Building standards - proposed changes to Section 3.3 Flooding and Groundwater: consultation analysis

1 Introduction

1.1 Introduction

1.1.1 Optimal Economics has been invited by the Building Standards Division (BSD) of the Scottish Government to submit a tender to undertake an analysis of responses to the public consultation on the proposed changes to Section 3.3 Flooding and Groundwater of the Technical Handbooks.

1.2 The Consultation

1.2.1 In 2018, it was estimated that 1 in 11 homes in Scotland were at risk from flooding from rivers, surface water and sea. This is projected to increase to 1 in 9 homes if a 2080 future climate change scenario is considered. The responsibility for protecting property from flooding rests with the homeowner.

1.2.2 The Property Flood Resilience Delivery Group (PFRDG) was established to prepare and deliver an action plan to help property owners take action to make their properties more resilient against the impacts of flooding. BSD, as a member of the PFRDG, has considered how property flood resilience (PFR) may be incorporated into new and existing homes.

1.2.3 BSD prepares and updates building standards legislation and guidance documents and this consultation sets out proposed updates to guidance in Section 3.3 Flooding and Groundwater of the Building Standards Technical Handbook, including the introduction of a new Annex 3.B Building Standards Flood Guide.

1.2.4 The purpose of the update is to provide designers and verifiers with more knowledge and information on how to meet the Mandatory Standard 3.3 where a flood risk has been identified. The consultation seeks to obtain the views and opinions of stakeholders on any updates and amendments to the Technical Handbooks and has ten questions:

• Five questions on proposed updates to the main parts of the standard.
• Three more general questions on the proposed updates.
• Two questions on the introduction of Annex 3.B.

1.3 Methodology

1.3.1 The first stage of the analysis was to review the responses to ensure that they are relevant to the consultation, whether there were any duplicate responses and whether there were any campaign responses. The validation stage also developed a typology for analysing responses. All respondents were allocated to one of the following groups:

• Individuals.
• Local authorities.
• Other.

1.3.2 The second stage of the research focused on establishing an appropriate framework for the analysis. The consultation combined both quantitative and qualitative aspects to each question and while the quantitative responses provided a good overview of opinion, the qualitative comments provided much more detail to support the response.

1.3.3 A coding framework was established of the main themes with a more detailed coding of each main theme also established. The framework allowed responses to be analysed to reflect the issues/views for the typology groups set out above.

1.3.4 The final stage of the research was the analysis and reporting of the results. All ‘closed’ questions asked for a yes/no answer and the analysis presents the number of responses by group answering yes/no and those who did not answer the question. The overall proportion of responses answering yes/no is also provided.

1.3.5 All responses to the ‘open’ questions have been given equal weighting, allowing every idea presented to be considered. Where possible we have used a number of simple bands to provide an indication of the frequency of an idea, although it is noted that this treats the response from an individual with the same weight as the response from a ‘representative body’ which many have many members. Nevertheless, the following bands have been used:

• Few: up to 3 responses.
• Several: 4 to 10 responses.
• Many: over 10 responses.

1.4 Overview of Responses

1.4.1 At the close of the consultation period (3^rd October 2025) there were 18 responses submitted online and a further two responses submitted directly to BSD. These additional responses were input into Citizen Space taking the total number of responses to 20.

1.4.2 The responses were categorized into the following three groups:

• Individuals: respondents who were individuals.
• Local Authorities: respondents who were from a local authority.
• Other: all other organisations.

1.4.3 Table 1.1 shows the distribution of respondents by group with Appendix A providing a list of respondents by group.

1.5 Report Structure

1.5.1 The remainder of the report is organised as follows:

• Section 2 presents the analysis for draft updated guidance on Section 3.3 flooding and groundwater.
• Section 3 sets out the analysis relating to Annex 3.B building standards advice on flooding.