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The Flood Risk Management (Scotland) Act 2009: Delivering Sustainable Flood Risk Management


3. An integrated approach to flood risk management


Flood risk management is the process of assessing, organising and implementing actions to deal with flood risk. The main outcome of the flood risk management planning process should be a set of sustainable actions being taken to reduce overall flood risk across Scotland.

Multiple organisations are involved in managing flood risk. It is therefore essential that an integrated approach, that balances national consistency and strategic decisions with local knowledge and accountability, is adopted.

This section provides guidance on:

  • principles that should be adopted to deliver an integrated approach to flood risk management;
  • the interaction of flood risk management with other land and water management decisions;
  • involving stakeholders in flood risk management.

Flood risk management plans

The preparation and implementation of flood risk management plans will be at the heart of future efforts to tackle flooding. The Act sets out a flood risk management planning process that will ensure that long-term and nationally-focused objectives are balanced with local knowledge and priorities. Table 4 summarises the key steps in preparing these plans, and Annex 1 provides further information on key milestones. Once in place, the plans will be reviewed and updated every six years.

Table 4 Key steps in preparing flood risk management plans

(National) Flood risk assessment - by 22 nd December 2011

The national flood risk assessment will create a broad-scale picture of the causes and impacts of flooding across Scotland. The assessment will lead to the identification of Potentially Vulnerable Areas that will be used to help target studies, actions and investment to reduce flood risk.

Flood hazard and flood risk strategies - by 22 nd December 2015

Building on flood risk assessment and mapping exercises, plans will be prepared to coordinate measures across catchments. Flood risk management strategies will allow for targeted investments and better decisions to be made about measures to reduce flood risk.

Local Flood Risk Management Plans - by June 2016

Local plans will supplement the strategic objectives and measures identified by SEPA. The will translate the strategies into coordinated actions to reduce the impacts of flooding.

The principal output of the planning process should be a set of sustainable actions to manage flood risk across Scotland. These actions should deal with all identified flood risks and should be selected following the guidance set out in this document.

The Act establishes lead roles for all the key steps in preparing and implementing flood risk management plans, although cooperation between SEPA and the responsible authorities will be required at all stages.

Scottish Ministers have tasked SEPA with ensuring that the most sustainable measures are identified and included within flood risk management plans. SEPA's strategic plans are a key step in the flood risk management process. The flood risk management strategies, and the measures which follow, will drive national investment decisions in each 6 year cycle. These plans will be subject to approval by the Scottish Ministers.

Flood risk management actions

Once a lead local authority has been agreed, the lead local authority for each local plan will lead on agreeing the funding routes and timetables by which actions will be taken forward locally. The Scottish Ministers, SEPA and the responsible authorities are then responsible for implementing the agreed actions and reducing flood risk.

The strategies and local plans can not be developed in isolation, SEPA and the responsible authorities must ensure that systems are in place to manage all interdependencies, while also ensuring that the national exercises being undertaken, such as the national flood risk assessment, take account of local knowledge and priorities.

Although developed through an integrated process that will lead to a set of coordinated objectives, measures and actions for Scotland, information will need to be presented in the two closely related sets of plans prepared by SEPA and local authorities (Figure 4).

Figure 4 Roles and responsibilities in preparing flood risk management plans

Figure 4 Roles and responsibilities in preparing flood risk management plans

The first set of flood risk management plans will be prepared and published by SEPA. These strategic plans will set the overall direction of flood risk management across Scotland. They will also fulfil the reporting requirements of the EC Floods Directive.

To promote stakeholder engagement and coordination with local plans, it is expected that SEPA will prepare a flood risk management strategy for each local plan district. This will be done working closely with the lead local authority and other responsible authorities relevant for that district.

The second set of plans, known as local flood risk management plans, will be published by lead local authorities. In addition to providing a local expression of the strategic plans prepared by SEPA, these 'tactical' plans will include a summary of how actions will be implemented in each local plan district. Local flood risk management plans will support engagement with local communities and should also contain both surface water management plans and any additional actions and information that they believe is necessary to support local needs.

SEPA and local authorities should integrate as far as practical the presentation, publication and consultation of their respective plans.

In urban areas, the coordination of actions to tackle surface water flooding presents a unique set of challenges. Local authorities will be expected to lead on the coordination of actions to deal with surface water flooding. This work should be coordinated and presented within local flood risk management plans. Surface water management and drainage are examined further in Section 4.

Delivering integrated FRM planning

Multiple organisations are involved in managing flood risk. It is therefore essential that a fully integrated approach, that balances the need for national consistency with local knowledge and accountability, is adopted. A top down approach that disengages local authorities and local communities from decision making must be avoided.

National consistency

Adoption of consistent principles, approaches and methods at each step in the process of managing flood risk will ensure a nationally comparable risk-based approach informs management and investment decisions. Areas where consistency will be particularly important include methods adopted to assess flood risk, approaches to considering climate change, and techniques adopted to appraise management options (Table 5). SEPA should lead on ensuring the appropriate level of national consistency is delivered.

Table 5 Areas where consistency should be promoted

Assessing and quantifying flood risk

Considering the full range of social, economic, environmental impacts of floods

Examining current and future risk based on climate change scenarios and other long term trends

Promoting and adopting a source, pathway impact approach to assessing and managing flood waters

Considering a full range of actions, paying particular attention to those that restore a catchments ability to slow or store flood water

Communicating flood risk and engaging with the public

Balancing local and national needs

A balance must be struck between national strategies and priorities and local decision making and accountability. This will require close collaboration and a structured planning process that creates the space and time needed to consider any competing needs and reach informed decisions.

The strategies set out in Flood risk management plans should establish the overall approach, for instance identify the need for particular combinations of measures or management response. Where these measures, for instance a flood protection scheme require significant public expenditure, more detailed design and appraisal work will be required to ensure that the best option and design is selected and tailored to suit local needs.

Joint ownership of plans and actions

The identification and undertaking of sustainable flood management actions will require close collaboration between SEPA, local authorities, Scottish Water, and other stakeholders. Ultimately, there must be joint ownership of the plans and the actions set out therein.

Wherever necessary, SEPA should ensure that decisions on setting objectives and identifying measures are taken jointly with the responsible authorities, as well as with others who could contribute to delivering actions and could be affected by decisions. Where agreements on objectives and measures cannot be reached, SEPA will have to set out any difficulties in reaching agreement in their report to the Scottish Ministers, who can then approve the plan, or require SEPA to undergo further consultation before it is approved.

The same principles apply to local authorities when developing the implementation plans. Where agreements can not be reached on how actions will be implemented, the Scottish Ministers will determine the content of the implementation plans.

Creating efficiencies in the development of flood protection schemes and measures

The promotion of joint working and sharing of skills and expertise will be challenging but should lead to efficiencies of time and resources between SEPA and the responsible authorities. Importantly, the process of preparing flood risk management plans should speed-up the process of taking forward and implementing a flood protection scheme or other measures. For example, the information generated by SEPA should fulfil, at least in part, early option appraisal stages of scheme development, while also supporting subsequent, more detailed assessments and appraisals.

Interactions with other issues

There will need to be close coordination of flood risk management planning work with other areas which affect or are affected by flood risk management, including the land use planning system, insurance provision and emergency response (Figure 5).

Land use planning decisions are one of the most powerful tools available to manage flood risk. This concept is set out in Scottish Planning Policy, which states that development which would have a significant probability of being affected by flooding or would increase the probability of flooding elsewhere should not be permitted. Where redevelopment occurs, the planning system can identify opportunities to build flood resilient structures, integrated urban drainage and flood management actions into the fabric of our urban landscapes.

Figure 5 Three elements of flood risk management

Figure 5 Three elements of flood risk management

Flood risk assessments and plans produced under the Act will provide additional information that will enable the planning authorities to plan and consider future development with a more complete picture of current and future flood risk and the insurance industry to offer premiums which reflect the risk of such provision.

Scottish emergency planning and response is founded on the concept of Integrated Emergency Management ( IEM). Under IEM, preparation and response to emergencies focus on the effects of events rather than their causes. Close ties between Scottish emergency planning, the Scottish Flood Forum and flood risk management planning will need to be established so as to coordinate actions to reduce flood risk with existing work to manage the effects of flooding, including where restoration and repair of homes and properties is being undertaken once the flood waters have receded.

Integrated land and water management

As far as is practicable, an integrated approach to land and water management should be pursued. When developing flood risk management plans, early links must be made with other relevant aspects of water and land management. In turn the findings from flood risk management plans should influence other planning initiatives in an interactive and iterative cycle. Making these links will help identify opportunities to deliver multiple benefits from flood risk management measures.

Examples of relevant policy areas include:

  • National planning framework;
  • Local and strategic development plan;
  • River Basin Management Plans;
  • Rural Development policy;
  • Shoreline management plans;
  • Marine spatial plans;
  • Green Networks;
  • Emergency response;
  • Economic development plans;
  • Asset management and investment plans;
  • Protection of critical national infrastructure;
  • Climate change adaptation and mitigation.

This is not an exhaustive list. The important point is that connections and dependencies should be considered early so as to allow links and synergies to be established and taken account of.

Ecosystem Services Approach

The ecosystem services approach (BOX 1) can be used to help create a common framework upon which flood management decisions can be balanced with other decisions, for instance spatial planning, food security, environmental regulation and river basin management.

River Basin Management Planning, which is led by SEPA, takes a source-to-sea approach to integrating land and water management to improve the quality of Scotland's Waters. The FRM Act requires consistency and coordination between River Basin Planning and flood risk management. Examples of where SEPA should ensure consistency and coordination include:

  • where possible, promoting land management measures that deliver coincident flooding and environmental benefits;
  • where possible not undermining the objectives of one, when addressing the other;
  • operating its monitoring regime so as to provide information about flooding;
  • managing advisory groups and consultation activities to reduce consultation fatigue.

SEPA must strike the right balance between protecting and improving the environment and supporting the social and economic needs of those who depend upon or are affected by land and water. Areas of particular importance to flood risk management include the construction and operation of reservoirs, CAR licensing of flood protection schemes, land drainage and the maintenance of watercourses and flood defences.

BOX 1 Ecosystem services

Our natural environment contains natural capital that underpins our economic activity, our well being and the earth's life support systems. The food we eat, the water we drink and the air we breathe are only available to us because the natural environment cycles nutrients, purifies water and generates oxygen.

This natural capital is locked within a series of living, interacting systems - ecosystems. A river system and the land around it can be described as an ecosystem. In these systems, people, other living things and the environment all interact. These ecosystems provide the services (often called ecosystem services) that we need. Well-functioning ecosystems provide these services very cost-effectively compared with other alternatives.

The ecosystem approach offers a useful tool to understand value and account for the physical, biological and chemical interactions within and flowing from ecosystems.

The information, knowledge and structures created to support flood risk management should also be used to support continued improvements to River Basin Planning. The greatest opportunities are likely be in the areas of diffuse pollution, water resources and hydro morphology, all of which should benefit significantly from the information, tools and knowledge that will be generated through the preparation of flood risk management plans.

SEPA should work towards an appropriate integration of River Basin Planning and Flood Risk Management Planning so as to develop a joined up approach to protecting and managing Scotland's water resources.

Involving stakeholders

SEPA and the responsible authorities will need to work in partnership with communities and land managers to help them understand flood risk, while encouraging them become involved in decision-making and flood management actions. This will include giving communities a bigger say in what action is taken and a more active role in decisions on local funding priorities. Ultimately, SEPA and the responsible authorities should be accountable for the decisions they take.

Opportunities for stakeholder participation should be incorporated at all stage of flood risk management, from the preparation of flood risk management plans through to schemes and projects. Engagement with interested parties should aim to gain a sound understanding of local issues and an appreciation of the concerns of individuals, communities and businesses potentially affected, as well as more strategic and national perspectives.

SEPA and the responsible authorities need to consider and utilise a range of different mechanisms for engagement including physical and online forums, mobile texts as well as formal written consultation routes.

Information should be conveyed to stakeholders in a transparent way, using plain language to enable stakeholders to gain a better understanding of the decisions that affect them and what they can do to influence or get involved in the decision making process.

Information on flooding and its management should also be communicated through the advisory services that provide support to businesses and land managers.

To support the preparation of flood risk management plans, the Act provides for the creation of advisory groups. The groups, which must include representation from a wide range of interests, will provide an important forum for discussing flood management and engaging with the stakeholder community. SEPA and the responsible authorities will need to consider how best to engage with existing stakeholder forums and whether further fora will need to be established.