National Flood Resilience Strategy: consultation analysis

Executive Summary

Background

As part of Scotland’s National Adaptation Plan and wider commitments to a Just Transition, the Scottish Government is developing a Flood Resilience Strategy that will focus on how to make our communities more flood resilient. The Strategy aims to move away from trying to ‘fix flooding problems’ to an approach that focuses on creating flood resilient places.

A consultation on the draft Flood Resilience Strategy ran from May to August 2024, and the consultation document is available on the Scottish Government’s website. It asked 22 questions, seeking views on the key guiding principles and the actions needed to improve flood resilience in Scotland.

A total of 198 responses to the consultation was received, with 87 from groups or organisations and 111 from individual members of the public.

The main report presents a question-by-question analysis of the answers given and comments made. This thematic summary sets out some of the key themes to emerge from across the analysis.

Changing the narrative

There was broad support for the shift in emphasis from ‘fixing flooding problems’ to creating flood resilient places. This was described as a sensible and common-sense way forward, particularly in the light of climate change happening faster than has been predicted. It was suggested that Scotland needs to take more impactful action at significant pace, and that there is a strong and clear case for change.

One of the reasons given for supporting the change to creating flood resilient places was that more traditional, hard engineering solutions on their own are insufficiently effective or flexible. There was also a view that taking a more holistic, catchment-based approach is the most logical way forward, including the use of nature-based solutions that would bring benefits to both people and nature.

Those who did not support the change were most likely to be concerned about a shift away from protecting communities, homes and businesses that are at greatest risk from flooding. There was an anxiety that a change in emphasis or focus could lead to funds being redirected away from pure protection actions, potentially leaving such measures undeliverable.

In relation to helping Scotland to become more flood resilient and adapt to the impacts of climate change, respondents were most likely to see the Scottish Government as having the most important role to play, followed by a range of other public sector organisations (local authorities, SEPA and Scottish Water). Respondents were most likely to consider community groups, homeowners and individual members of the public as having the least important role to play.

Key themes

The draft Strategy has three themes – People, Places and Processes. The main issues raised in relation to each of these three themes are summarised below.

People: Involving people in decisions about improving flood resilience in their places and highlighting the contributions individuals can make to community flood resilience.

Capacity and resources: Community councils and Individuals were amongst those highlighting that local groups and community organisations will require a range of support if they are to become fully engaged in creating flood resilient places. Lack of financial resources was highlighted as a specific barrier to local groups being involved.

Genuine collaboration: There were calls for communities and the relevant authorities to work collaboratively, with communities given equal status and having a real voice in decision-making. Respondents highlighted active engagement, inclusiveness, and genuine dialogue as being important for successful community participation.

There were references to the National Standards for Community Engagement, with the need for engagement to begin early in the process noted. Community-based flood resilience groups (where they exist) were seen as a useful starting place.

However, there was a concern that, while communities should be involved in improving flood resilience, they should not be responsible for creating flood resilient communities. It was noted that some communities simply will not have the capacity to set up a local flood resilience group, and that many volunteers are already overstretched with other community activities.

Information and support: Access to up-to-date and reliable information, and particularly local flood maps, was also seen as important and it was suggested that all data should be publicly available in full, free of charge, and in a range of formats.

Giving communities access to independent expert advice, specialist guidance and support was also seen as key. Examples included help to better understand flood maps or return periods, or providing practical information on up-to-date techniques for mitigating flooding.

Places: What changes we must make to our places to increase flood resilience.

Among general comments was a view that it will be important to take a holistic, or multifaceted approach to flood resilience, which should be designed in at the placemaking stage and accompanied by a robust planning regime that ensures flood risk is considered from the beginning, in terms of both where and how to build.

Avoiding development in flood-prone locations: This was a frequently raised issue across the consultation, with calls for no further building on floodplains or other sites with a high risk of flooding. It was also argued that the risk of flooding in the area around a proposed development should be considered, or that a development should not be permitted if it will increase the risk of flooding in other areas. Requirements for better data, regular updates to flood mapping reflecting the latest science, and improved methodologies to support the decision-making process were all suggested.

Catchment scale approach and natural flood management (NFM) techniques: Managing risk of fluvial flooding at catchment level and deploying NFM techniques were two frequent suggestions for making places more flood resilient. Those advocating a catchment scale approach argued that this should involve reviewing the upstream land management practices of farmers and large landowners and that positive actions could include using NFM techniques to hold water upstream after heavy rainfall and slow run off. It was also suggested that the efficacy of NFM techniques needs to be evaluated.

Designing for flood resilience: It was argued that designing with flood risk in mind should be central to development of housing, commercial areas, transport networks and public spaces. There were calls for the planning system and/or the building regulatory framework to be revised where necessary, for example to prioritise delivery of buildings that are resilient to climate-related risks, including flooding, or to upgrade requirements to reduce flood risk beyond an individual development site. In terms of particular approaches:

• Sustainable drainage systems (SuDS) were seen as important, with suggestions that these should be standard practice in urban planning and should be considered from the initial design stage. More widely it was suggested that local drainage systems must be specified for heavy rainfall and must have adequate capacity for foul and surface water flows before new housing is approved. The importance of routine maintenance of existing drainage systems was also highlighted.
• With respect to individual properties, it was argued that Building Standards should be used to mandate flood resilience measures, and that this approach for new homes would be less costly than retrofitting at a later date.

Capacity and funding: It was suggested that a national program to develop the building skills and the products and processes needed to make property flood resilience measures more accessible and affordable. Training for professionals including architects, civil engineers and planners to move beyond traditional flood management approaches was also proposed.

Respondents also referenced the importance of funding, including grant funding, to stimulate uptake for property measures; support community engagement and capacity building; and for the implementation of NFM solutions and development of blue-green infrastructure.

Moving communities away from areas with the highest exposure: Although a considerable majority of respondents thought that moving communities away from areas with the highest exposure should be considered as an option, a frequently made point was that this should be considered only as a last resort, in extreme circumstances, or when other feasible options have been exhausted. Nevertheless, there was a view that all options have to be considered, with an associated suggestion that it makes sense to plan for complex actions that may be necessary in the longer term.

Among respondents who did not think that relocation should be considered, some argued that such action is not realistic or that the costs of moving whole communities would be too high. There were also views that communities should not be abandoned and that, in the case of river flooding in particular, better approaches would be to regulate new development in the area, improve flood defences, deploy innovative technologies to protect individual properties and modify land management in the catchment area.

Processes: Making changes to the way we do things and the way we work together to enable us to create flood resilient places.

Community Councils and Flood Resilience Groups were highlighted as an avenue for sharing information to the wider community. The need for high quality communication when working with communities was referenced, as was tailoring approaches to local circumstances, including geographical risks and populations.

The value of networking and of sharing experiences, best practice, innovative solutions and case studies was highlighted and there was support for a single online access point for information, whether a dedicated website or an online portal, providing easier access to information, guidance and technical support.

Suggestions for how to improve efficiency, consistency and value in delivering flood actions included creating a single, national organisation responsible for flood risk and managing drainage networks and/or management of flood schemes resting with national bodies. The importance of partnerships and the need for co-ordination across different but related policy areas was also highlighted.

Other than large flood protection schemes, respondents thought Scotland should focus on supporting or funding NFM approaches and maintaining existing flood protection. In terms of funding sources or mechanisms that could be used to support flood resilience, they tended to favour all new development making a contribution. Payments to farmers, crofters and land managers were also seen as relatively important, but there was limited support for financial contributions from those who directly benefit from improved flood resilience.

One thing to improve resilience

In terms of the one thing that would do most to improve Scotland’s flood resilience, respondents were most likely to point to:

• Wider recognition and adoption of NFM techniques. There was also support for taking a catchment management approach that transcends local authority boundaries.
• A requirement for additional funding for flood management.
• A better integrated, comprehensive approach to management of flooding and effective partnership working.
• Raising awareness in relation to flood risk and the actions needed to improve resilience.
• Engaging with and listening to communities of all sizes. The need for transparency in communication between agencies and communities was also highlighted.
• Not building in high-risk areas including on floodplains. Make flooding a primary issue of concern in all planning applications and giving SEPA greater powers to prohibit development were also suggested.