Delivering sustainable flood risk management: guidance (2019)
Second edition of statutory guidance to SEPA, local authorities and Scottish Water on fulfilling their responsibilities under the Flood Risk Management (Scotland) Act 2009.
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;
Flood risk management strategies and local flood risk management plans
The preparation and implementation of flood risk management strategies and local flood risk management plans is at the heart of Scotland’s efforts to tackle flooding. The Act sets out a flood risk management planning process that ensures that long-term and nationally-focused objectives are balanced with local knowledge and priorities. Table 4 summarises the key steps in preparing these strategies and plans, and Annex 1 provides further information on key milestones in the development of the documents for 2021 and 2022 respectively. The strategies and plans are reviewed and updated every six years.
Table 4 Key steps in preparing flood risk management strategies and local flood risk management plans
National flood risk assessment – by 22nd December 2018
The national flood risk assessment (NFRA) provides a broad-scale picture of the causes and impacts of flooding across Scotland. It is important to regularly update the NFRA to consider new data and modelling techniques. The assessment leads to the review and identification of Potentially Vulnerable Areas, which is used to help target actions and investment to reduce flood risk.
Flood risk management strategies – by 22nd December 2021
Building on the NFRA, a strategic assessment of flood risk management actions and the analysis of recent more detailed local flood studies, the next generation of flood risk management strategies will be prepared to coordinate actions across catchments post 2021. Flood risk management strategies support targeted investments and better decision-making to reduce flood risk.
Local flood risk management plans – by June 2022
Local plans supplement the strategic objectives and actions identified in the strategies. They translate the strategies into an implementation plan to reduce the impacts of flooding with more detail on local delivery including timing, funding and coordination arrangements.
The principal output of the planning process should be a set of sustainable actions to manage flood risk across Scotland. These actions 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 asked SEPA to ensure that the most sustainable measures are identified and included within flood risk management strategies. These strategies are a key step in the flood risk management process. The strategies, and the actions which follow, drive national investment decisions in each 6 year cycle and are subject to approval by the Scottish Ministers.
Flood risk management actions
The lead local authority for each local plan district leads on coordinating the agreement of the funding routes and timetables by which actions will be taken forward locally. The Scottish Ministers, SEPA and the responsible authorities are responsible for implementing the agreed actions and reducing flood risk.
Figure 4 Roles and responsibilities in preparing flood risk management strategies and local plans
The strategies and local flood risk management plans must not be developed in isolation (Figure 4).
SEPA and the responsible authorities must ensure that systems are in place to manage interdependencies, while also ensuring that the national exercises being undertaken, such as the national flood risk assessment, take account of local knowledge and priorities. Chapter 7 provides further information on working in partnership.
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).
The flood risk management strategies will be prepared and published by SEPA. These strategies set the overall direction of flood risk management across Scotland. They also fulfil the reporting requirements of the EU Floods Directive.
SEPA is responsible for reviewing and updating the flood risk management strategy for each local plan district. This is done by working closely with the lead local authority and other responsible authorities relevant for that district.
The local flood risk management plans are led by lead local authorities. In addition to providing a local expression of the strategies prepared by SEPA, these ‘tactical’ plans include a summary of how actions will be implemented in each local plan district. Local flood risk management plans support engagement with local communities and should also contain surface water management actions and any other 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 strategies and plans.
In urban areas, the coordination of actions to tackle surface water flooding presents a unique set of challenges. Local authorities are 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 chapter 4.
Implementation of the actions must be reviewed regularly. The lead local authorities prepare an interim report between 2018 and 2019 and a final report at the end of each flood risk management cycle (2022) on the progress of tackling flood risk and implementing actions.
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.
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 future challenges (such as climate change, societal, cultural and political changes), and techniques adopted to appraise management options (Table 5).
SEPA should lead on ensuring the appropriate level of national consistency is delivered. Guidance documents to support national consistency are summarised in Annex 3.
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 catchment’s 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 requires close collaboration and a structured planning process that creates the space and time needed to consider any competing needs and reach informed decisions.
The flood risk management strategies should establish the overall approach, for instance by identifying the most sustainable and most appropriate combination of actions. Where these actions, for example 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 strategies, local plans and actions
The identification and delivery of sustainable flood management actions requires close collaboration between SEPA, responsible authorities and other stakeholders. Ultimately, there must be joint ownership of the strategies, local plans and the actions set out therein.
Wherever necessary, SEPA should ensure that decisions on setting objectives and identifying actions 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 actions 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 strategies, or require SEPA to undergo further consultation before it is approved.
The same principles apply to local authorities when developing the local plans. Where agreements cannot 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 actions
The promotion of joint working and sharing of skills and expertise is often challenging but should lead to efficiencies of time and resources between SEPA and the responsible authorities. Importantly, the process of preparing flood risk management strategies and local flood risk management plans should assist in the process of taking forward and implementing a flood protection scheme or other actions. 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 needs 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, infrastructure planning, coastal erosion, insurance provision and emergency response (Figure 5).
Land-use planning decisions can be one of the most powerful tools available to manage flood risk. This concept is set out in Scottish Planning Policy 2014, which states that the planning system should prevent development which would have a significant probability of being affected by flooding or would increase the probability of flooding elsewhere. Where redevelopment occurs, the planning system can identify opportunities to build flood resilient structures, sustainable urban drainage and flood management actions that are integrated into the fabric of our urban landscapes. SEPA has been developing its guidance to planning authorities on how flood risk should be taken into consideration in the land-use planning process.
Figure 5 Three elements of flood risk management
Flood risk management strategies and local plans produced under the Act provide additional information to enable planning authorities to plan and consider future development with a more complete picture of current and future flood risk.
The strategies and local plans include a series of land-use planning related actions, which can help guide the management of flood risk within the Development Plan area. They include nationally applicable land-use planning actions, as well as actions specific to potentially vulnerable areas that may have influence on land use matters. The Development Plan process will be the mechanism for delivering these actions.
Planning authorities should review the actions in each of the potentially vulnerable areas in their Development Plan area in order to identify any opportunities to help deliver them through the planning process.
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 emergency planning, the Scottish Flood Forum and flood risk management planning are needed to coordinate actions and to manage the effects of flooding, including where restoration and repair of homes and properties is being undertaken once the flood waters have receded. It is important to build community and property resilience to reduce the impacts of flooding.
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 strategies and local 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 planning should influence other planning processes or activities in an interactive and iterative cycle. Making these links helps to identify opportunities to deliver multiple benefits from flood risk management actions.
Examples of relevant policy areas include:
- National land-use planning policy
- Local and strategic development plan;
- River basin management plans;
- Coastal erosion and shoreline management plans;
- Marine spatial plans;
- Green networks;
- Emergency response;
- Economic development plans;
- Asset management and investment plans;
- Protection of critical national infrastructure;
- Community resilience
- Curriculum for Excellence
- 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 accounted for.
Links with river basin management plans
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 water environment.
The 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 not undermining the objectives of one, when addressing the other;
- operating its monitoring regime so as to provide information about flooding;
- managing data to allow flood risk management and river basin management to exchange information easily and take advantage of opportunities for coordination of objectives and actions;
- managing advisory groups and consultation activities to reduce consultation fatigue.
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 strategies and local plans.
SEPA will work towards supporting integration of River Basin Planning and Flood Risk Management Planning to develop a joined up approach to protecting and managing Scotland’s water environment.
SEPA, and the responsible authorities will need to work in partnership with communities, businesses and land managers to help them understand flood risk, while encouraging them to 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.
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