National Flood Resilience Strategy: consultation analysis

4. Summary

Question 20: What is your main concern about flooding?

Around 180 respondents answered Question 20, raising a broad range of concerns. Some of the issues raised related to current activity or impact while others raised concerns about problems or challenges not being addressed.

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

The most frequently raised issues related to current activity or impact were:

• Impact on communities, and particularly the most vulnerable. Risk to safety and fear that lives will be lost. Physical and mental health impacts for those who are flooded or live with fear of flooding.

The most frequently raised concerns about problems or challenges which respondents saw as not being addressed adequately were:

• Failure of decision makers to engage with and listen to local communities.
• Lack of awareness of increasing flood risk among the public contributing to lack of understanding of their flood risk and lack of preparation for flooding. Arising from this, an expectation that traditional flood protection schemes can be provided or that local authorities can ‘solve’ flooding problems.

Other concerns raised by included:

• The potential burden on volunteers.

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

The most frequently raised issues related to current activity or impact were:

• Climate change causing increased amounts of rainfall and greater risk of flooding, which is becoming more frequent, more severe, and more widespread, putting more properties at risk. Also concerns around sea level rise and coastal erosion.
• Existing flood defences and drainage proving inadequate or not being properly maintained.
• Damage to, or loss of, homes. Falling property values, rising insurance costs and inability to get insurance.
• Damage to infrastructure and services, including disruption to transport network.
• Damage and loss of revenue for businesses.
• Environmental damage and loss of habitat caused by sediments or sewage polluting water courses and disrupting aquatic ecosystems.
• Damage to agricultural land with impacts on food growing. Farmers being blamed for causing flooding or expected to mitigate its effects.
• Upland land management increasing volume of run-off water or the risk of landslip, and associated concerns with respect to funding schemes that may promote activities that contribute to flooding.
• Too much reliance on hard engineering solutions.

The most frequently raised concerns about problems or challenges which respondents saw as not being addressed adequately were:

• Failure to take a catchment scale approach, or to adopt NFM techniques.

Other concerns raised included:

• Risk that an over-cautious approach (using climate protections based on a high emissions scenario) leads to some areas being considered at risk of flooding when this is may not be the case.
• Failing to consider flooding and drought as two sides of the same problem.
• Trying to reconcile potentially contradictory policies relating to mitigation of flooding and redevelopment of brownfield sites.
• Risk of irreparable damage to historic properties and associated financial harm through repair costs and reduced visitor numbers.
• Reduction of accessible greenspace and particularly loss of access and damage to sports facilities.

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

The most frequently raised issues related to current activity or circumstances were:

• A planning system that continues to approve development on flood plains and other places at risk of flooding.
• A fragmented regulatory approach that does not encourage co-operation across local authority boundaries.
• Too few qualified and experienced staff in local authorities and gaps in the evidence base needed for decision making.

The most frequently raised concerns about problems or challenges which respondents saw as not being addressed adequately were:

• Lack of action in relation to flooding by the Scottish Government and its agencies resulting in lack of preparedness.
• Lack of funding and investment in flood management and lack of support for those affected by flooding.

Question 21: What one thing would do the most to improve Scotland’s flood resilience?

Around 175 respondents answered Question 21.

Wider recognition and adoption of NFM techniques to hold water and slow run off was the most frequent suggestion for one thing to improve Scotland’s flood resilience, with associated benefits to biodiversity were also highlighted. There was also support for taking a catchment management approach that transcends local authority boundaries. Examples of NFM included: setting more land set aside for water capture and storage; planting trees; stopping burning and overgrazing of upland areas; improving soil health; and introducing beavers. It was suggested that incentives should be provided for land management that helps to reduce flooding or, conversely, that existing subsidies for increasing drainage should be stopped.

A requirement for additional funding for flood management was another frequent suggestion. Some respondents proposed specific purposes for funding including providing equipment to local resilience groups; a focus on surface water management; a property flood resilience grant scheme with a portion of funds prioritised for social housing and properties in deprived areas; a Flood Resilience Partnership Fund to guarantee community involvement; and a Flood Resilience team within local authorities.

Other frequently raised priorities were:

• A better integrated, comprehensive approach to management of flooding and effective partnership working. One view was that everyone from national and local government to communities and households will need to play their part.
• Raising awareness in relation to flood risk and the actions needed to improve resilience. Local authority respondents suggested normalising discussion of the need to adapt to climate change and acceptance that living with water on the surface in some locations may help to reduce risk of more serious flooding in other parts of the catchment were seen as important.
• Engaging with and listening to communities of all sizes. This point was often raised by Individual respondents. The need for transparency in communication between agencies and communities and guaranteed community involvement in decision making were also suggested.
• Not building in high-risk areas including on floodplains. Again, this was a suggestion that tended to be made by Individual respondents. In some cases this there was an associated view of short comings in existing planning processes or the failure to listen to expert advice. Make flooding a primary issue of concern in all planning applications and giving SEPA greater powers to prohibit development were also suggested.

Other issues highlighted included:

• Requiring flood resilient design and building practices, for example inclusion of greenspaces in all developments and restricting use of concrete and plastic grass. It was also suggested that housing developers should meet costs for increased drainage infrastructure.
• Improved maintenance of existing flood defence infrastructure.
• Accepting the need for relocation and managed coastal retreat.
• Enhancing the evidence base for decision making – for example a national database of flood defence data, including condition assessments, and better forecasting. Using geological data to support decision making was also suggested.
• Building new flood defences. One Local authority respondent considered direct defences as the single most effective measure for reducing flood risk and increasing future resilience of existing properties.
• Addressing various issues in relation to insurance including availability and affordability; a requirement for insurance companies to build back better; and insurance being more vigorously promoted, especially in the rented sector.
• Providing information on flood history or flood risk for individual properties either via the Home Report or a Flood Exposure Certificate for property sales. It was suggested that the latter might make developers more mindful of flood risk.

There were also references to the need for a national approach and central control, and to clear management responsibilities and avoiding duplication of effort. Suggestions included:

• Making one organisation responsible for flood risk and managing drainage networks.
• Creating a Scottish Flood Authority.
• An increased role but different outlook for SEPA.
• Scottish Government monitoring of how local authorities and agencies fulfil their responsibilities.
• Removing local authority responsibility for designing flood protection schemes.

Local authority respondents were amongst those who commented on aspects of legislation or existing processes that they would like to see reviewed or amended, particularly with respect to the Flood Risk Management (Scotland) Act 2009.

Question 22: Do you have any other comments?

Around 90 respondents commented at Question 22. Some respondents used Question 22 to comment on aspects of the consultation process or to expand on answers at earlier questions, while others summarised the position set out at earlier questions.

Points not covered elsewhere in this report included concerns with respect to the condition of much of Scotland’s infrastructure which, it was noted, was engineered based on climatic assumptions that are now out of date. It was suggested that many systems are not fit to cope with the conditions now predicted and that a full infrastructure needs assessment is required to determine the extent of any problems.

Concerns were also expressed with respect to the potential impact of the Strategy on sports facilities. It was noted that Question 12 references using ‘sports pitches to help soak up and store water in the heaviest rainfall events’ while Question 17 mentions ‘floodable sports pitches’. With specific reference to rugby, one respondent highlighted the number of matches that already have to be rescheduled or cancelled when pitches are waterlogged, arguing that if the Strategy exacerbates this problem, the infrastructure of the game and resultant public health benefits from physical activity could be compromised. Suggestions included that the Strategy should remove specific references to sports pitches and add a requirement for the reinstatement of sports facilities that are damaged during any use to mitigate impacts of flooding.

On a similar theme it was argued that that holiday or home parks might be located next to greenspaces used to increase resilience, and that careful management would be necessary to ensure that flood water does not overflow into these parks.

Issues were also flagged up with respect to the horticulture sector, and the importance that funding arrangements – for example to support tree planting – allows the businesses growing the plants to plan and budget. The time needed to ensure availability of plants of suitable size and appropriate species was highlighted, and it was reported that recent funding cuts created the prospect of millions of young trees being destroyed.