedbacks on land use, snowpack, and soil
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moisture, its magnitude as well. These processes are complex, and there is only limited
scientific confidence in associated estimates of the implications of climate change for the
frequency and magnitude of peak flood flows in England (Cloke et al., 2010; Lane et al.,
2011; Reynard et al., 2005). Second, rises in sea level will increase the rate of coastal erosion
and the associated risks from coastal flooding, and there is greater scientific confidence
about the increases in sea level due to thermal expansion of the oceans (Defra, 2006a). 1
These climate change processes are incorporated into FCERM through two parallel
assessment and planning processes focused on inland flood risk and on risks to the coastline
from coastal erosion and storm surge flooding respectively. Both assessment processes are
governed by the same Defra guidance on how climate change should be taken into account
and by virtue of this as well as the fact that many of the same lead flood authorities are
involved, the two processes are closely coupled. And yet, as we discuss below, these parallel
assessment processes pursued contrasting approaches to managing the scientific
uncertainties about the impacts of climate change and the associated institutional risks of
adapting FCERM to them.
Climate change and peak flood flows
The management of inland flood risk is informed by two distinct risk assessment
processes. First, the EA recently completed updating 77 Catchment Flood Management
Plans (CFMPs) for the main rivers in England and Wales. CFMPs were first required following
major flood events in 1998 and 2000 so as to provide a holistic overview of fluvial flood risks
at the catchment scale, rather than the fragmented administrative geography through
which those risks were being managed. The latest generation of CFMPs now “consider all
sources of inland flooding: from rivers, ground water, surface runoff and also tidal flooding
from rivers and estuaries” but excludes “flooding directly from the sea”, which is considered
as part of the EA’s parallel Shoreline Management Planning process (EA, 2013, p.1).
Supplementing the broad overview provided by the National Flood Risk Assessment, the
more detailed CFMPs are used by the EA to prioritize its own investment and maintenance
decisions as well as informing its interactions with other stakeholders, such as lead local
flood authorities and local planning authorities, and the EA is now also working on adapting
the CFMPs to fulfil its obligations under the EU Floods Directive. As a catchment-scale
overview of flood risks, CFMPs outline broad strategies and priorities for investment rather
than specifying particular FCERM schemes or allocating resources for them. Accordingly, a
recent study found that they have only limited influence on the SFRAs undertaken by local
planning authorities (Thurston et al., 2010).
However the potentially much greater volumes of future sea rise due to accelerated melting of the
Greenland and Antarctic ice sheets, like the effects of climate change on coastal flooding and erosion risk due
to potential changes in the frequency, magnitude, and location of extra-tropical storms, are considered too
uncertain to quantify reliably and so were simply ignored by Defra guidance as if these uncertain hazards did
not exist all.
1
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These SFRAs are the second major assessment process informing the management of
inland flood risks in England. First required of English Local Authorities (LAs) by the 2006
revisions to the PPS25 guidance on flood risk (DCLG, 2006), SFRAs are supposed to ensure
that LAs and developers alike take appropriate notice of current and future flood risk when
planning for local development. Based on more detailed local modelling than the CFMPs,
SFRAs are still strategic in the sense that they provide an overview of flood risks across the
entire LA, rather than the very detailed flood risk assessment required for individual project
level planning decisions (Porter and Demeritt, 2012).
Defra prescribed how these flood risk assessment processes should account for the
impacts of future climate change. For river floods Defra (2006a, p.4) proposed a “single
precautionary allowance” for the period 2025 to 2080 that would increase peak river
discharges on all major catchments by 20%. The uncertain possibility of changes in future
flooding due to climate change was thus transformed into a calculable risk by adding 20% to
historically observed peak discharge values. This adjustment does not consider how climate
change may alter the relative frequency and magnitude of flooding from intense summer
rainfall or from winter low pressure systems (Pall et al., 2011), but simply takes the current
probability density function and shifts the entire curve to the right, “making a flow with a
probability under current climate more frequent as a result of future climate change” (Lane
et al., 2011, p.1797). Despite these limitations, the 20% increase in estimated peak flow
values was endorsed as “appropriate as [a] precautionary response to the uncertainty of
future climate change impacts on flood flows” in a peer reviewed evaluation study
commissioned from consultants by Defra and the EA (Reynard et al., 2005, p.61), and lead
flood authorities ordered to use it “until further updates are provided” (Defra, 2006a, p.3).
Although Defra (2006a, p.3) acknowledged “significant uncertainties” both in climate
change predictions themselves and in their estimated impacts on peak flows, awareness of
these limitations varied widely among interview informants. When asked about uncertainty,
scientists were usually quick to note how difficult it is to quantify the effects of climate
change on the coupled processes of rainfall and runoff. Some also acknowledged how the
full scope of uncertainty about future flood risk was closed off by the use of the 20%
adjustment to peak flows, as one informant who had been heavily involved in preparing the
latest UKCIP09 climate scenarios went on to explain to us:
“it is a very difficult thing to come up with a quantitative number of how much heavy
rain will change and peak flows. We don’t really go there. We're only really looking at
the rainfall. Even in terms of the rainfall, there's a lot of uncertainty. There are a lot of
seasonal differences. To some extent, there are some regional differences across the
UK as well” (Int 11).
All of the scientists interviewed expressed awareness of recent developments in regional
climate modelling since the publication of Defra’s 2006 guidance, and a few were also aware
of the work, still ongoing at the time of the interviews, to revise the climate change
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guidance so as to take account of the latest probabilistic UKCP09 scenarios provided by the
Met Office Hadley Centre (EA, 2011).
There was also some awareness of these limitations among the 3 informants working
in strategic policy making roles (Int 6, 8 9). Pointing to the regionally differentiated
projections provided by the latest UKCP09 projections, one policy-maker noted that the
problems of applying the 20% increase uniformly were clear enough to see, at least in
retrospect:
“But having looked at that again in UKCIP09, it's apparent that there's a huge
amount of variation in there. Some areas it's 20% and 50% and it's all depends on the
local conditions” (Int 6; similar Int 8).
But s/he was also quick to defend the 20% figure, albeit on instrumental as much as
scientific grounds:
“It was the best figure we had in previous UK CIP2, but it’s very shaky. It was basically
better than nothing. We had that figure because we found from experience that if
local people don’t have specific instructions, they won't do anything. So what we did
is we gave them some indicative figures” (Int 6).
Having been involved in revising PPS25 on flood risk, this informant was acutely conscious of
the need for clear and unambiguous guidance to drive the policy process and reduce the
institutional risks of taking action. Five years ago, “people weren't doing anything about
climate change… because … everything was based on the Environment Agency flood zones,
which are just snapshots” that ignored future climate change altogether (Porter and
Demeritt, 2012). But with the revised Defra guidance, “they [now] have to take into account
climate change” (Int 6) when preparing the SFRAs required by PPS25.
In this context the attraction of the number was not its scientific robustness relative to
existing climate projections—its reasonableness as “the best figure we had” at the time was
largely taken for granted-- but instead its role in resolving the institutional uncertainties
about whether and how lead flood authorities should take climate change into account.
Specifying “some indicative figures” was the only way policymakers at the strategic level
saw for getting “local people” at the operational level to take the uncertain but nevertheless
calculable risks from climate change into account in their long term planning.
Interviewees working at the operational level and involved in preparing CFMPs and
SFRAs reported no such uncertainties, either about the treatment of peak flows or the
science underpinning it. Only 2 out of the 9 operational-level informants could say anything
about where the 20% allowance had come from or the uncertainties associated with it. Its
scientific basis was of no interest. All that mattered was that they had a number to follow,
and, if challenged, some guidance to point to so as to justify the choice. Its validity and
appropriateness were accepted without question. Indeed, when pressed, an EA official
involved in operational FCERM simply retorted: “Why should people question it? Why? We
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have a policy and this is the way we're going to do it” (Int 2). If doubts about the number
were expressed, they were typically downplayed:
“Again we're talking about a 100-year extent. That 20% extra flow doesn't make a lot
of difference in terms of extent. It may make a little bit more on damages. But again if
you're already flooded, what would that extra mean?” (Int 10).
His somewhat blasé attitude partly reflects the relative insensitivity of flood risk estimates
to the additional 20% peak flow adjustment as well as the very distant time horizon over
which it is being applied. Both tend to attenuate public interest in the results of those
climate change risk assessments and thus the institutional risks of being challenged over
them.
By contrast, operational staff were very concerned about potential uncertainties and
inconsistencies in how present-day exposure to flood risk is calculated and then
communicated externally. Different types of flooding and different datasets and models for
assessing them result in different estimates of the number and location of properties at risk.
While there are good scientific reasons for those variations, members of the public do not
always understand or accept them, and operational officials can face criticism as result, both
from the public at large and, in particular, from their elected representatives. Expressing a
sentiment shared by many interviewees, one informant explained, “It's a minefield. It's a
very tricky one” (Int 2). He explained how much effort the EA was devoting to pre-empting
possible criticisms of the numbers used in the CFMPs and other risk assessments:
“A colleague of mine, his task at the moment is looking at all these numbers of
properties and start to say which one as a region will we quote when asked. We get a
standard list of questions which we expect the media to ask us. We'll have an answer
which we can all say the same” (Int 2).
Similar pressures face local authority officials involved in developing operational SFRAs,
and they too devote considerable effort to trying close off potential lines of external
complaint. One local authority informant explained how in preparing a SFRA, he was already
anticipating the external scrutiny it would have to withstand:
“I wanted to be able to come up with an assessment that treated everywhere the same,
so that if a councillor says ‘why isn't my town listed as a flood risk area?’, I can say we
did this assessment and it didn't come up that high” (Int 4).
Defensibility was more of a concern with assessing present-day exposures than with the
temporally distant risks from climate change, but in both cases the institutional need to
guard against criticism influenced the ways that uncertainties were framed and transformed
into governable risks.
Sea level rise and coastal flood risk
Just as the CFMPs do for inland flooding, Shoreline Management Plans (SMPs) set out a
long-term strategic framework for managing coastal flooding and erosion, though unlike the
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CFMPs, SMPs are not strictly required by Government regulation. Instead they are prepared
on a formally voluntary basis by cooperating authorities to improve policy coordination and
inform deliberation over whether and where to hold the line against the sea. The first
generation of SMPs was produced in the mid-1990s amidst rising awareness of both the
threats from coastal erosion and of the costs to the public purse and potentially to
neighbouring areas of trying to defend existing coastlines against the rising tide. A total of
11 SMP1s, each subdividing the coast into a number of physically coherent sediment ‘cells’
within which the movement of sand and shingle is largely self-contained, were completed in
that first round, and many of their recommendations are now embedded in local authority
development plans, FCERM investment and maintenance plans of regional EA offices, and
the biodiversity action plans developed by Natural England, among others.
Defra regards the SMPs ‘living documents’ and is encouraging authorities to revise and
update their SMPs to take account of the latest research on climate change as well as its
expectation that the planning horizon be extended from 50 years out to 100. To support
those revisions, Defra published, in 2006, two lengthy volumes of revised Shoreline
Management Plan Guidance detailing the aims and requirements (vol 1) and procedures (vol
2) for a second generation of SMP. Then in October of that year, a further “supplementary
note to Operating Authorities” set out instructions for how climate change impacts should
be taken into account in these and other planning processes (Defra, 2006a).
The 2006 climate change guidance framed the underlying evidence-base about sea
level rise and associated coastal flood risk as having substantially “improved, leading to
greater certainty” compared to earlier assessments (Defra, 2006a, p.4). The first generation
of SMPs had used figures for regional rates of sea level rise set out in by the Ministry for
Agriculture, Fisheries, and Food (MAFF 1993) in its official Flood and Coastal Defence Project
Appraisal Guidance Note (PAGN). The PAGN figures, in turn, were derived from estimates
published in the first IPCC assessment report (Warrick and Oerlemans, 1990). In 1999, MAFF
substantially expanded and revised its project appraisal guidance for coastal and flood
defence, but left its recommended allowances for sea level rise unchanged from those
originally set out in the 1993 PAGN based on IPPC projections from 1990. As MAFF
explained in the third technical volume of its appraisal guidance (sometimes referred to as
FCDPAG3), while sea level rise projections are “continually being refined” to take “more
complex feedback effects … into account”, they must be “treated with caution”, and “with
the degree of uncertainty involved, there is no current justification” for changing the
previously published estimates (MAFF, 1999, p.43–44). By 2006, however, Defra’s (2006b,
p.26) SMP guidance could point to the UKCP02 climate scenario work done under the UK
Climate Impacts Programme as well as the extensive research on future flooding
commissioned by the Government’s foresight programme (OST, 2004) as the scientific basis
for issuing more detailed and spatially and temporally precise projections of sea level rise
than were used for the very first SMP1s.
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Kuhlicke & Demeritt, Institutional Geographies of Adaptation
Such confidence meant the approach taken to translating the uncertain impacts of
climate change on sea level into a calculable risk was very different to that followed for
estimating future peak flows under climate change. Whereas a uniform adjustment was
made to all peak flows over time, on the grounds that they were too poorly understood to
treat in a more detailed and dynamic way, Defra (2006a) recommended using an
exponential curve for sea level rises to reflect the latest IPCC projections about how they
will evolve dynamically over time. This dynamic approach departs from the assumption of a
steady linear increase outlined in the 1999 guidance used for the preparation of the SMP1s.
When asked to explain the change, one local authority informant did not reflect much on
the evolving science, despite some probing. Instead he simply replied:
“It was originally 5 per year [for the South West] and then we received more specific
numbers. So [now] there is a curve” (Int 4; cf. also Int 10).
Furthermore, unlike the universally applied 20% adjustment applied to peak flows, sea level
rise projections are also regionally differentiated to reflect differences in sea level due to
local land subsidence and isostatic post-glacial rebound of the earth’s crust. Whereas the
north of England is expected to rise on the order of 0.8mm/year over the next century, the
land surface across the East of England, East Midlands, London and the South East of
England is projected to recede by 0.8mm/year. But these regionally differentiated
assumptions about isostatic rebound are not the main reason that different planning
documents often made wildly inconsistent assumptions about future sea level rise affecting
the same or adjoining stretches of coastline (FIGURE 1).
Rather inconsistencies were created by the institutional geographies of FCERM itself.
The SMPs were not the only FCERM plans making allowances for future sea level rises. Sea
level rise assumptions were also made by a number of CFMPs to inform their assessments of
flood risk to tidal estuaries, and these assumptions often differed from those made in SMPs.
Inconsistencies were further magnified by several other features of the institutional
configuration of FCERM. The SMPs and CFMPs were institutionally distinct processes
involving different sets of actors and proceeding according to various, locally determined
timetables without any formal mechanisms for coordinating the one with the other, despite,
typically, some involvement by staff from EA regional offices in both processes. Moreover,
these two FCERM planning processes were also based on fundamentally different
administrative geographies. The 77 CFMPs (whose boundaries are outlined in figure 1) were
organized according to a riverine geography of catchments and fluvial flooding that was very
different to the sediment cells and more localized ‘policy units’ that were the foundation for
the 22 SMPs with their focus on coastal erosion and the risk of storm surge flooding direct
from the sea. These different administrative concerns led them to cut up the coastline in
different ways for which they devised different management plans based on different sea
level rise allowances generated through different local assessment processes.
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Kuhlicke & Demeritt, Institutional Geographies of Adaptation
FIGURE 1. Sea level Rise Allowances (mm) used for the second generation SMPs (blue,
outer line) and CFMPs (green, inner line) for England and Wales. The differing magnitudes
of assumed sea level rise for the years 2085 (SMPs) and 2100 (CFMPs) are represented by
the thickness and hue of the various line segments. Their length represents the different
stretches of shoreline to which those assumptions were applied in various SMP and CFMP
planning documents prepared as part of two separate revision processes, based on different
administrative geographies and observing different central guidance depending on how far
revisions to local baseline planning assumptions had progressed when Defra (2006a)
guidance superseded FCDPAG3 (MAFF 1999). Coastal segments for which there is no
information about sea level allowances, either because the revisions to the CFMPs and
SMPs were not yet complete or the sea level rise assumptions not publicly available online
at the time of writing, are represented with a dotted line. The boundaries between the 77
CFMP areas are outlined in grey.
Finally, inconsistencies also arose from the diverse temporalities involved in FCERM
assessment and planning processes. As ‘living’ documents, the CFMPs and SMPs are
expected to keep up with the latest science. Indeed their legitimacy, like that of the climate
change guidance issued by central government, depends on it, and so official guidance has
repeatedly emphasised that “as understanding of climate change improves guidance will be
updated” (Defra, 2006a, p.2; MAFF, 2001, p.21). But the process of revising central
guidance was not closely coupled to the timetable for local revisions to the SMPs and
CFMPs. Updating these plans can take years, and with different authorities proceeding at
different speeds, and the background guidance subject to regular updates to maintain its
scientific currency and the institutional credibility of the Government departments
14
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
responsible for it, different planning processes followed different sets of central guidance
about how to treat the uncertainties about future sea level rise. As one informant recalled:
“We were working on the standard guidance when there was the UKCIP02 that came
out. That had the lower levels of sea level rise estimates. So some of the early
catchment flood management plans started working on that. But then we got the
2006 DEFRA guidance for the operating authorities and that used the later version of
the climate change levels.
The combined effect of these institutional processes was that radically different
assumptions about future sea level rise could be applied to the same or adjoining stretches
of coastline by different planning processes. For example, the CFMPs for the Wye and Usk
and for the Welsh side of the Severn Estuary, prepared by the Wales regional office of the
EA, assumes 1000 mm sea level rise by 2100, or twice as much as the 500mm rise assumed
by the CFMPs for North and Mid Somerset and the Parett catchment on the English side of
the Severn, prepared by officers from the EA’s Southwest region office. Both these
estimates are different again from the 700mm of sea level rise by 2085 assumed by the
revised SMP2 prepared by the Severn Estuary Coastal Group, comprising nine English and
Welsh county councils and unitary authorities, two Inland Drainage Boards, English Nature,
the Countryside Council for Wales, and the Wales and Southwest Region offices of the
Environment Agency.
These inconsistencies were a subject of considerable concern to those working at the
operational level on developing-- and then defending through the required public
consultation processes—SMPs. One EA official explained that inconsistencies created
“problems” (Int 10) for he and his colleagues, particularly during the required public
consultation phases of FCERM planning, when they needed to explain why one SMP was
basing its deliberations about whether and where to defend particular areas against coastal
erosion and flooding from the sea on different sea level allowances than those used
elsewhere. Public pressure could be intense, as one local authority informant explained:
“Coastal erosion, storms, and all that kind of things. People are fairly aware of it and they
can become quite nasty about it” (Int 5).
Such deliberations were particularly fraught, because assessments of the number of
properties at risk of flooding are quite sensitive to assumptions about sea level rise. Changes
of even a few centimetres in projected sea level rise due to climate change are much more
consequential for assessments of risk than the adjustments made to peak flows to account
for the consequences of climate change:
“So even if you add on 20% of extra flood, it's not really impacting on any more
properties. The sea level rise, it suddenly changes everything. The places that weren't
thought of at risk becomes in the risk zone” (Int 10).
Several informants noted the difficulties of conveying that message to those at risk:
15
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
So it's a lack of believability for some people in the higher levels of predictions.
You've got a real problem in actually getting them to think about the response ahead.
I had one little community which when you look at . . . the road runs right along the
back of the beach. Even the coastal engineer down there says . . . ‘the highway, we
can't lose that, it's got to stay there’…. But the model is saying well, you could be
seeing it retreat going 20m, not a huge distance, but that's going to almost take up
the highway. ” (ManU9).
Discussion and conclusions
There are important differences in the framing and management of climate change
uncertainties about peak flood flows and sea level rise, two ostensibly similar and tightly
coupled FCERM processes. In the face of high levels of scientific uncertainty about the
impacts of climate change on peak flood flows, risk assessment incorporated a blanket 20%
increase in peak flows so as to translate those uncertainties into a calculable number to
inform risk-based management. Although this representation of the underlying processes
was scientifically crude and readily acknowledged as such by the scientific experts involved,
operational policymakers did not see it that way. For them, the 20% adjustment was easy to
understand and to apply in a consistent way, and this institutional convenience, in turn,
reduced the institutional risks about whether and how climate change would get taken into
account in FCERM planning and policymaking, even as it tended to close down the space for
institutional reflexivity about the uncertainties buried within it, which were framed in quite
different ways by those working in operational policy development and implementation as
against those at the broad strategic level and the experts involved in conducting the
underlying scientific assessments.
The dynamics in the case of sea level rise offer some interesting contrasts. Here, the
underlying scientific knowledge was framed as rather solid (particularly in relation to peak
flood flows) and policy guidance sought to reflect this with much more spatio-temporally
precise and detailed advice about how the uncertainties about future sea level rises should
be translated into calculable risks to be anticipated and managed. The sensitivity of risk
assessment to assumptions about sea level rise made the scientific credibility of those
allowances critical, but in the effort to shore up their credibility and to protect its own
reputation for sound, science-based advice about how to represent and manage those
uncertainties, strategic level policy makers at Defra and its predecessor MAFF regularly
reviewed and revised their guidance. However the timing of these revisions in policy
guidance was only loosely coupled to implementation. Cooperating authorities had their
own timetables for revising their CFMPs and SMPs, which was a long and drawn out process
that proceeded at different speeds in different regions and accordingly made different
allowances for sea level rise depending on the guidance prevailing at the time the
assessment for a plan was being prepared. The resulting inconsistencies in the assumptions
about sea level rise made then created uncertainties about whether operational plans for
16
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
managed realignment of the coastline would face public challenge, given the political
contentiousness of the entire issue and the sensitivity of estimated numbers of property at
risk to even small shifts in sea level rise allowances.
Operational level staff were acutely conscious of these risks to the authority of their
risk assessments and thus to the legitimacy of the policy decisions that were to be based
upon them, and they sought to deal with them by closing down the space for challenging
decisions taken. This response, in turn, tended to subvert the stated purpose of the CFMPs
and SMP process as a means for encouraging deliberation and reflexivity about the long
term strategic challenges of climate change.
Our two cases highlight the institutional geographies shaping risk governance and
climate change policy. Adaptation decisions depend on scientific assessments, and a wealth
of recent research has explored the ways in which these coupled but institutionally distinct
processes are co-produced and mutually constitutive (Lane et al., 2011; Lövbrand, 2011;
Shackley and Wynne, 1996; Webb, 2011). Whereas the SFRAs are rhetorically positioned as
an assessment process that merely informs but is institutionally distinct from and does not
determine planning policy for FCERM (Porter and Demeritt, 2012), the CFMP and SMPs did
not try to distinguish scientific risk assessment from political risk management quite so
sharply, even as the authority for their policy decisions still depended on the rhetoric of
being science-based and was therefore vulnerable if the credibility of the underlying science
were to be challenged. Those involved in FCERM were very conscious of these risks to their
institutional authority, and their efforts to guard against them exemplify a wider “defensive
dynamic” (Power et al 2009: 309) in the organizational culture of risk management in Britain.
Two distinct strategies for managing these institutional risks can be identified from
our cases. First, in the case of peak flood flows, challenges to the 20% adjustment were
managed through deferral of responsibility and blame deflection. Operators avoided
personal responsibility for adding this arbitrary figure by pointing to the guidance and to the
wider institutional requirements to follow it, while at the strategic level those responsible
for formulating that guidance appealed to the ‘science’ and to the independent peer review
commissioned by Defra to legitimate it. The second common strategy is what Hood and
Rothstein refer to as “prebuttal”, by which institutions seek to respond “to anticipated
criticisms or demands for information before they materialize” (Hood and Rothstein, 2001,
p.41). Protecting against such criticisms is one reason why Defra is so keen to keep updating
guidance. Its decision to make a single arbitrary adjustment to peak flow values, while
making more detailed and spatio-temporally precise allowances for future sea-level was
shaped, in no small part, by institutional considerations about defending those decisions, as
was the subsequent implementation of that guidance by operational-level policymakers
responsible for conducting SFRAs, CFMPs, and SMPs. Our two cases thus highlight how this
concern with defensibility and with managing the second-order institutional risks to the
reputations of those involved in FCERM influence the ways in which the first-order risks to
society from climate change are themselves understood and managed.
17
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
But the role of risk assessment in FCERM is about more than just not just legitimation.
The broad strategy for FCERM in England is explicitly risk-based, with policies for managing
the risks to society from flooding relying on risk concepts and instruments to organize the
very conduct of that management. Such risk-based governance depends on translating
scientific uncertainties about the impacts of climate change on the probability and
consequences of flooding and coastal erosion into calculable risks that can be governed
through risk-based resource prioritization and other strategies for risk-based management.
In this paper we have highlighted the institutional dynamics shaping the ways in
which those uncertainties are framed and managed as risks. Our two cases show that
increased scientific certainty about climate change does not necessarily lead to more certain
policy outcomes. Despite being regarded by experts as, at best, a makeshift measure until
the science could be developed well enough to provide more spatio-temporally precise
estimates of peak flows, the 20% adjustment proved to be an institutionally robust way to
get long term plans for fluvial flooding to take the added risks from climate change into
account. With sea level, however, efforts to keep the guidance up-to-date with the very
latest scientific advances made institutional implementation of that guidance more difficult
and increased the institutional uncertainties about whether and how to adapt shoreline
management plans to the risks posed by future climate change. These institutional risks
arose, not so much from the limitations of scientific knowledge of climate change as from
the very institutional architecture for translating those uncertainties into actionable policy.
Our research thus suggests reasons for caution about the heavy emphasis given in
climate change research and policy making to generating ever more elaborate and
probabilistic scenarios of future climate change to underpin policy making (LWEC
Partnership, 2011). While it is certainly important to clarify and correctly communicate
scientific uncertainties, this is not sufficient for robust policymaking, particularly if it fails to
acknowledge the conflicting interests and institutional demands of the various actors
involved in science-policy processes. Indeed several recent studies have pointed to
situations in which probabilistic representations of scientific uncertainty, so prized by the
climate research community, are not simply unwanted by those charged with policy
decisions but actively resisted (Demeritt and Nobert, 2011; Tang and Dessai, 2012). This
paper has highlighted the importance of acknowledging those institutional dynamics and
the ways in which they shape the framing and response to scientific uncertainties and risk. If
these considerations about the practical use of science in governance continue to be
ignored, there is a risk not just of poorer adaptation policy, but also of poorer science too,
insofar as climate policy processes reciprocally influence the underlying science.
Acknowledgements
Research was funded by grants from the European Commission (FP7-People-IEF-2009 Grant
agreement No. 253773) and ESRC (ES/K006169/1). We gratefully acknowledge the
constructive feedback offered on an earlier draft by Anne-Laure Beaussier, Lukasz Erecinski,
18
Kuhlicke & Demeritt, Institutional Geographies of Adaptation
Phil Hendy, Luckas James Porter, Henry Rothstein, David Self, Sam Tang, Dominic Way, Mara
Wesseling, and Rob Wilby.
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