Consultation on the Draft Scottish Climate Change Adaption Programme: Analysis of Responses

6 Climate Ready Buildings and Infrastructure Networks

6.1 This chapter presents an analysis of respondents' views on the objectives, policies and proposals set out under the heading of Climate Ready Buildings and Infrastructure Networks (the B theme). The B theme included the following three objectives:

• B1 - Understand the effects of climate change and their impacts on buildings and infrastructure networks
• B2 - Provide the knowledge, skills and tools to manage climate change impacts on buildings and infrastructure
• B3 - Increase the resilience of buildings and infrastructure networks to sustain and enhance the benefits and services provided

6.2 The consultation asked five questions in relation to this theme:

Question 3a: Do objectives B1, B2 and B3 collectively set an appropriate long term direction to ensure that Scotland's buildings and infrastructure networks are able to adapt to our changing climate?

Question 3b: To what extent will the policies and proposals listed under objective B1 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 3c: To what extent will the policies and proposals listed under objective B2 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 3d: To what extent will the policies and proposals listed under objective B3 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Question 3e: Taken together, do the policies and proposals listed under objectives B1, B2 and B3 address the current and predicted impacts to Scotland's buildings and infrastructure networks identified in the UK Climate Change Risk Assessment?

6.3 This chapter includes three sub-sections: the first will discuss respondents' comments on Question 3a; the second will present views about the policies and proposals under each objective (Questions 3b-3d); and the third will consider the responses to Question 3e.

Do the objectives set an appropriate long term direction? (Q3a)

6.4 Forty-three (43) respondents answered Question 3a. Of these 33 (77%) thought the objectives either "fully" or "mostly" set an appropriate long term direction for adaptation of Scotland's buildings and infrastructure networks, while 10 (24%) thought they only "partially" or "poorly" did so. (See Table 6.1.) The latter group included most of the non-governmental organisations (NGOs), two out of three education / research bodies, and four out of 19 local authority respondents.

6.5 Forty-one (41) respondents provided further comment in relation to Question 3a. This represents 61% of the total 67 respondents.

Table 6.1: Question 3a - Do objectives B1, B2 and B3 collectively set an appropriate long term direction to ensure that Scotland's buildings and infrastructure networks are able to adapt to our changing climate?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	1	1	3
Local authority & CPPs	4	11	3	1	19
NGOs		1	3		4
NHS or health-related		4			4
Private sector	2	2			4
Transport	3				3
Other public bodies		4			4
Individual respondents		1			1
Total	9	24	8	2	43
Total percentages	21%	56%	19%	5%	100%

* Percentages do not total 100% due to rounding.

General comments

6.6 Respondents who ticked "fully" or "mostly" in response to Question 3a described the objectives as "comprehensive" and "appropriate". This group considered the B theme to be "the most coherent of the three themes", providing "a strong foundation" for improving the resilience of Scotland's infrastructure, and reflecting "the considerable experience developed nationally of severe weather events". This group also noted that a successful adaptation programme would make Scotland more attractive for investment.

6.7 Those who were less satisfied with the objectives (i.e. those who ticked "partially" or "poorly" in response to Question 4a) described the B objectives as "vague" and "too narrowly defined". This group wanted to see more specific objectives, incorporating a wider range of measures, with both short and long term actions.

6.8 Many of the issues set out in Chapter 3 (Key issues) were raised in respondents' comments on the B theme. In particular, respondents pointed out that significant investment would be needed to bring about the adaptation of buildings and infrastructure in Scotland and there were concerns that the Programme was too short term to make this happen.

Perceived gaps and areas for development

6.9 Respondents identified a number of areas where they felt the B theme needed further development. The main issues raised by a range of respondents at Question 3a, included:

• The key role of planning: Respondents emphasised the importance of planning policy and legislation in delivering well adapted buildings and infrastructure. It was suggested that the Programme should inform the revised Scottish Planning Policy to give both planners and developers a strong policy basis for taking account of adaptation in the future.
• Green infrastructure: Respondents thought that "infrastructure" was too narrowly defined in the Programme. Respondents emphasised the importance of green infrastructure in supporting a wide range of other adaptation measures (e.g. Sustainable Urban Drainage Systems (SUDS); management of surface water run-off; air quality improvements; cooling of buildings and outdoor spaces; providing places for walking and cycling; delivering biodiversity benefits).
• Adaptation of existing buildings: The B objectives should prioritise the retrofitting of existing properties and incorporate policies to address flooding impacts, and algal and fungal growth in existing buildings.
• Avoid unintended consequences: Respondents commented that care should be taken to ensure that actions to address the B objectives do not inadvertently result in increased health risk (e.g. by reducing indoor air quality), or in greater carbon emissions (e.g. by increasing the resilience of the roads infrastructure in preference to rail or public transport networks).

6.10 Respondents perceived a lack of attention in the B theme to:

• Information and communications technology infrastructure
• Energy infrastructure
• Coastal and inland water infrastructure (including ports, harbours, canals)
• Water supplies (including both private water supplies and water supplies for key Scottish industries)

Appropriateness of policies and proposals under each objective (Qs 3b-3d)

6.11 Questions 3b, 3c and 3d asked for respondents' views on the policies and proposals set out under objectives B1, B2 and B3 respectively. Tables 6.2, 6.3 and 6.4 on the following page show that just over three-fifths of the 67 respondents answered each of these three questions:

• Of the 41 respondents who answered Question 3b, 29 (71%) thought that the policies and proposals under objective B1 either "fully" or "mostly" provided an appropriate lifetime focus for the Programme, while 12 (29%) thought they only "partially" or "poorly" did so.
• Of the 42 respondents who answered Question 3c, 28 (67%) thought that the policies and proposals under objective B2 were "fully" or "mostly" appropriate, while 14 (33%) thought they were less so.
• Of the 41 respondents who answered Question 3d, 28 (69%) thought that the policies and proposals under objective B3 were "fully" or "mostly" appropriate, while 13 (31%) thought they were less so.

6.12 Across all three objectives, those who were less supportive included a majority of the NGO respondents and around a quarter of the local authority respondents.

6.13 The number of respondents who made further comments at Questions 3b, 3c and 3d are shown below:

• 39 respondents (58% of the total 67) commented at Question 3b
• 42 respondents (63% of the total 67) commented at Question 3c
• 41 respondents (61% of the total 67) commented at Question 3d

Table 6.2: Question 3b - To what extent will the policies and proposals listed under objective B1 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	1	1	3
Local authority & CPPs	2	11	5		18
NGOs		1	3		4
NHS or health-related	1	3			4
Private sector	2	2			4
Transport		3			3
Other public bodies		3	1		4
Individual respondents					0
Total	5	24	11	1	41
Total percentages	12%	59%	27%	2%	100%

Table 6.3: Question 3c - To what extent will the policies and proposals listed under objective B2 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	1	1	3
Local authority & CPPs	1	12	5		18
NGOs			4		4
NHS or health-related		2	2		4
Private sector	3	1			4
Transport		3			3
Other public bodies		4			4
Individual respondents		1			1
Total	4	24	13	1	42
Total percentages	10%	57%	31%	2%	100%

Table 6.4: Question 3d - To what extent will the policies and proposals listed under objective B3 provide an appropriate focus for the lifetime of the Programme in order to progress towards the long-term objective?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research	1			1	2
Local authority & CPPs	1	12	6		19
NGOs		1	3		4
NHS or health-related		3	1		4
Private sector	3	1			4
Transport	1	2			3
Other public bodies		3	1		4
Individual respondents					0
Total	6	22	12	1	41
Total percentages	15%	54%	29%	2%	100%

General comments

6.14 Those who supported the policies and proposals described them as "comprehensive", "realistic" and "sound". Respondents particularly welcomed the Scottish Government's approach to "evidence-based decision-making", and the Programme's recognition of the importance of improving knowledge and skills and providing tools to support climate change adaptation.

6.15 Those who were less supportive described the policies as "vague". This group of respondents repeatedly raised many of the issues outlined in Chapter 3 (Key issues). In particular, they asked for clarity about whom the policies and proposals were intended for; how the policies would be co-ordinated and delivered; and what the mechanisms would be for sharing learning with those who most needed it - including local authorities, the transport and energy industries, and the next generation of building trades professionals.

Perceived gaps and areas for development

6.16 Respondents noted a number of perceived gaps, or areas for development in the objectives under the B theme.

6.17 Under objective B1 (understand the effects of climate change and their impacts on buildings and infrastructure networks):

• Transport-related policies: Respondents who commented on the transport-related policies under B1 voiced support for them. However, there were also concerns that the transport policies focussed predominantly on the roads infrastructure. There were repeated calls by respondents to incorporate policies aimed at supporting walking and cycling, and reducing reliance on cars. These could include: Regional and Local Transport Strategies and the Strategic Transport Projects Review (2009) which all promoted walking, cycling and the use of public transport.

There was support for proposal B1-17 (Tomorrow's Railway and Climate Change Adaptation) and respondents wanted to see a greater focus on measures to address the risk of climate change on the rail infrastructure.

Gaps in the transport-related policies were perceived in relation to water transport infrastructure (e.g. harbours, ports, etc.) and airports.

• Built environment: Respondents made two main points in relation to policies B1-1 and B1-2 (research to identify necessary resilience measures for new / existing buildings). First, respondents noted that "existing buildings" appeared to be defined in policy B1-2 as "historic buildings". Respondents wanted assurance that policies to improve the resilience of "existing buildings" would cover the whole range of building types, including housing, workplaces, care homes - as well as historic monuments and archaeological sites.

Second, respondents called for the Programme to clarify the mechanism(s) by which research findings / good practice would be communicated, promoted and enforced in the building sector. Costs of building repairs or upgrades were seen as a barrier to wide-spread adoption of adaptation measures. Therefore, respondents saw the need for stronger, enforceable policies in this area.

• Flood Risk Management Plans (FRMPs) and River Basin Management Plans (RBMPs): In relation to policies B1-12 and B1-13, respondents wanted more detail about how FRMPs and RBMPs would address climate change adaptation. Respondents wanted to see the Programme inform the development of FRMPs and RBMPs from 2014 onwards.

It was suggested that the Programme should include stronger, more specific measures to address the potential impacts of climate change on rivers, lochs and reservoirs - for example, in relation to nutrient loadings, algal blooms, water quality and quantity.

• Energy infrastructure: Respondents supported the proposal to develop an Energy Sector Climate Change Impacts research programme. However, they also wanted to see a wider range of policies and proposals to support a resilient energy sector. It was suggested that the Programme could include reference to:
  • The energy sector's First Round Adaptation Reports (submitted to the UK government in 2011)
  • The summary report produced by the Association of Electricity Producers, "Climate change risks and adaptation responses for UK electricity generation" (Oct 2011).
  • The Energy Sector Action Plan.

6.18 Under objective B2 (provide knowledge, skills and tools to manage climate change impacts), the following issues were raised by a range of respondents:

• Insufficient emphasis on skills and tools: It appeared to respondents that the focus of policies under objective B2 was mainly on providing knowledge, and less on providing skills and tools. It was suggested that the Programme should include a wider range of policies and proposals related to training schemes and tool kits to balance this section. Respondents noted the importance, in particular, of providing training to local authority planners, public sector estate managers, builders and members of the construction industry and developers (including those involved in telecommunications and energy sector developments).
• Sustainable Urban Drainage Systems (SUDS): It was suggested that local authorities needed additional guidance on how to design and manage SUDS and that the Programme could usefully refer to the existing guidance available from RSPB.
• Energy sector: Respondents welcomed the proposal to establish a Scottish Government Energy Sector Flood Risk work stream (proposal B2-24), but wanted the Programme to clarify that this would also include work on hydro, tidal and wind energy. Respondents queried why there was a policy on "liaising with the industry on thermal generation" (B2-7), but no specific policies related to these other forms of energy generation.
• Historic sites and older housing stock: There was a view that any focus on historic properties should emphasise "adaptive management" rather than "protection". Respondents also emphasised that any learning acquired - for example, by Historic Scotland through the management of historic buildings - should be disseminated to local authorities who also have responsibility for maintaining a wide range of older buildings.
• Relevance of certain policies to adaptation: Respondents asked for clarification about how policies B2-8 to B2-10 (on marine strategy and planning) would contribute to the adaptation of coastal infrastructure. It was suggested the Programme might highlight the importance for marine planning authorities to ensure that marine and coastal developments will be resilient to the risks of coastal change and flooding; and will not themselves contribute adversely to coastal change.

6.19 In relation to objective B3 (increase the resilience of buildings and infrastructure networks to sustain and enhance the benefits and services provided), respondents' comments often echoed points they had previously made in relation to objectives B1 and B2. Additional areas for development or perceived gaps identified in the policies / proposals under B3 were in relation to:

• Adaptation of existing buildings: Respondents welcomed policies B3-1 to B3-3 and reiterated the importance of planning policy and building standards guidance in driving forward adaptive practices in the construction industry. However, there was concern that the Programme had not addressed the challenges of developing resilience in older buildings that may be difficult and expensive to improve, or where mixed ownership makes it difficult to undertake repairs and improvements.
• Green infrastructure: Respondents appreciated the mention of green infrastructure under the Scottish Planning Policy (B3-3). However, as noted previously, it was thought that the importance of green infrastructure was not adequately acknowledged in the Programme.
• Flood insurance: Respondents welcomed the inclusion of proposal B3-13 (work with the UK government and insurance industry to ensure the availability of flood insurance) and considered this to be a priority action. Respondents emphasised the importance of this issue not only for domestic properties, but also for businesses - and small businesses in particular, which may not be able to operate if they cannot afford flood insurance.

Extent to which the Programme addresses the impacts identified in the UK CCRA (Q3e)

6.20 Forty-one (41) respondents answered Question 3e. Of these, 29 (71%) thought the policies and proposals listed under the B objectives either "fully" or "mostly" addressed the impacts identified in the UK CCRA, while 12 (29%) thought it only "partially" or "poorly" did so. (Table 6.5.) The latter group included most non-government organisations (NGOs) and education / research organisations and four out of 18 local authority respondents.

Table 6.5: Question 3e - Taken together, do the policies and proposals listed under objectives, B1, B2 and B3 address the current and predicted impacts to Scotland's buildings and infrastructure networks identified in the UK Climate Change Risk Assessment?

Respondent Type	Fully	Mostly	Partially	Poorly	Total
Conservation & planning			1		1
Education & research		1	1	1	3
Local authority & CPPs	2	12	4		18
NGOs		1	4		5
NHS or health-related		3	1		4
Private sector	3	1			4
Transport		2			2
Other public bodies		4			4
Individual respondents					0
Total	5	24	11	1	41
Total percentages	12%	59%	27%	2%	100%

6.21 Thirty-one (31) respondents made comments in relation to Question 3e. This represents 46% of all respondents to the consultation. In general, respondents who commented at Question 3e referred back to, or repeated, comments they had made in response to one or more of Questions 3a-3d. Others identified a range of additional risks which they thought were not addressed in the Programme. These included:

• Risks to the historic environment and cultural heritage from erosion
• Risks to alternative energy generation
• Risks to health from a changing climate, and how these would influence estates strategies in public sector (particularly NHS) organisations.

6.22 In addition, there was a general view that the Programme had comprehensively addressed the risks of flooding on infrastructure and the built environment. However, it was thought that other risks had not been adequately addressed. This include, among others:

• Overheating in buildings
• Higher energy demands for cooling
• Heat damage and disruption to energy infrastructure
• Changes in soil conditions and loss of water holding capacity in soils
• Sea level rise and related risks of tidal and storm surges.