National Flood Resilience Strategy: consultation analysis

2. Places

The Scottish Government believes that actions taken to build flood resilience should take a place-based approach, with decisions made in a joined-up way across responsible authorities, delivery partners and communities to provide multiple benefits to a community. In the shorter term, delivery partners should consider how to adopt a whole-catchment approach to their planning to enable more joined-up decisions about how to manage water effectively. As part of this catchment approach, consideration must be given to urban and rural land use and how to make space for water recognising that water will always want to follow its natural course.

At a household level, making space for water could be something as simple as installing a raingarden to reduce the amount of rainwater entering drainage systems during storms. For a community it could be thinking about how they can reduce the number of properties on the floodplain and at a catchment level this could mean changing land use practices to slow the flow of water into rivers and allow more water to be retained in upland areas.

Question 10: How can we ensure that our places are designed to be flood resilient in future?

Around 185 respondents answered Question 10.

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. It was also suggested that a flood resilience approach will require buy in from the insurance industry and that early engagement with insurers will be essential to ensure that proposed buildings are insurable.

Some respondents highlighted the importance of implementing policies on flooding set out in the Fourth National Planning Framework (NPF4).

Avoiding development in flood-prone locations

The most frequently made point, particularly by Individual and Community Council or group respondents, was that there should be no further building on floodplains or other sites with a high risk of flooding or a history of flooding. A Local authority respondent was clear that, in their view, this should include redevelopment of brownfield sites that are prone to flooding. Some respondents argued that the risk of flooding in the area around a proposed development should also 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.

An associated point, made by a number of respondents, was that flood resilience should be considered, or should be a priority, in all planning decisions, with suggestions that this should apply to infrastructure and energy efficiency projects as well as to additional development in urban areas. There were also concerns that, at present, some Local Authority Planning Committees are too keen to be ‘pro-development’ and that planning applications in areas at risk of flooding are still being approved, even when SEPA have raised objections. Additionally, it was argued that flood resilience should be required for projects that may not require formal planning approval if undertaken as Permitted Development or under roads legislation, or that permitted development rights that can impact flood risk should be reviewed.

The need to understand future climate risks in order to plan appropriately was highlighted, with suggestions that comprehensive risk assessments must use generous projections for rainfall based on future climatic conditions or, in coastal areas, on potential sea level rise. A Local authority respondent noted their view that, while Representative Concentration Pathway (RCP) 8.5^[5] sets a good standard for drainage and flood design, there is likely to be a requirement to plan for more extreme scenarios in the future. However, an alternative perspective (raised by different respondents at other questions), was that RCP 8.5 is a high scenario and may be overly cautious.

In addition to climate considerations, it was suggested that data on the underlying geology of an area should be used when mapping floodplains and that evidence of past flooding events in the geological record should be considered.

While there was a view that regulations should prioritise developments that will bring the most benefit or impact, others argued specifically that the risk of flooding should be prioritised over other considerations – including environmental protection, economic development, tourism or public interest in housing provision. However, there was also a view that planning decisions should not reduce the value of land purchased in good faith, where climate change means flood risks have arisen since the land was acquired.

Catchment scale approach and natural flood management techniques

Managing risk of fluvial flooding at catchment level and deploying NFM techniques were two frequent suggestions for making places more flood resilient.

Some of the respondents advocating a catchment scale approach argued that this should involve reviewing the upstream land management practices of farmers and large landowners with felling trees, creating new drainage channels and straightening water courses given as examples of practices that can contribute to faster run off and exacerbate flooding downstream. In contrast, positive actions – for which landowners might be compensated – could include using NFM techniques to hold water upstream after heavy rainfall and slow run off. Examples included: restoring peatlands; planting trees; creating leaky dams; introducing beavers; re-meandering rivers; encouraging planting on riverbanks to reduce their erosion; allowing more land to flood; creating or protecting wetlands; and reconnecting rivers to their floodplains. It was also suggested that the efficacy of NFM techniques needs to be evaluated.

Other suggestions with respect to increased management of rivers included placing a legal obligation on large landowners to maintain riverbanks; allowing land owners the right to put constructions in streams and rivers to slow the flow of water and dredging rivers where silt has accumulated.

Reducing run off in urban areas

Actions to reduce run off in more urban areas were also suggested by a number of respondents, including: avoiding or controlling use of impermeable surfaces for pavements, driveways and gardens; creating rain gardens; installing green roofs; and harvesting rainwater. The potential to use canals to store flood water was also highlighted.

There was, however, a concern that flood resilience should not be achieved at the expense of other, beneficial uses of existing greenspaces, and that greenspace which can double as flood resilience capacity must be extended.

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 also suggestions that all urban realm projects should include metrics and targets to deliver flood resilience measures, or that a flooding ‘net zero’ test for new developments should include both current and future flood risks. It was suggested that the planning system and/or the building regulatory framework should be revised – 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. It was also suggested that detailed flood resilient design and flood reaction plans should be required for any development proposed in a flood risk area.

There were also points on improving enforcement and ensuring that flood related measures required as part of planning permission are actually implemented.

Drainage systems

SuDS were seen as important by some respondents, with suggestions that these should be standard practice in urban planning and should be considered from the initial design stage. It was argued that SuDS should aim to deliver multiple benefits, for example in relation to improved biodiversity and place enhancement. Adherence to SEPA’s Regulatory Method on SuDS, and clearer monitoring on their use by local planning authorities was thought to be important, although it was also suggested that SuDS design standards may not fully attenuate extreme rainfall events, which may still produce a greater run off than an undeveloped site.

Although most respondents referenced SuDS in the context of new development, there was also a suggestion that retrofitting should be considered.

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.

Property level protection

With respect to individual properties, some respondents argued that Building Standards should be used to mandate flood resilience measures, and that this approach for new homes can be less costly than retrofitting at a later date. A Local authority respondent anticipated that if resilience measures were specified as standard for all new builds, then costs would fall. Incentives for retrofitting were also proposed, as was an onus on insurance companies to build back more flood resilient properties rather than like-for-like replacement.

Suggested measures included: elevating buildings; installing waterproofed tanking for ground floors; valves on sewage pipes; higher positioning of electrical sockets; replacing timber floors with concrete that will not warp or rot after flooding; and installing floodgates (for individual properties or groups of properties).

There was a welcome for the potential development of Flood Performance Certificates and it was anticipated that a comprehensive scoring methodology for resilience measures will be crucial to demonstrate their benefits.

Leadership and partnership working

Some respondents commented on the importance of effective management of flood resilience, including the relationship and communication between stakeholders. One suggestion was that the existing roles of the Scottish Government, SEPA and Scottish Water should be reviewed and, potentially, a new body created. There were also calls for:

• Better communication between the Scottish Government, SEPA and Scottish Water.
• SEPA and Scottish Water to have more active roles in delivering the new strategy.
• A move away from an approach based on individual local authority areas, with a small number of respondents reporting their experience of apparent lack of co-operation between neighbouring authorities when addressing flooding problems.
• Community flood groups that can form collaborative links with the local authority and flood support organisations, and front-line agencies that view communities as an essential partner to be involved in co-design of measures to improve resilience.

Also with respect to valuing local knowledge, it was argued that the strategy could be advanced by SEPA taking a more flexible approach with respect to licensing and managing watercourses.

Local planning

Creation of local flood risk management plans that identify areas and outline actions to be taken were also seen as important. Suggestions included that:

• Flooding could be included in the Place Standard tool.
• Local communities who are preparing Local Place Plans should be encouraged to consider flood resilience as a core part of their approach.

Updating legislation, regulations and guidance

It was suggested that flooding regulations and building standards should be updated to ensure new construction and renovations meet resilience standards. Amending roads legislation to allow the temporary use of roads to formally manage exceedance / flow was also proposed.

Professional or representative body and Local authority respondents were among those referencing the need for guidance on delivery of flood resilient places, with requests for this to be clear and streamlined. Suggestions included that there should be best practice in relation to specific sites and challenges – for example achieving flood resilience whilst also creating active and attractive frontage at street level and maintaining level access to meet disability needs – and that nature-based water management solutions should be emphasised in the Developing with Nature Guidance.

The need for a strong, national evidence base of flood data to support decision-making was also highlighted.

Capacity

It was suggested that a national program to develop the sector is required, building skills and developing 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, although it was noted that resource pressures are already placing a strain on access to specialised skills within local authorities and that this needs to be addressed if the Strategy is to be successful.

Funding

Respondents referenced the importance of funding, including grant funding to stimulate uptake for property measures, resources for community engagement and capacity building and resources to implement NFM solutions and blue-green infrastructure. Suggestions included:

• Additional funding to support local authorities and partner organisations in the transition to flood resilient places, along with a review of cost-benefit scoring methodology.
• Better alignment of funding sources, timescales and approval processes.
• Funding for housing that reflects consideration of flood resilience and managing water above-ground.

Other issues raised

Among other issues raised by respondents, the most frequent was acceptance that, in some circumstances, relocation may be the best available option. Relocation is considered further at Question 14. Additional suggestions for making places more flood resilient included:

• Improved emergency preparedness, such as early warning systems and evacuation plans.
• Identifying opportunities for historic assets to increase resilience, for instance through the use and reuse of historic blue-green infrastructure.

Question 11: To what extent do you agree that there is a need to make space for water to improve the flood resilience of our villages, towns and cities?

Responses to Question 11 by respondent type are set out in Table 3 below.

Percentages may not sum to 100% due to rounding

Almost all respondents (98% of those answering the question) were in agreement that there is a need to make space for water to improve the flood resilience of our villages, towns and cities. A very substantial majority, 87% of those answering, strongly agreed with the proposition.

Question 12: In urban areas, we should make more use of our greenspace and urban watercourses to help manage increased rainfall and reduce the impacts of surface water flooding. Which of the following do you think would be helpful? (Please rank by importance)

Four options were presented at this question:

• Increasing the use of sustainable drainage systems
• Creating blue and green drainage networks to enhance existing drainage systems
• Using available greenspace such as parks and sports pitches to help soak up and store water in the heaviest rainfall events to prevent drainage systems becoming overwhelmed
• Creating raingardens in public parks and streets.

Around 180 respondents responded to this question.

Preferred options

Respondents were most likely to think that ‘increasing the use of sustainable drainage systems’ would be most helpful when making more use of our greenspace and urban watercourses to help manage increased rainfall and reduce the impacts of surface water flooding; 48 respondents selected this option as most important.

‘Creating blue and green drainage networks’ also received high levels of support, with 42 respondents selecting this option as most important and 52 as second most important.

‘Creating raingardens’ tended to be seen as less important, with 71 respondents putting this option in fourth place.

‘Other’ suggestions

Around 80 respondents made a further comment in relation to the ‘Other’ option.

Among suggestions for ‘other’ things that can help manage increased rainfall and reduce the impacts of surface water flooding, the most frequent related to water conservation and storage infrastructure. Specific suggestions included:

• Use of regulatory, funding and procurement systems to change the default to permeable and storage-based solutions on existing hard footprints.
• Pro-actively using other existing public open space, including roads, to store and route flood exceedance as part of the design of our places.
• Building-scale rainwater retention tanks could collect rainwater runoff from roofs to reduce the amount of water that flows into streets and waterways.
• More use of river catchments, reservoirs, holding point ponds and ‘old’ urban watercourse culverts were also highlighted.

There were also frequent references to upgrading, retrofitting, maintaining and clearing existing drainage systems.

In terms of greenspaces and/or any new development, there were references to:

• Increasing both public and private greenspaces, including through construction of green roofs/walls and by tree planting.
• Limiting the loss of permeable surfaces. It was suggested that small roads, car parks and pavements should use permeable materials for surfacing that allow the ingress of water and that homeowners should be encouraged to preserve green gardens instead of block paving or artificial grass.

Less frequent suggestions included:

• Using derelict and vacant sites for attenuating foul and surface water.
• Looking at grey water infrastructure. There was a view that all new buildings should contribute to resilience by using greywater systems and to making system level changes that ‘green the grey’ over time.
• Re-establishing floodplains, particularly those for urban watercourses.
• Pursuing nature-based solutions, such as beaver reintroductions. The Ealing Beaver Project (London) was cited as a cost-effective example of helping develop more flood resilient landscapes.

Question 13: If we are to make more use of our river catchments and coastal areas to increase our flood resilience, which of the following do you think would be helpful? (Please rank by importance)

Six options were presented at this question:

• Using soil, and land management techniques to slow down the flow of water and increase infiltration and water retention
• Using river and floodplain management techniques such as re-introducing meanders to rivers to slow flow and enhancing floodplains and wetlands to increase storage
• Increasing woodland to help intercept, slow and store water throughout a catchment
• Restoring peatlands to absorb, store and release water slowly
• Enhancing natural dune systems to maintain a natural barrier that reduces the risk of tidal inundation
• Managing saltmarsh and mudflats in estuaries to store water and dissipate wave energy.

Around 180 respondents responded to this question.

Preferred options

Respondents were most likely to think that ‘using river and floodplain management techniques’ would be most helpful; 53 respondents selected this option as most helpful and 39 respondents as second most helpful. ‘Using soil and land management techniques’ was also a popular option, seen as most helpful by 41 respondents and second most helpful by 36 respondents. ‘Managing saltmarsh and mudflats in estuaries to store water and dissipate wave energy’ tended to be seen as the least helpful option.

‘Other’ suggestions

Around 70 respondents made a further comment in relation to the ‘Other’ option.

Among suggestions for other ways of making more use of our river catchments and coastal areas to increase our flood resilience, the most frequent were:

• Holistic land use management and natural flood management including rewilding, planting of appropriate sand catching grasses, and reintroducing keystone species. Also looking at floodplain management, the removal of flood banks and the use of measures such as farm bunds.
• Reviewing and revising relevant legislation, regulations, strategic management plans and auditing/frameworks.
• Undertaking further research to increase our understanding around building flood resilience.

Less frequent suggestions included:

• Tightening of planning policies, including to prevent development on floodplains. Also preventing/reducing development in and around dune systems, riversides and estuaries.
• Addressing water storage, for example storing water behind flood embankments, and using canals and other water storage places in urban areas.
• Repairing and improving existing infrastructure, such as leaky dams, culverts and bridges.
• The use of offshore reefs, including to reduce the impact of erosion during stormy sea conditions and tidal surges.
• Making sufficient funding available, including to maximise the benefits from mitigation and adaptation. Also look at the role of innovative business models.
• The use of technology, such as LiDAR (Light Detection and Ranging), to create flood models, analyse how land is used and prioritise communities and areas with the highest exposure to flooding.

Question 14: It may not be possible for the most exposed communities to maintain a level of flood resilience indefinitely and alternative long-term planning needs to take place. Should moving communities away from areas with the highest exposure be considered as an option? Please give the reasons for your answer.

Responses to Question 14 by respondent type are set out in Table 4 below.

A considerable majority of respondents – 90% of those answering the question – thought that moving communities away from areas with the highest exposure should be considered as an option.

Around 150 respondents gave their reasons. Key themes from these further comments are summarised below.

A frequently made point, irrespective of the respondent’s answer at the closed question, was that moving individuals or communities should be considered only as a last resort, in extreme circumstances, or when other feasible options have been exhausted. The difficult, potentially highly emotive nature of such a decision was often acknowledged. There was also a view that any decision to relocate should rest with individuals and that some may prefer to accept a risk of flooding rather than leave their existing homes.

Reasons moving communities should be considered

Among reasons for thinking that moving communities should be considered, the most frequent argument was 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. In the face of climate change and increased flood risks, some respondents saw relocation as potentially more cost-effective and more sustainable than large flood protection schemes. It was also thought likely to be the only practical option in some coastal locations where sea level rise and storm surges increase the risk of flooding or where erosion cannot be prevented. Safety considerations, and the importance of protecting life as well as property were also emphasised and it was noted that some individuals and communities that have experienced repeated flooding events might welcome the opportunity to move if provided with assistance to do so.

A minority view was that relocation should not be restricted to floodplains and coastal areas but should also be applied in urban areas as part of surface water management planning.

Reasons moving communities should not be considered

Among respondents who did not think that relocation should be considered, it was 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.

Practical considerations associated with relocation

Consultation

Some respondents highlighted the importance of early consultation with communities for whom relocation is a possibility, including because such engagement may increase understanding of the risks and the need to adapt.^[6] The village of Fairbourne on the coast of North Wales was referenced as illustrating the impacts that the possibility of relocation can have on a community, including the anxiety and stress that can be involved.

National guidelines

Some respondents identified a requirement for clear national policy/guidelines on decision making to ensure a robust, consistent approach. Local authority respondents were among those raising this issue.

It was also noted that there are currently no criteria for adopting a proactive process to identify areas where relocation could be appropriate and it was argued that, as a reactive measure, relocation is unlikely to link with other flood risk management or land use planning processes. It was suggested that improving the evidence base for frequent flooding would support proactive identification of areas with highest exposure.

Funding

A requirement for financial compensation and other support for those who need to relocate was a frequently raised issue, particularly among Individual respondents. However, it was also noted that the current approach to flood risk management funding does not support relocation: a Local authority respondent reported having been asked to consider property abandonment/relocation as an alternative to building flood walls but that this was not supported as a fundable option in a formal flood protection scheme under current legislation.

It was suggested that, where there are no feasible alternatives, state funding to purchase properties can not only support a Just Transition but also allow the area vacated to be restored – for example as a floodplain – to contribute to local flood resilience. There was also a call for long-term government policy on coastal adaptation together with a funding review to ensure that adaptation and more traditional management approaches are both considered.

Integrating flooding and erosion management

It was observed that the current flood risk management approach does not integrate coastal and fluvial erosion with the assessment of flooding, and it was suggested that responsibility for assessment of flooding and erosion should be brought together, with clear remits to understand and plan for future impacts.

Impact on other policy areas

Potential implications of a relocation policy for housing and wider planning policies were also highlighted with references to leaving properties derelict when there are already housing shortages and to potential impacts in relation to:

• Delivering sustainable communities in close proximity to existing facilities and infrastructure if, for example, parts of existing settlements are rendered ‘uninhabitable’ by inability of homeowners, housebuilders or commercial developers to obtain finance.
• NPF4 policy on developing brownfield sites ahead of greenfield sites if areas of brownfield land cannot be redeveloped.
• Availability of building materials such as aggregates for replacement housing.