On 13 August, RTPI Scotland submitted a response to Scottish Government on Flood Resilience Strategy consultation. Read the response below.
Guiding principles
Question 1: Do you support the change from fixing flooding problems to creating flood resilient places?
Yes
This approach aligns with the purpose of NPF4's Policy 22, which seeks to strengthen community resilience to the current and future impacts of climate change. This will require a whole-systems approach in line with the Place Principle, the importance of which should be stated in the Strategy. This new approach will require greater emphasis on adaptive flood risk planning (see 2019 Climate Xchange research) and a clear resourcing strategy -
acknowledging the limited resources of LPAs.
Question 2: How can decision makers ensure that actions taken to improve flood resilience align with the aims of a Just Transition to achieve a fairer, greener future?
Decision makers' (including planners') access to up to date flood data is crucial to ensure a Just Transition. This must include flood disadvantage data to ensure deprived communities have the right ongoing support in place to tackle flood risk and impact. See 2015 Joseph Rowntree Foundation research (England) on this topic, which found that "adopting and responding to the concept of flood disadvantage in flood risk management could support more just responses in the face of climate change, demographic change, and other socio-economic policy". We welcome the paper's recognition of the important role of planners, but stress that they must have access to the right knowledge & skills. In-house expertise in areas such as flood risk are under increasing pressure (and are being lost) due to increasing local authority budgetary constraints. Without this knowledge & skill set, planners will be put on the back foot with respect to taking a proactive approach to planning for flood resilience.
Question 3: Who do you think has a role in Scotland to help us become more flood resilient and help us adapt to the impacts of climate change? (Please rank from 1-12, where 1 is the most important)
a- Individuals
b- Homeowners
c- Businesses
d- Scottish Government
e- Scottish Water
f- Local Authorities
g- Scottish Environment Protection Agency (SEPA)
h- Landowners/Land managers
i- Farmers and crofters
j- Housebuilders/developers
k- Community groups
l- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
All of the above have an equally important (albeit varied) role to play to help Scotland become more flood resilient at different scales and in different contexts. We are concerned that ranking the above in order of importance inappropriately generalises the issue when in fact the importance of each group named above will vary depending on scale, context, and type and extent of flooding (i.e. coastal, pluvial, fluvial).
Main themes
People
Question 4: What support do communities need to become involved/engaged in climate adaptation and flood resilience planning?
It is important to acknowledge that not all communities are the same, not all will be faced with the same type and level of flood risk. They will require different levels of support depending on their unique circumstances - including access to community expertise, time and group dynamics. Proactive engagement with and ongoing support of communities is key but also costly and time-intensive. Any future strategy must state who is responsible for
supporting communities, in what circumstances, and the cost and staff implications of this (including required skill sets). The strategy must also acknowledge existing mechanisms that can support communities to become flood resilient. For example, the development of Local Place Plans and Local Development Plans both represent an important opportunity to support communities in a way that engages and involves them in climate adaptation and
flood resilience planning. However, the ability of communities to prepare LPPs is not even across Scotland.
Question 5: What should local authorities be doing to ensure meaningful community participation when taking decisions about improving flood resilience?
Existing LDP and LPP processes provide opportunities for meaningful community participation and could include flood resilience. It is vital that local authorities use all mechanisms currently available to them and do not duplicate activities unnecessarily. It is also important that local authority departments work collaboratively (not in silos) to make the most efficient use of existing community engagement activities in line with the Place Principle. Understanding also that flood catchments do not always follow council boundaries, cross-boundary collaboration between local authorities will be important when it comes to meaningful community participation. In this regard, there may be a role for Regional Spatial Strategies to support this. To ensure existing community engagement mechanisms are meaningful and impactful, adequate resources must be invested into these processes. Engagement is costly, time intensive, and requires particular skills to facilitate them effectively.
Question 6: What would help communities understand their current and future flood exposure and the range of options available to them to help them become more flood resilient? (Please rank from 1-6, where 1 is most important)
a- Access to flood maps showing current and future flood exposure
b- Access to local flood history
c- Access to information on community 'self help' options
d- Access to flood resilience advice/support
e- Access to information on the range of flood resilience options available for their community
f- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
We believe that all of the above options have the potential to assist communities and have an important role to play. As per our response to question 4, not all communities are the same and they will require a range of different options depending on the type and level of flooding they are exposed to, as well as the level of flood disadvantage they experience.
Question 7: What actions could communities take to improve their flood resilience? Please rank from 1-5, where 1 is the most important
a- Set up a local community flood resilience group
b- Develop a local community flood response plan
c- Share local knowledge of what happens during floods with organisations like SEPA and local authorities
d- Link up with their local climate action group
e- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
As above, all of the above options have the potential to support communities in enhancing their flood resilience. It is impossible to rank these in broad terms as they will largely depend on the unique circumstances of the community, as well as the type and level of flood risk they are exposed to. We cannot assume a one-size-fits-all approach. For example, some communities may benefit from a local community flood resilience response plan. However, the skills and expertise required to create such a plan may prove challenging for some communities, particularly if they are also involved in the preparation of Local Place Plans.
Question 8: What actions could householders/businesses take to improve their flood resilience? (Please rank from 1-7, where 1 is the most important)
a- Learn about flood exposure in their area
b- Invest in property resilience measures, such as installing flood gates, raising electrical wall sockets and using flood resilient building materials
c- Join a community flood action group
d- Sign up to Floodline for flood alerts and warnings
e- Seek advice on flood resilience
f- Make sure they have flood insurance
g- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
As above, we are concerned that ranking in such broad terms is unhelpful and runs the risk of suggesting that a one-size-fits all approach is appropriate. In our view, all of the above actions have the potential to improve householders' and businesses' flood resilience. This would need to be determined by each individual community on a case-by-case basis.
Question 9: What would you do to improve your personal flood resilience? (Please rank by importance)
a- Find out how exposed you are to floods
b- Sign up to Floodline for flood alerts and warnings
c- Have a personal flood plan ready to put into action when flooding is expected
d- Ensure you know what to do if your property was to get flooded
e- Check your flood exposure before buying or renting a property
f- Make sure you have flood insurance
g- Other (please specify)
If you selected 'Other', please specify your answer
No comment
Places
Question 10: How can we ensure that our places are designed to be flood resilient in future?
We agree that a place-based and whole system approach to enhancing flood resilience is required. In this regard, collation and access to relevant nation-wide flood data will be critical to ensure we have a strong evidence base to support decision-makers, communities, and developers (including planners) in adopting the right approaches (including for flood disadvantaged communities). For example, investment in nature-based solutions and
green and blue infrastructure will play an important role in ensuring our places are designed to be flood resilient into the future. These solutions have strong support within NPF4 but will require appropriate resources and skills to be implemented successfully. Increasing resourcing pressures are placing a strain on access to specialised skills within local authorities. This must be addressed if the objectives of NPF4, and any future flood resilience strategy are to be realised.
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?
Strongly agree
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 most helpful? (Please rank from 1-5, where 1 is the most important)
a- Increasing the use of sustainable drainage systems
b- Creating blue and green drainage networks to enhance existing drainage systems
c- 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
d- Creating raingardens in public parks and streets
e- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
We see potential in implementing all of the above actions. The actions which will be most appropriate will vary depending on the scale, context and type of flood risk we are seeking to address. We do not believe it is possible to accurately rank the above in broad terms, as an approach in one context might be completely inappropriate in another.
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 most helpful? (Please rank from 1-7, where 1 is the most important)
a- Using soil, and land management techniques to slow down the flow of water and increase infiltration and water retention.
b- Using river and floodplain management techniques such as re-introducing meanders to rivers to slow flow and enhancing floodplains and wetlands to increase storage.
c- Increasing woodland to help intercept, slow and store water throughout a catchment.
d- Restoring peatlands to absorb, store and release water slowly.
e- Enhancing natural dune systems to maintain a natural barrier that reduces the risk of tidal inundation.
f- Managing saltmarsh and mudflats in estuaries to store water and dissipate wave energy.
g- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
All of the above have the potential to increase our flood resilience. We do not believe it is possible to rank them in broad terms, as their effectiveness will depend on site context and scale. It is important that we develop an in-depth understanding of how each of the above actions has/has not worked and why in order that we can continue to learn from our endeavours and support current and future generations in taking an adaptive flood resilience
planning approach.
Question 14: Should moving communities away from areas with the highest exposure be considered as an option?
Yes
We acknowledge that this is one option that may become necessary and unavoidable in certain severe circumstances. However, this must not be a blanket response and must be approached and considered in partnership with communities. The detail of this approach is also important - having regard to scale of the risk (in the short/medium/long terms), and also having regard to the approaches that are taken - e.g. a gradual approach to relocation
through land use planning, or through more direct means such as through the compulsory acquisition of land. As previously stated, the impact of such actions on communities will vary, and understanding flood disadvantage data will be critical in ensuring a Just Transition is achieved.
Processes
Question 15: How might information, guidance, direction and technical support be provided for communities and flood management organisations?
There are many dissemination and support methods that could be used to support communities. It is important that we understand what is already being undertaken by the Scottish Government and others to ensure that any new initiatives do not add additional and unnecessary layers of complexity that could otherwise hinder our efforts to enhance our flood resilience. Any future flood resilience strategy must include a detailed communication,
action and funding plan that takes stock of the actions we are already doing or that are already underway that have the potential to enhance community flood resilience. For example, the Government's proposal to establish a planning hub has the potential to act as a base for expert flood-related information. Also, community flood resilience has important wellbeing implications that links with the work being undertaken to develop a Wellbeing and
Sustainable Development (Scotland) Bill, including the creation of a Future Generations Commissioner.
Question 16: How can we improve efficiency, consistency and value in delivering flood actions?
As previously mentioned, efficiency, consistency and value in delivering flood actions can only be achieved by taking a place-based and whole systems approach in line with the Place Principle. Collaboration, clarity and transparency are key to ensure that communities, developers and decision makers have access to the right data, evidence, knowledge and skills to deliver the right flood resilience actions in the right areas at the right times. An agile and adaptive approach will be necessary to deliver a proactive flood resilience response that caters to future generations. A clear evidence-based and data-driven action, funding and communications strategy will be necessary to create a clear pathway for all those involved in and responsible for delivering Scotland's Flood Resilience Strategy.
Question 17: Other than large flood protection schemes, what flood resilience actions should we focus on supporting/spending available funding on? (Please rank from 1-9, where 1 is the most important)
a- Maintaining existing flood protection
b- Small flood protection schemes
c- Natural flood management
d- Blue and green infrastructure (e.g. multi-purpose green space, such as floodable sports pitches)
e- Flood forecasting and warning
f- Property level flood resilience measures
g- Supporting local community flood resilience groups
h-Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
Enhancing Scotland's flood resilience at the national level will require wide ranging and varied responses across multiple scales and having regard to the unique needs of individual communities, including their level of flood disadvantage. We do not believe it is possible to rank the above actions in broad terms, as each one has the potential to deliver benefits depending on the scale and context. Also, many of these actions will need to be used in
combination (rather than in isolation) to have the intended impact.
Question 18: Do you think there is enough evidence and information to support the delivery of a broader range of flood resilience actions?
No comment
Question 19: What other funding sources or mechanisms could be used to support flood resilience? (Please rank from 1-4, where 1 is the most important)
a- Financial contributions from those who directly benefit from improved flood resilience (e.g. private sector/businesses)
b- All new development makes a contribution
c- Support natural flood management through payments to farmers, crofters and land managers (for example, Forestry Grant Scheme, the future agricultural support framework or Peatland ACTION payments)
d- Other (please specify)
1- Other
If you selected 'Other', please specify your answer:
We do not believe it is appropriate to rank the above actions in broad terms. Each has potential to support flood resilience. We take this opportunity to highlight the links between this consultation and the Infrastructure Levy consultation - which is open until the end of September. As we move away from a reactive "fixing problems" approach towards a proactive "flood resilience" approach, it is important that flood resilience actions are seen as
"infrastructure" in the same manner as physical flood defences.
Question 20: What is your main concern about flooding?
As the principal professional institute for planners in the UK, the RTPI's main concern about flooding is to ensure that our members, and the planning and built environment profession generally, have access to the necessary tools and skills to support a flood resilient Scotland. As previously mentioned, this will require a clear action, funding and communication strategy to accompany any future flood resilience strategy, as well as consistent flood data at the national level (including flood disadvantage data) to assist planners in carrying out their duties within existing budgetary constraints.
Question 21: What one thing would do the most to improve Scotland's flood resilience?
Improving Scotland’s flood resilience will require a whole-systems approach and the collective action of national and local government, organisations, businesses, communities and households. There is therefore no one action that can be identified to achieve improved flood resilience. Rather, a collective series of actions that support an adaptive flood risk planning approach will be crucial to support both current and future generations in enhancing their resilience to flooding.
Question 22: Do you have any other comments?
Enhancing our flood resilience will require a whole-systems and place based approach. Flood resilience does not sit neatly in its own box, but branches into other climate action areas - including, for example, biodiversity enhancement. It also has potential strong links with other existing Government proposals, including the Wellbeing and Sustainable Development (Scotland) Bill, and the introduction of an Infrastructure Levy. In the latter regard, it is
vital that as we move from a "fixing flood problems" to a "creating flood resilient places" approach, that we continue to see flood resilience actions as a form of "infrastructure". For example, design measures to accommodate water within communities should be seen as just as vital infrastructure as physical flood defences used to keep water out, as should the soft infrastructure required to maintain, monitor and adapt so that we can continue to
enhance our flood resilience into the future.
