Building standard 3.3 - flooding and groundwater guidance review: research

2. Survey

Introduction

2.1 In parallel with the literature review (section 3), a survey of current practice was issued primarily to local authorities and also to industry representatives. Responses were received from the planning, building standards and flood teams from the following eight local authorities:

• Aberdeenshire Council.
• Angus Council.
• Argyll and Bute Council.
• Clackmannanshire Council.
• City of Edinburgh Council.
• Highland Council.
• Orkney Islands Council.
• Scottish Borders Council.

2.2 Additional responses were also received from flood practitioners from JBA Consulting^[1] and one response from an officer from an unnamed local authority.

2.3 The survey was grouped into four main themes: Planning and Flooding; Checking Compliance; Working Together; and Knowledge and Training.

2.4 Under each category, the survey contained a mixture of scored and free-form questions. The survey's main aims were:

• To obtain details from each building standards department on what their approach to verification of a building warrant application is where flood risk has been identified and PFR is required as a condition of the planning approval.
• To help identify the relationship between Local Authority (LA) services of building standards and planning, and relevant designated flood officer or environment team.
• To help identify frameworks for successfully ‘managing’ the risk assessment and mitigation of flood risk.
• To help establish how building standards are made aware of planning conditions relating to flood risk and PFR.
• To confirm if the LAs carry out inspections of flood mitigation methods.
• To confirm if mechanisms are used by building standards to ensure extensions and conversions etc. are built to the same or higher flood resilience standards as the original dwelling, and how risk is checked.
• To request copies of relevant local LA (particularly Building Standards) guidance on flooding and flood resilience and inspection information.

2.5 A copy of the survey is provided in Appendix A.

Survey results

2.6 The full results of the survey (anonymised) are provided in Appendix B and are summarised in the following sections per category. Forty one responses were obtained.

Flood risk and breakdown of respondents

2.7 In order to provide an additional level of analysis, the eight Local Authorities (LAs) were ranked by flood risk. For the purposes of this ranking, the percentage of residential properties exposed to flooding from a 0.5% Annual Probability (AP, 200 years) plus climate change flood from any source (river, coastal or surface water) as estimated from the information available in the Scottish Government report "Mapping Flood Disadvantage in Scotland 2015: Main Report^[2]". Although this analysis was undertaken in 2015, using the SEPA mapping available at the time, it was judged to be sufficient for providing a simple ranking of the LAs. This is because it provided information on major flood sources in a readily accessible risk percentage format allowing easy comparison between the LA areas. The results are summarised in Table 2-2, with the percentage residential properties at risk ranging from over 8% (for the top ranked LA) to circa 3% (for the lowest ranked LA).

2.8 Table 2-1 also lists the total number of respondents per organisation, together with a breakdown of whether they were building standards officers or others (such as planning or flooding officers). It can be seen that, for the most part, there is a reasonable spread between building standards officers and others. However, LA number seven is an exception as, of the 21 total responses, 20 related to building standards and 1 was from another (flood officer). In addition, the 21 responses from this LA form over half of the total number of responses received (41). In order to minimise the risk of bias, in the following sections, the survey results are discussed both as overall averages (across all of the respondents) and also by LA ranked by flood risk.

Survey: Planning and Flooding

2.9 Table 2-2 summarises the survey responses for the Planning and Flooding category. The table includes the average scores (on a 1 to 5 scale, where for example, 1 represents little awareness of flooding in the planning process and 5 represents high awareness) together with relevant information drawn out from the free form responses. Table 2-3 provides the scores by LA, as ranked by flood risk.

2.10 The average scoring on the first two scored questions (awareness of flood risk and flood risk planning conditions) is perhaps a little biased by the LA seven scores, but the LA seven answer to the third scored question (on flood risk identification at building warrant stage) is consistent with several of the other LAs. The third scored question is also the only question in this group where the top ranked LA on flood risk has a higher score than the others: i.e. in this LA flood risk is identified at building warrant stage more frequently than in the other LA areas.

2.11 Overall, a key finding from this information is that flooding is generally not an issue building standards officers often deal with; but it is addressed at the planning stage by planning and flooding officers. For example, when the roles of those who answered the survey are taken into account, those who have a role as a building standards officer responded that they are almost never made aware of flood risk in the planning stages and similarly are not aware of planning conditions relating to the flood risk. Building standards officers also reported that they are generally not made aware of flood risk issues arising at planning stage. Both planning officers and building standards officers informed that it is unlikely for flooding issues to have not been picked up in the planning stage and for these to only emerge at the warrant stage. This suggests that there is a potential strength in the planning system in addressing flooding issues from the outset, but that there still could be a role for building standards officers in checking mitigation measure compliance.

Survey: Checking Compliance

2.12 Table 2-4 and Figure 2-3 to Figure 2-4 summarise the survey responses for the Checking Compliance category. The key findings were:

• Based on the average score of 2.49, compliance on matters relating to flooding and groundwater are rarely checked for new build. A similar finding was obtained for conversions, extensions and basements.
• For the most part, there was no clear trend in the scored questions relating to ranking by flood risk (Table 2-5) with some of the highest scores (representing checking compliance on flood risk matters) being submitted by LA number six. The exception was on the question on effectiveness of checking compliance, where LA number one scored highest (suggesting checking compliance is effective). LA number seven's scores generally sit within the range of the other LAs, suggesting it has not introduced substantial bias in this category.
• When compliance is checked, the most common matters which are checked are: location, finished floor level and drainage (Figure 2-3).
• With respect to checking compliance for conversions, extensions and basements, there was an almost even split between treating them in the same way or differently to new build. The main reason given for treating them differently was that the conversion, extension or basement was in relation to an existing building.
• The same approach to compliance was generally taken between domestic and non-domestic development. Where a different approach was taken, one reason given was that the non-domestic development could be water compatible.
• PFR is rarely part of an inspection when checking compliance relating to flooding.
• The Building Standards Technical Handbook was identified as the document most commonly used for checking compliance (Figure 2-4). Planning and flooding officers also identified NPF4 and the Local Development Plan as key documents in their roles.
• Only two Local Authorities noted local guidance, and this was publicly available guidance on planning and flooding rather than Building Standards.
• The reported approaches to building warrant verification where flood risk had been identified included: involving the flood officer, viewing SEPA maps, flood risk assessment (note that a flood risk assessment is usually undertaken at the planning stage), site investigation report and involvement of LA structural engineers. However, responses also noted that flooding issues at building warrant stage are identified quite rarely.

2.13 From these findings, it can be concluded that, with some limited exceptions, Building standards officers are generally not involved in checking for compliance on flood risk matters and that there is no standard approach (across the Local Authorities surveyed) taken when they do.

Survey: Working Together

2.14 The purpose of this part of the survey was to identify whether building standards officers commonly work together with colleagues from the planning and flooding teams on checking compliance for flooding matters. The results are summarised in Table 2-6 and the key findings were:

• Building standards officers rarely work together with flood officers.
• Building standards officers work slightly more frequently with planning officers, but still very rarely. When they do work together, matters discussed include planning conditions and dates of commencement/completion.
• Occasionally staff from other organisations such as SEPA and Scottish Water are contacted by building standards officers on flooding matters.
• When ranking by flood risk is considered (Table 2-7), building standards officers work together with flood officers and planning officers a little more frequently in LA one than in the other LAs, but the frequency of collaborative working is still relatively low.

Survey: Knowledge and Training

2.15 The purpose of this section of the survey was to identify the respondents' current knowledge and training with respect to flood risk and highlight possible future needs. The results are summarised in Table 2-8 and Figure 2-5. The key findings were:

• The average scores generally showed a middle ground across the different questions asked. This can be explained by respondents assigning high scores in their specialist area and low scores in areas where there are less familiar (e.g. building standards officers assigned a high score to knowledge of Building Standards Technical Handbook section 3.3. "Flooding and Groundwater", but a lower score to knowledge of Flood Risk Assessment and flood officers assigned the opposite).
• When ranking by flood risk was considered (Table 2-9), there was no clear pattern with LA one scores similar to other scores.
• Notably the lowest scoring category was on knowledge of PFR and familiarity with related guidance ("Living With Flooding: An action plan for delivering property flood resilience in Scotland").
• With respect to improving effectiveness when checking compliance matters relating to flooding, enhanced communication within different parts of the local authority and training on Flood Risk Assessment and PFR were rated highest of the suggested options (Figure 2 5).
• A limited number of respondents had undertaken training on Flood Risk Assessment, and only one on PFR. Training was provided by the following organisations: HR Wallingford, Jacobs, JBA Consulting, SEPA and WTI.
• Commentary on the well defined process for planning and flooding was also provided and a suggestion for identifying gaps across the working together across the different departments (planning, flooding and Building Standards), made.

2.16 From the above information it was concluded that while respondents have some knowledge of flood risk, there is a key gap on PFR and additional information, awareness raising and training on PFR moving forward may be desirable.

Survey: Conclusions

2.17 From the analysis of the survey results, the following key points were identified with respect to flooding and Building Standards:

• Flooding is generally not an issue building standards officers often deal with.
• Building standards officers rarely work together with flood or planning officers. (In the LA ranked for the highest flood risk, it is more common for building standards officers to be aware of flood risk and work with other officers).
• This may be because it is unlikely for flooding issues to have not been picked up in the planning stage and for these to only emerge at the warrant stage.
• This suggests that there is a potential strength in the planning system in addressing flooding issues from the outset, but that there still could be a role for building standards officers in checking mitigation measure compliance.
• Further to this, compliance (e.g. as part of a site inspection) on matters relating to flooding and groundwater do not appear to be checked often rarely for new build, conversions, extensions and basements. This applies to both domestic and non-domestic development (this is based on average scores of 2.49 and 2.40 for new build and conversions, etc, Table 2 4). As noted in the points above, this may be because flooding matters are generally dealt with at the planning stage and it is rare for building standards officers to become involved.
• When compliance is checked, the most common matters which are checked are location, finished floor level and drainage.
• PFR is rarely part of an inspection when checking compliance relating to flooding.
• The Building Standards Technical Handbook was identified as the document most commonly used for checking compliance.
• Where compliance is checked, there was no single approach taken across the Local Authorities surveyed. Approaches included: involving the flood officer, viewing SEPA maps, flood risk assessment (note that a flood risk assessment is usually undertaken at the planning stage), site investigation report and involvement of LA structural engineers.
• A limited number of respondents had undertaken training on Flood Risk Assessment, and only one on PFR.

2.18 The findings support an update to the Building Standards Technical Handbook (e.g. as this was found to be the most common document used for checking compliance) but do highlight that flooding is not an issue commonly dealt with by building standards officers. In particular, the findings suggest a lack of knowledge of PFR. This is perhaps not surprising given the (to date) limited uptake of PFR in Scotland in comparison to more traditional flood avoidance and mitigation measures such as location and finished floor level. However, given BSD's aspirations for PFR (including its referencing in an update to the Technical Handbook, section 1.1), the survey findings highlight a knowledge gap and potential need for training. In addition, across the Local Authorities surveyed, there was no common approach in checking compliance on flood risk matters at the building warrant stage. Again, this is perhaps not surprising given the reported rarity of building standards officers being involved in flood risk matters, with flooding generally being considered at the planning stage. A suggested good practice template for flood risk matters and compliance is provided in the next section.