Consultation outcome

Summary of responses: consultation on reforming our approach to floods funding

Updated 14 October 2025

Introduction 

Purpose and background 

The summary of responses includes a detailed analysis of responses to the public consultation on reforming our approach to flood and coastal erosion risk management (FCERM) funding.

It also provides a high-level summary of initial findings from the analysis of the responses to: 

• the call for evidence on alternative sources of funding for FCERM 

• the call for evidence on local choice, English devolution and opportunities for FCERM 

The consultation and two calls for evidence ran for 8 weeks from 3 June until 29 July 2025. The consultation sought views on proposals for a new approach to funding FCERM projects. It focused specifically on how we can simplify our approach, speed up delivery, and respond to the changing nature of risk.   

The current partnership funding formula was established more than a decade ago. It slows down the delivery of new flood schemes through a complex application process and neglects more innovative approaches such as natural flood management.

Defra’s aim is to ensure that funding for FCERM projects is distributed more effectively across the country. This will help to protect properties across all communities including in rural, coastal, and more economically deprived areas.  

The consultation and calls for evidence were published on the online digital platform Citizen Space which recorded responses through an online form. Responses were also received by email and post. 

Overview of consultees 

A total of 380 individual responses were received, of which 104 were submitted by email, 1 by post and 275 through the online form.  

Of the 298 consultees who answered Question 5 (‘Who are you responding as?’), the breakdown by group was: 

• local authorities – 94 (32%) 

• individuals – 52 (17%) 

• environmental groups – 30 (10%) 

• internal drainage boards – 21 (7%) 

• water and sewerage companies – 7 (2%) 

• farmers or landowners – 5 (2%) 

• insurance companies – 3 (1%) 

• other – 86 (29%) 

We are grateful to everyone who took the time to respond to this consultation, as well as for the detailed and well considered views we have received.   

Methodology 

How we analysed responses 

We asked consultees to answer 47 questions: 

• questions 1 – 6 asked for consultees’ details 

• questions 7 – 31 sought views on the 3 parts of the consultation 

• questions 32 – 38 related to the call for evidence on alternative sources of funding 

• questions 39 – 45 related to the call for evidence on local choice, English devolution and opportunities for FCERM 

• question 46 and 47 asked for feedback on the consultation tool 

The consultation included both closed questions (that gave a limited range of answers to select from, for example ‘agree’ or ‘disagree’) and open-ended questions (where consultees could provide free text).  

Responses to closed questions were collated for analysis. Responses to open-ended questions were analysed individually to identify key recurring themes.  

The large majority of consultees (314 of 380 responses, or 83%) followed the format of the consultation document and provided answers that could be clearly assigned to questions 1 to 47. The analysis of these responses is included under each question in the Summary of consultation responses section.

We also received 66 responses in free text format. It was often not possible to link the answers to questions 1 to 47. They were analysed separately in terms of support or opposition to the proposed reforms, prioritisation approaches and transition arrangements. The findings can be found under the ‘other email responses’ section.  

Some consultees submitted answers in more than one format (via the online form and email). Multiple responses from the same respondent were counted as one response.  

Some consultees submitted very similar or identical responses, including one campaign where 25 individuals responded as part of a co-ordinated effort. All these responses were read and analysed individually.  

Reporting terminology 

Not all consultees answered all questions.  

When reporting different responses to closed questions, we have reported proportions of total responses as percentages. Percentages are rounded to the nearest whole number. Total percentages therefore may not always add up to 100%.

Where there was a notable difference (>5%) in responses between risk management authorities (RMA) and others, we have also provided a breakdown of responses by respondent type. We have differentiated between risk management authorities and non-risk management authorities (non-RMA).

Risk management authorities included:

• local authorities 

• water or sewerage companies  

• internal drainage boards   

Non-risk management authorities included:

• individuals 

• farmers and landowners  

• environmental groups  

• insurance companies 

• other 

Consultees who did not answer Question 5 (‘Who are you responding as?’) have been excluded from these breakdowns. The tables in the summary of responses section will show the total responses in the breakdown is less than the total responses received.

The summary of responses to open-ended questions is not an exhaustive list of all ideas provided by consultees. It focuses on the top three themes for each question to provide a concise overview of the most prominent feedback. 

We’ve used the following terms to describe the frequency of responses to individual questions: 

• ‘large majority’ refers to answers given by more than 80% of consultees 

• ‘majority, most’ refers to answers given by 51% - 80% of consultees 

• ‘even number (of consultees)’ refers to answers given by approximately equal numbers of consultees (to the nearest whole percent) 

• ‘many’ refers to answers given by 21% - 49% of Consultees 

• ‘small number, several, few, some’ refers to answers given by 20% or less of consultees

Summary of consultation responses 

Changing our approach to funding flood and coastal erosion projects  

Part 3 (Questions 7 to 22) in the consultation sought views on the proposed changes to funding for flood and coastal erosion projects.  

The changes proposed in the consultation were: 

• a contribution free allowance of £3 million to be applied to all schemes (Principle 1) 

• a 90% flat rate of government funding to be applied to costs above £3 million (Principle 2) 

• fully funding all FCERM refurbishment projects (Principle 3) 

This section of the consultation also included the following additional considerations: 

• boosting investment in natural flood management 

• our approach to property floods resilience measures 

• the 2012 rule 

Question 7: To what extent do you agree with our overall proposed approach to funding FCERM projects as set out in part 3?

We received 294 responses, 30 via email, 1 via post and 263 via the online form. 

Results show strong support for the overall proposed approach set out in part 3. The majority of consultees (79%) said they agreed or strongly agreed.  

 In response to this question: 

• 45 (15%) strongly agreed 

• 188 (64%) agreed 

• 27 (9%) were neutral 

• 23 (8%) disagreed 

• 6 (2%) strongly disagreed 

• 5 (2%) didn’t know

Table 1 shows a breakdown of responses to question 7 for risk management authorities (RMA) and non-risk management authorities (non-RMA):

Response options	No. of RMA	RMA %	No. of Non-RMAs	Non-RMA %
Strongly agree	8	7%	36	22%
Agree	88	75%	91	55%
Neutral	13	11%	14	8%
Disagree	5	4%	16	10%
Strongly disagree	1	1%	5	3%
Don’t know	2	2%	3	2%
Total	117	100%	165	100%

Question 8: Please explain your answer to Question 7.
 

We received 293 responses, 34 via email, 1 via post and 258 via the online form. 

Most consultees agreed that the proposed reforms would help to simplify the process for seeking FCERM funding from government. Several consultees mentioned that the removal of the partnership funding calculator was welcome.

However, it was also mentioned that the process would only be simpler and fully effective if scheme appraisal and approval processes were simplified in parallel and if the effort required to obtain funding becomes proportionate to the size of the project.  

The wider environmental and societal benefits that schemes can deliver were also mentioned frequently. Consultees wanted the process to be comprehensive in capturing all benefits, both monetisable and not. There was support for the proposal to update the assessment and appraisal process for natural flood management projects.

Consultees highlighted the multiple benefits they can deliver, but also that the modelling costs can be disproportionately high for these types of schemes. There was also a call to reassess the appraisal process for coastal schemes to better capture the benefits of coastal environments. Some consultees raised concerns that without wider changes to funding rules, other benefits that FCERM schemes deliver would continue to be disregarded.  

Another common theme concerned programme overheads and the disparity between the Environment Agency’s and other RMAs’ resources. This was a particular concern because other RMAs are increasingly delivering a large part of the investment programme.

Comments included calls for a new resourcing model for internal drainage boards. It was also mentioned that, if delivery of FCERM schemes was expanded to non-RMAs, there should be a mechanism to recover their overheads. 

Question 9: Are there any other approaches to funding flood projects you feel would be effective?

We received 256 responses, 34 via email, 1 via post and 221 via the online form. 

Consultees frequently mentioned the need to consider wider benefits in project funding assessments than those directly linked to reduced flood risk, and to enable more collaborative working across potential beneficiaries. Examples mentioned included better alignment with water company funding cycles or Defra’s Environmental Land Management schemes.

There were also calls for more cross-departmental alignment to deliver multiple benefits, with consultees saying funding streams are currently too siloed.  

Consultees were also in favour of retaining a mechanism for co-funding and partnership working. They called for more to be done to bring in private and third-party contributions, for example from developers.  

Many consultees advocated for a greater focus on holistic, landscape-scale, catchment-based approaches to FCERM, for example through natural flood management.  

Question 10: To what extent do you agree that Principle 1 is an appropriate way to fund FCERM projects?
 

Principle 1 is the first £3 million of eligible project costs to be notionally provided by Defra through a contribution free allowance.   

We received 289 responses, 30 via email, 1 via post and 258 via the online form. 

The majority of consultees (79%) either agreed or strongly agreed with the proposal to notionally provide the first £3 million of eligible project costs from Defra grant funding.  

 In response to this question: 

• 81 (28%) strongly agreed 

• 148 (51%) agreed 

• 29 (10%) were neutral 

• 21 (7%) disagreed 

• 5 (2%) strongly disagreed 

• 5 (2%) didn’t know

Table 2 shows a breakdown of responses to question 10 for RMA and non-RMA:

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Strongly agree	27	23%	52	33%
Agree	64	54%	75	47%
Neutral	17	14%	12	8%
Disagree	5	4%	16	10%
Strongly disagree	3	3%	1	1%
Don’t know	2	2%	3	2%
Total	118	100%	159	101%

Question 11: Please explain your answer to Question 10.
 

We received 270 responses, 30 via email, 1 via post and 239 via the online form. 

Many consultees mentioned the positive impact this change would have on smaller-scale schemes in particular.

Consultees highlighted that it would reduce the administrative burden that has been a barrier to their delivery. Consultees thought this change would enable more schemes that target smaller communities, which have previously struggled to attract funding (for example, in rural areas).

It would also enable more innovative approaches such as natural flood management, sustainable drainage systems and property flood resilience.

However, consultees also raised concerns that it could create perverse incentives for project teams. For example, they may divide up larger schemes or underestimate costs in an attempt to stay below the £3 million threshold.  

Many comments focused on the impact of the £3 million contribution free allowance on the wider programme.

Whilst there was strong support for the proposal of government fully funding the first £3 million of all schemes, some consultees raised concerns. For example, some thought that the proposal was too simplistic and rigid and may discourage additional partnership contributions.

There was also a common concern that it could lead to fewer schemes being funded overall, or that there could be less funding available for larger, more complex projects.  

There were different views as to the £3 million level of the contribution free allowance. Some consultees thought it was too generous and would prevent beneficiaries from contributing.

Others pointed out that it was likely insufficient for many coastal schemes. Several consultees thought the contribution free allowance should be adjusted in line with inflation. A number of consultees thought that funding contributions should continue to be sought.  

Some consultees also mentioned that the proposal would help to speed up project delivery. It would do this by reducing financial barriers which can cause delays and by simplifying the funding application through the removal of the partnership funding calculator.  

Question 12: To what extent do you agree that Principle 2 is an appropriate way to fund FCERM projects?
  

Principle 2 is a single basic rate of Defra funding to be ‘notionally’ applied to all new FCERM project costs above the £3 million Contribution Free Allowance, regardless of their outcomes. 

We received 287 responses, 30 via email, 1 via post and 256 via the online form. 

Most consultees (57%) agreed or strongly agreed with the proposal that Defra funds 90% of eligible project costs above the £3 million contribution free allowance, with the remaining 10% to be funded from partnership funding contributions. 

In response to the question: 

• 28 (10%) strongly agreed 

• 135 (47%) agreed 

• 77 (27%) were neutral 

• 29 (10%) disagreed 

• 9 (3%) strongly disagreed 

• 9 (3%) didn’t know

Table 3 shows a breakdown of responses to question 12 for RMA and non-RMA: 

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Strongly agree	7	6%	20	13%
Agree	60	51%	70	44%
Neutral	42	36%	34	22%
Disagree	5	4%	20	13%
Strongly disagree	2	2%	6	4%
Don’t know	1	1%	8	5%
Total	117	100%	158	101%

Question 13: Please explain your answer to Question 12.

We received 254 responses, 30 via email, 1 via post and 223 via the online form. 

Many consultees mentioned that the proposed approach would simplify funding processes. Consultees welcomed that it would reduce the complexity of the current funding calculations and create predictability.

Comments made included that this would help RMAs to focus on delivering the right schemes in their areas rather than ones that fit a rigid funding calculator. 

However, there were also concerns that a flat rate – whilst less complex to administer –  

• would not distinguish enough between higher and lower benefit schemes 

• would not incentivise schemes to deliver wider social or environmental benefits 

• would discourage seeking additional partnership funding contributions and collaborative working 

There were also many comments raising concerns that the requirement to secure 10% funding contributions would be challenging for some communities or delivery organisations.

Consultees thought this could disproportionately disadvantage communities without access to private sector investment or substantial local authority funding. For example, this could disadvantage rural, coastal or deprived communities.  

For that reason, many consultees thought that the rate should be flexible. Suggestions included applying a lower rate where schemes are able to bring in more funding contributions, and to fully fund schemes where this is impossible.  

Question 14: To what extent do you agree that Principle 3 is an appropriate way to fund FCERM projects?
 

Principle 3 is all FCERM refurbishment projects are fully funded (refurbishment projects are those that restore existing assets that have fallen below designed levels of operation or are at the end of their design life). 

We received 294 responses, 33 via email, 1 via email and 260 via the online form. 

The majority of consultees (76%) agreed or strongly agreed with the proposal for flood and coastal erosion refurbishment projects to be fully funded by Defra.  

In response to this question: 

• 99 (34%) strongly agreed 

• 124 (42%) agreed 

• 37 (13%) were neutral 

• 20 (7%) disagreed 

• 6 (2%) strongly disagreed 

• 8 (3%) didn’t know 

Question 15: Please explain your answer to Question 14.
 

We received 270 responses, 33 via email, 1 via post and 236 via the online form. 

Many responses included questions and comments about the definition and scope of ‘refurbishment’ as a fully funded category.

Consultees raised concerns about the lack of clarity provided on what ‘refurbishment’ covers.

This included the need for more clarity on whether this would include refurbishment of nature-based solutions like natural flood management, sustainable drainage systems or property flood resilience assets.  

A common thread across responses was the need to apply a broad definition of refurbishment that covers improvements or changes to assets, including green or low carbon solutions, rather than just a ‘like for like’ replacement.

RMAs wanted clarity on whether fully funding refurbishment applied only to Environment Agency assets or to the assets of all RMAs, like those of local authorities, internal drainage boards or water companies. 

Whilst consultees overall agreed with the proposal to fully fund refurbishment of assets, many responses highlighted that it could lead to unintended consequences and create perverse incentives.

Consultees, for example, thought it could lead to less routine maintenance being carried out and assets being left to deteriorate. This is because the funding rules would make it easier to refurbish an asset than to regularly maintain it. 

Others flagged that the rules could lead to assets being refurbished when the better solution would be to build new or different assets.

There were therefore recurring calls for refurbishment only to be funded if it was the most appropriate solution, delivered value for money and aligned with strategies such as shoreline management plans. 

Many consultees raised concerns that refurbishment projects could take up a large portion of government funding, consequently leaving less for new defence schemes to be delivered.

Comments included suggestions for upper limits to government funding for refurbishment, or for Principles 1 and 2 to also apply to refurbishment projects. 

Question 16: Do you agree property flood resilience (PFR) (resistance measures) is an appropriate option to include in government funded flood risk mitigation?

  We received 290 responses, 30 via email, 1 via post and 259 via the online form.  

The majority of consultees (79%) either agreed or strongly agreed with the question.  

 In response to this question: 

• 72 (25%) strongly agreed 

• 156 (54%) agreed 

• 27 (9%) were neutral 

• 18 (6%) disagreed 

• 7 (2%) strongly disagreed 

• 10 (3%) didn’t know

Table 4 shows a breakdown of responses to question 16 for RMA and non-RMA:

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Strongly agree	28	24%	43	27%
Agree	70	59%	77	48%
Neutral	11	9%	16	10%
Disagree	7	6%	10	6%
Strongly disagree	1	1%	6	4%
Don’t know	1	1%	8	5%
Total	118	100%	160	100%

Question 17: Please explain your answer to Question 16.

We received 264 responses, 30 via email, 1 via post and 233 via the online form. 

Most consultees mentioned that property flood resilience (PFR) measures can be an appropriate – or even the only viable – solution to addressing flood risk, and that it therefore forms an important element of the FCERM toolkit. However, consultees also highlighted the limitations of PFR if deployed as a standalone solution, and the need to install it alongside other measures. Consultees overall welcomed that the proposed reforms would provide an easier route to funding for PFR measure. However, there was also broad agreement that it should be funded only where it is the best solution and not to become the default solution because it’s the cheapest.  

Several consultees raised the issue of maintenance being required for PFR to remain effective, and the challenge of ensuring property owners carry out regular inspections and repairs.  

Comments included calls for post-installation support, as well as funding, to be made available for PFR maintenance, including for replacement and post-flood inspections.

Some comments also voiced support for the rollout of food performance certificates to track the effectiveness of PFR risk reductions, which would boost private interest in its maintenance. 

Another common theme across responses was the lack of market capacity and skills to support a more widespread rollout of PFR. Comments made included concerns about a lack of accredited surveyors and qualified contractors.  

Consultees stressed the need to support the growth for the market and, for example, called on the government to invest more in training and workforce development. 

Some consultees also mentioned that the proposed reform should go hand in hand with development of the Environment Agency’s PFR delivery framework to increase capacity. This included a suggestion to provide funding only to PFR delivered by partners on the framework.  

Question 18: Do you think that the overall proposals for funding flood and coastal erosion projects will support the right amount of natural flood management? Are there other proposals you think we should consider?

We received 293 responses, 31 via email, 1 via post and 261 via the online form. 

The most common response was “Don’t know”. Many (39%) of consultees agreed that the proposals would support the right amount of natural flood management, and 21% disagreed.  

 In response to this question: 

• 113 (39%) agreed 

• 62 (21%) disagreed 

• 1 (0%) was neutral 

• 117 (40%) didn’t know

Table 5 shows a breakdown of responses to question 18 for RMA and non-RMA:

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Agree	52	44%	59	36%
Disagree	15	13%	43	26%
Neutral	0	0%	0	0%
Don’t know	52	44%	61	37%
Total	119	101%	163	99%

Question 19: Please explain your answer to Question 18.

We received 275 responses, 34 via email, 1 via post and 240 via the online form. 

There were mixed views on the proposal to expand the delivery of natural flood management schemes to organisations that are not RMAs.  

Some consultees welcomed this proposal, highlighting that non-RMAs have the capabilities to deliver high-quality schemes, and that it would help to deliver more natural flood management.  

Others opposed the proposal on the grounds that it would increase the competition for limited government funding and may direct focus unduly away from FCERM and towards other benefits.

Consultees raised the risk that schemes promoted by non-RMAs may not align with local FCERM strategies, or even conflict with other FCERM activities in the area. There were suggestions for RMAs and RFCCs to be given a sponsoring role over projects led by non-RMAs.  

There were some concerns about the proposal to use the Environment Agency’s grant making powers under section 16 of the Flood and Water Management Act 2010 to give government funding to non-RMAs.

Consultees mentioned that Environment Agency teams would not be involved in the projects led by non-RMAs, and that this could increase the burden placed on lead local flood authorities and inhibit partnership working.

There were calls for funding for non-RMAs to flow through the Environment Agency or other RMAs and to change the grant memorandum to enable this.  

A common theme across responses was also the integration of natural flood management as part of a wider scheme. Several consultees mentioned that natural flood management should not (only) be considered as a stand-alone intervention, but as part of wider ‘hybrid’ schemes.  

Some consultees also highlighted that funding for natural flood management should be guided by a holistic catchment-scale strategy. It should encompass not only flood risk reduction but other benefits that natural flood management delivers (for example habitat restoration).  

Question 20: Do you believe there are any benefits and/or challenges of the current 2012 rule that have not been identified in part 3?

We received 227 responses, 26 via email, 1 via post and 200 via the online form. 

There were mixed views about the benefits of the 2012 rule. It was mentioned repeatedly that the 2012 rule had been unsuccessful in discouraging inappropriate development in flood risk areas.

Some consultees thought that the rule was being undermined by planning pressures and the need to make compromises over competing needs and demands.

Comments included calls to strengthen planning policy, the statutory powers of lead local flood authorities and the enforcement powers of local authorities.

It was pointed out that planning policy allows development in flood risk areas to go ahead as long as sequential and exception tests are met, and that it therefore seems unfair to exclude these properties from benefit calculations.  

Others thought a provision like the 2012 rule was needed to ensure public funding for FCERM would not subsidise development in unsuitable locations. 

There were also frequent mentions of the challenges and limitations of flood risk modelling. Consultees pointed out that some risks, such as groundwater and surface water flooding, were particularly difficult to model, and that risks were increasing due to climate change.

As a result, some properties that were considered to be low risk at the time of the planning decision may now be at high risk, and that it seemed unfair to exclude them. 

Consultees also raised concerns that excluding properties built after 2012 from benefits calculations undervalued the benefits of FCERM schemes. It could lead to entire communities or areas being left unprotected only because some properties were built after a certain date.

This could complicate the delivery of FCERM schemes in areas with mixed-housing stock. It was also mentioned that the rule was acting as a blocker to private sector investment, as it meant that future developments could not be considered in scheme benefits.  

Question 21: Do you think a similar provision to the ‘2012 rule’ remains necessary under the new approach?

We received 240 responses, 26 via email, 1 via post and 213 via the online form.    

• 42% consultees were against retaining the 2012 rule or a similar provision. 

• 36% consultees were in favour of retaining the 2012 rule or a similar provision. 

• 22% consultees did not specify or could not be assigned to either category 

Of those that were in favour of retaining the 2012 rule or a similar provision, there was broad agreement that the rule should be updated and exemptions applied.  

In line with the responses to question 20, consultees frequently mentioned the failure of the current 2012 rule in discouraging development in flood zones, and the need to strengthen planning policy and powers by local authorities to enforce it.

Consultees urged for new homes to be flood resilient, for example by promoting flood resilience measures such as property flood resilience and sustainable drainage systems.

Several consultees wanted government to enact Schedule 3 of the Flood and Water Management Act. There were also calls to strengthen local authorities’ powers to enforce maintenance of sustainable drainage systems.  

Whilst some called for the 2012 rule or a similar provision to be scrapped altogether, others thought a rule of this kind should be included in the new funding framework.  

The challenges and limitations of flood risk modelling and mapping were also mentioned frequently in response to this question.

Consultees highlighted the need to consider the latest risk assessments in funding decisions. Several consultees proposed a more flexible, risk-based approach, advocating for properties built after 2012 to be eligible for funding if their risk has changed.  

There were various proposals for a more flexible approach to funding, as well as ways to secure contributions from developers.

Consultees, for example, suggested that property eligibility could be based on a rolling instead of a fixed date. This would mean that properties would only be excluded from benefits calculations for a certain number of years after they’ve been built (for example 5 or 10 years).

Others thought that there should be a mechanism for developments to contribute to FCERM projects that benefit it, for example, through dedicated levies or ringfenced funding raised through section 106 agreements. 

Question 22: Please outline any potential effects of the proposals outlined in part 3 on groups with a protected characteristic.

We received 160 responses, 21 via email, 1 via post and 138 via the online form. 

Many consultees (33%) considered there to be no significant risk of the proposals affecting groups with a protected characteristic. 

Of those that did identify potential effects, 28% highlighted the impacts on deprived or less affluent areas which may have a higher proportion of people with protected characteristics.

Potential effects were both positive (for example the £3 million contribution free allowance enabling more schemes in smaller or disadvantaged communities) and negative (for example fully funding refurbishment may disproportionally benefit more affluent communities that have already benefitted from flood protection).  

27% of consultees mentioned potential effects in relation to age and vulnerability, highlighting that these groups are disproportionally affected by flooding (for example, by not being able to evacuate).

Consultees mentioned both positive effects (for example, more funding for rural communities) and negative effects (for example, physical barriers to deploying property flood resilience measures). 

Changing our approach to prioritising the delivery of flood and coastal erosion projects  

Part 4 (questions 23 to 28) of the consultation considered how FCERM investment projects should be prioritised within the new investment framework.  

Question 23: Which of these options do you think that FCERM projects should be prioritised for delivery?

We received 294 responses, 29 via email. 1 via post and 264 via the online form. 

Approach 2 (bolstering projects that achieve priority outcomes) was the most popular option, with 48% of consultees selecting it as their preferred option. This was followed by Approach 1 (prioritisation based on value for money and flood risk), which received 26% of the votes. 

 In response to the question: 

• 75 (26%) selected approach 1 (overall FCERM project value for money and flood risk) 

• 141 (48%) selected approach 2 (bolstering projects that achieve priority outcomes) 

• 21 (7%) selected approach 3 (incentives to secure additional partnership funding contributions) 

• 8 (3%) selected none of the above 

• 49 (17%) selected other 

Question 24: Please explain your answer to Question 23.
 

We received 282 responses, 32 via email, 1 via post and 249 via the online form.  

Many consultees advocated for the inclusion of strategic outcomes in the prioritisation criteria.

Consultees thought that this would support a more inclusive and outcome-focused approach that would help to tackle existing inequalities in funding. Consultees also suggested additional priority outcomes, such as local strategic objectives, protection of former coastal landfill, coastal transition and adaptation.  

Many consultees commented on the approach to appraising the value for money of FCERM projects.

Concerns were raised about the reliance on benefit-cost-ratios to determine value for money, which consultees thought were too narrow and undervalued significant benefits. Consultees requested a clearer framework for value for money calculations.  

There were also several consultees who supported prioritisation purely based on value for money and flood risk as the simplest, fairest and most cost-effective approach.

Concerns were raised that a more complex approach could create analytical burden and decrease transparency. However, consultees also highlighted their concerns with the Environment Agency’s national flood risk assessment (NAFRA), a key tool for driving investment.

Consultees raised that NAFRA does not contain all assets that reduce flood risk, and so NAFRA does not accurately reflect the real-world flood risk in all locations.

Consultees also highlighted that NAFRA did not yet work in some flat, low-lying areas of the country such as The Fens. They also flagged concerns with NAFRA accuracy in complex areas with multiple sources of flooding, or in pumped catchments. 

It is worth noting that some consultees stated that they would prefer a hybrid approach that combines elements of the suggested approaches.  

We also noted a request for a separate consultation on the matter of the prioritisation criteria alone.  

Question 25: Please rank in order of preference the 5 potential outcomes that could be prioritised through prioritisation approach 2 (with 1 being the highest preference and 5 being the lowest preference)
 

275 consultees at least partly answered this question, 23 via email, 1 via post and 251 via the online form.  

The following table and graph show the average ranking of each of the 5 potential outcomes: 

• local choice 

• specific types of communities, for example rural or coastal communities 

• specific types of flood resilience intervention, such as natural flood management 

• deprived areas 

• supporting economic growth and the wider economy 

The scale in the following table 6 and graph is different from the ranking given by consultees. Consultees gave 1 to the option with the highest preference and 5 to the one with the lowest. In the following table and graph, the ranking has been reversed and a higher average ranking indicates that more people preferred that option.

Table 6:

Priority outcome	Average ranking
Local choice	2.84
Specific types of communities, for example rural or coastal communities	2.80
Specific types of flood resilience intervention, such as natural flood management	2.62
Deprived areas	2.59

Not all consultees ranked each priority outcome – for example, some only selected their top two.  

The ranking of the five proposed priority outcomes is closely matched, with the prioritisation of ‘local choice’ being the most preferred option, closely followed by prioritising by specific types of communities, for example rural or coastal communities. 

Question 26: Please explain your rankings in Question 25.
 

We received 262 responses, 30 via email, 1 via post and 231 via the online form. 

Consultees frequently mentioned that they found it difficult to rank the priorities. Consequently, a wide range of views was given with regards to all 5 suggested priorities.  

Half of all responses included comments about the proposal to strengthen local choice in the future investment framework.

There was broad support for this proposal, with consultees saying that local bodies were best placed to make decisions with regards to schemes in their areas, and that this could help to win broad support at a local level for schemes.

Consultees mentioned weight should be given to meeting strategic place-based objectives. However, there were also concerns about current regional flood and coastal committee processes not being transparent enough or insufficiently integrated with catchment partnerships.  

There were also suggestions for local choice decisions being given to a different body, for example local authorities. Whilst some consultees advocated for full local choice over schemes, others mentioned that a national framework or strategy would be needed to guide local decision-making and achieve the right outcomes. 

The second most frequently mentioned theme concerned the challenges faced by rural and coastal communities when it comes to securing FCERM funding.

Across consultees, there was broad support for prioritising schemes for those types of communities. However, consultees differed in their views whether this should be a priority at national level, or if it would automatically be achieved by giving local areas greater choice. There were also concerns that prioritising by types of communities could be arbitrary.  

The particular challenges faced by deprived areas were also mentioned frequently. There was broad agreement amongst consultees that they require more targeted funding.  

Several consultees pointed out that there was an overlap between the different priority outcomes – for example that economic growth could be achieved by directing funding to deprived areas; or that rural and coastal communities also had higher rates of deprivation.  

Question 27: Are there any other outcomes we should consider prioritising through prioritisation approach 2?

We received 221 responses, 27 via email, 1 via post and 193 via the online form. 

We identified a common ‘people/community-focused’ theme across responses. It focused on the need to strengthen community resilience and to target funding at the most vulnerable communities or those that have been historically underrepresented.

Consultees called for greater consideration of risk to life, frequency of flooding or mental health impacts.  

Consultees supported prioritising projects where risk is greatest, driving investment to surface water (the highest risk), frequently flooded communities and those in rural areas which are less densely populated.

Many consultees also called for a more holistic way of considering risk. Consultees called for co-benefits to be automatically weighted in prioritisation decisions.

Consultees also thought that schemes that address multiple sources of flood risk should have an easier route to funding. There were also frequent calls for a greater focus on catchment-based and landscape-sized approaches.  

There was also a common ‘climate-focused’ theme that featured in many responses. There was a common sentiment among consultees that adaptation was missing from the new funding framework. For example, consultees highlighted that funding for the delivery of shoreline management plans was not mentioned. Some consultees also thought that carbon reduction or sequestration should be considered as a priority outcome. 

Many responses included thoughts on how to better finance flood resilience.

Several consultees recognised the need to use government funding to attract co-funding and thought government had a greater role to play in enabling this. For example, consultees thought that greater consideration should be given on aligning FCERM with strategic planning and sourcing developer contributions.

Other comments included calls for better alignment with other investment plans and funding cycles, such as the 10-year infrastructure strategy or water company’s asset management plans.

Comments under this theme also included calls and suggestions for enabling economic growth, for example by better protecting businesses.  

Question 28: Please outline any potential effects of the proposals outlined in part 4 on groups with a protected characteristic.

We received 154 responses, 23 via email, 1 via post and 130 via the online form. 

Many consultees (42%) either did not identify any potential impact or thought there was insufficient information to come to a conclusion.  

23% of consultees highlighted that flooding has a disproportionate impact on groups with a protected characteristic. 21% of consultees mentioned that flood disproportionately impacts communities in deprived areas, which have a higher proportion of older or disabled residents.

The prioritisation approach therefore has the potential to have an effect on those groups. But whether the effect will be positive or negative depends on the approach that is chosen, for example whether it results in more funding being directed at deprived areas. 

Transition arrangements  

Part 5 (questions 29 to 31) of the consultation focused on the transition from the current to the new funding rules from 1 April 2026.  

Question 29 asked: How confident are you that the transition arrangements described are sufficient to ensure continued delivery of projects nearing construction and/or projects already under construction? 

Defra received 273 responses, 23 via email, 1 via post and 249 via the online form. 

The most common response was ‘neutral’ (32%). 27% of consultees felt ‘confident’ or ‘very confident’, whereas 26% felt ‘not confident’ or ‘not confident at all’. Confidence was lower among RMAs.  

 A full breakdown of consultees’ answers is as follows: 

• 7 (3%) very confident 

• 66 (24%) confident 

• 86 (32%) neutral 

• 53 (19%) not confident 

• 19 (7%) not confident at all 

• 42 (15%) don’t know

Table 7 shows a breakdown of responses to question 29 for RMA and non-RMA: 

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Very confident	1	1%	6	4%
Confident	23	20%	42	29%
Neutral	45	38%	39	27%
Not confident	31	26%	21	14%
Not confident at all	5	4%	10	7%
Don’t know	12	10%	29	20%
Total	117	99%	147	101%

Question 30: Please explain your answer to Question 29.

We received 228 responses, 25 via email, 1 via post and 202 via the online form.  

The most common recurring theme concerned the approach to schemes at different stages of delivery or development.

Consultees were concerned that schemes in development could be adversely affected. For example, schemes at outline business case stage where significant amounts of time and money have already been spent.

Comments included requests for a more phased approach rather than a strict cut-off date as proposed. There were also request for more flexibility for projects at outline business case stage or a longer transition period for larger schemes. 

Many consultees stressed the need for updated guidance and support to be made available in a timely manner. Consultees flagged that if guidance was released too late, it would not give RMAs enough time to get schemes ready to be submitted in the new programme.

It was also highlighted that too many changes to guidance and policies could overwhelm delivery organisations and assurance services without appropriate levels of support.   

Many consultees also expressed concerns that the transition arrangements could cause delays and put delivery at risk.

Consultees thought that uncertainty as to the new approach and the absence of clear guidance meant that project teams were not progressing projects for the moment. Some projects may be held back to take advantage of the new funding approach from April 2026.

Consultees highlighted that this could create bottlenecks and lead to delays once the new funding framework comes into effect.  

Question 31: Please outline any potential effects of the proposals outlined in part 5 on groups with a protected characteristic.
 

We received 111 responses, 17 via email, 1 via post and 93 via the online form.  

The majority of consultees (53%) did not think that the transition arrangements were likely to have any potential effects on groups with a protected characteristic.  

The most commonly identified potential effect (mentioned by 13% of consultees) was the risk of delays and disruptions that the transition arrangements could cause, and how this could delay protection for at-risk groups.  

Other email responses 

This is a summary of the 66 responses that did not use the consultation template and whose views could not be clearly assigned to the questions we asked.

Notably, 6 of the responses did not provide views on the content of the consultation. 

Proposed reforms to funding framework (part 3 of the consultation): 

• 65% of consultees (43) largely or fully supported the proposals 

• 6% of consultees (4) largely or fully opposed the proposals 

• 29% (19) could not be assigned to either category or did not specify a response. 

Proposed approaches to prioritisation (part 4 of the consultation): 

• 3% of consultees (2) agreed with prioritisation approach 1 

• 14% of consultees (9) agreed with prioritisation approach 2 

• None of the consultees agreed with prioritisation approach 3 or disagreed with all 3 approaches.  

• 83% (55) could not be assigned to any category or did not specify a response. 

Transition arrangements (part 5 of the consultation): 

• 5% (3) stated that they felt confident about the transition arrangements 

• 8% (5) stated that they were not confident about the transition arrangements 

• 88% (58) could not be assigned to either category or did not specify a response. 

A response was judged to be largely supportive if the respondent expressed support for at least 2 out of 3 key reforms, or stated that they agreed in principle but with some conditions. Correspondingly, a response was judged to be largely opposed to the reforms if they disagreed with at least 2 out of 3 the key reforms.  

A common concern raised by several consultees was the lack of RMA resources to carry out routine maintenance of existing assets, deliver the capital programme or their duties as lead local flood authorities.

Routine maintenance funding was not in scope of the consultation. There was specific mention of the maintenance need of natural flood management schemes, which can be significant.

Other consultees mentioned that local authorities are currently under-resourced and lack the skills and capacity to deal with, for example, repair grants and section 19 investigations.

Calls for evidence

Alternative sources of funding for flood risk management

For this call for evidence, we invited views on the proposed principles underpinning our work to identify alternative sources of funding for FCERM activities, as well as the 5 areas we’re proposing to explore in detail.

The analysis of the responses is ongoing, with some initial findings presented below.  

Question 32: To what extent do you agree with the four proposed principles guiding our work on alternative sources of funding (outlined in part 6) – viability, fairness, sustainability and efficiency?

We received 279 responses, 28 via email, 1 via post and 250 via the online form.  

The majority of consultees (82%) either strongly or somewhat agreed with the proposed principles.  

In response to the question: 

• 72 (26%) strongly agreed 

• 157 (56%) agreed 

• 32 (11%) were neutral 

• 6 (2%) somewhat disagreed

• 5 (2%) strongly disagreed 

• 7 (3%) didn’t know

Table 8 shows a breakdown of responses to question 32 for RMA and non-RMA: 

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Strongly agree	24	21%	46	30%
Somewhat agree	67	58%	82	54%
Neutral	16	14%	16	10%
Somewhat disagree	1	1%	4	3%
Strongly disagree	3	3%	2	1%
Don’t know	4	3%	3	2%
Total	115	100%	153	100%

Question 34: To what extent do you agree with the five areas we are planning to explore to identify alternative sources of funding (outlined in part 6) – insurance sector, water and sewerage companies, land and property value uplift, local funding and building on the existing system?
 

We received 277 responses, 27 via email, 1 via post and 249 via the online form.   

The majority of consultees (74%) either strongly or somewhat agreed with the five areas. 

 In response to this question: 

• 65 (23%) strongly agreed 

• 141 (51%) somewhat agreed 

• 26 (9%)were neutral 

• 34 (12%) somewhat disagreed 

• 2 (1%) strongly disagreed 

• 9 (3%) didn’t know

Table 9 shows a breakdown of responses to question 34 for RMA and non-RMA:

Response options	No. of RMA	RMA %	No. of Non-RMA	Non-RMA %
Strongly agree	24	21%	40	26%
Somewhat agree	56	49%	76	50%
Neutral	11	10%	15	10%
Somewhat disagree	19	17%	15	10%
Strongly disagree	1	1%	1	1%
Don’t know	3	3%	6	4%
Total	114	101 %	153	101%

Analysis of responses is ongoing. The summary below presents initial findings only.   

There was agreement that the current funding system alone is insufficient to tackle increasing risks, and that a more collaborative approach is needed.  

There was support for a blended finance model where government funding unlocks additional funding.

Consultees recommended investing in projects that deliver multiple benefits such as nature-based solutions. There were also calls to deliver catchment-based solutions, and for government to explore innovative finance mechanisms.  

There was broad support for the four proposed principles underpinning this work. However, some consultees mentioned that the principles of ‘viability’ and ‘fairness’ should consider that some RMAs may have limited capacity to secure private contributions.

Several consultees remarked that the proposed principle of ‘sustainability’ was too narrowly defined and should also include ‘environmental sustainability’. There was also a suggestion to include ‘Innovation’ as a fifth principle.  

Consultees generally supported the five proposed areas, with caveats. There were concerns that exploring alternative sources of funding opportunities with the insurance sector and water companies could lead to costs ultimately falling back onto customers.

While some consultees pointed out that RMAs had already attempted to secure funding contributions in these areas without success, others thought it was overdue for them to be explored more thoroughly.  

The government will continue to explore and develop alternative sources of funding for flood and coastal erosion risk management.

Local choice, English devolution and opportunities for flood risk management

The call for evidence invited views on the opportunities to enhance local choice and better align FCERM with local growth priorities to deliver wider benefits for communities.  

Analysis of responses is ongoing. The summary below presents initial findings only.  

The call for evidence identified three areas to explore:  

• partnerships 

• planning 

• funding 

In relation to partnership and planning, the call for evidence explored how mayors and strategic authorities could strengthen local resilience, align with growth priorities, and support flood and coastal erosion risk management across England.   

Consultees highlighted that strategic authorities have the potential to improve flood risk planning across England.  

 Key opportunities identified included: 

• enhanced mayoral oversight of delivery 

• integrated collaboration with partners across catchments 

• stronger connections between FCERM and other priorities such as housing, economic growth, infrastructure, and nature recovery - enabling wider co-benefits

Consultees also noted that mayors could play a valuable role in improving data sharing across authorities, supporting more informed and collaborative planning.   

Conversely, other consultees expressed concern that introducing an additional layer of governance could lead to inefficiencies. Their concerns suggested inefficiencies would be driven by increased approval requirements and potentially conflicting mayoral priorities. 

Responses also noted risk regarding politicisation of FCERM. There were concerns that disadvantaged areas, particularly coastal and rural communities, could be marginalised in favour of more vocal and affluent localities.

To mitigate these risks, some consultees recommended the development of robust guidance and, where appropriate, supporting legislation.  

In relation to funding, consultees noted that mayors have the potential to unlock a broader range of funding mechanisms, such as precepts and business rate supplements. This additional funding could help strengthen local authority skills and capacity, thereby enhancing regional FCERM capabilities.   

Consultees also highlighted key benefits of devolved funding, particularly improved coordination between funding mechanisms and greater scope for local decision-making and expertise in spending. However, concerns were raised that, without effective ringfencing, the additional layer of bureaucracy could lead to funds being diverted to other priorities.  

The government has no plans to make changes in April 2026 at the start of the new funding and programme approach. The evidence received will inform long term policy decisions.