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Appendix B: Stakeholder Consultation Workshops

A total of 3 workshops were held in Glasgow, Aberdeen and Dunfermline. The purpose of the workshops was to:

• To inform delegates about the Scottish Government's consultation 'The Future of Flood Management in Scotland', and also the supporting principles and objectives, as laid out in the consultation paper;
• To provide opportunity for delegates to respond to the questions included in the consultation paper;
• To provide forum for open debate and to encourage learning between stakeholders.

The workshops were also used to provide the opportunity to clarify any points of uncertainty concerning the consultation paper. A breakdown of the attendance list has been provided in Table B1.

Table B1 - Attendance List For All Workshops

The structure of the workshops involved two presentations as an introduction and then the delegates were spilt into two discussion groups to encourage open dialogue. Each group were asked the same open ended questions, which dealt with the key 3 themes. The findings were as follows:

The Future of Flood Risk Management in Scotland

Workshop 1 - Statutory Processes
Jurys Inn, Glasgow
26 March 2008

Workshop objectives

• To inform delegates about the Scottish Government's consultation 'The Future of Flood Risk Management in Scotland, and also the supporting principles and objectives, as laid out in the consultation paper;
• To provide opportunity for delegates to respond to the questions included in the consultation paper;
• To provide forum for open debate and to encourage learning between stakeholders.

1. Presentations

• Professor Paul Jowitt ( SISTECH) - Future of Flood Risk Management
• Judith Tracey (Scottish Government) - The Future of Flood Risk Management in Scotland : A consultation

Issues Raised:

• SEPA have been nominated as the competent authority. By definition SEPA are a regulator, therefore this would be a very new role and it is likely they would need to appoint new staff with the relevant expertise.
• Definition of Sustainable Flood Management - what is considered sustainable? The definition of sustainable that we use now may not be the same in the future. There is a need to keep this definition live, as it will change over time.
• Cross boundary issues with England will need to be addressed. The Scottish Government are holding discussions with DEFRA to resolve this issue.

2. Discussion Group - Statutory Processes

Question 1: What do you feel would be the best option for providing deemed planning consent, ministerial confirmation or a local authority based approach?

Question 2: How would this impact on timescales /expertise /resources/ current legislation?

Timescales

CAR licences: There is a need to review how the CAR licences are processed and review the timescales required on this basis. It was envisaged that timescales would remain the same whichever approval process was adopted.

Planning Act : The proposals do not sit well with the new planning act. Under this Act all local authority works need to apply for planning permission. Under the proposals information would need to be provided at an early stage of the process.

Funding mechanism : At present there is no central pot of money available and local authorities receive block grants. The framework will need to ensure that if this funding mechanism were to change that this can be accommodated.

Timelines for planning : Under the current framework, if a local authority has a scheme approved, there is no time limitation on when the scheme must be started or completed. Under the proposals, if deemed consent were to be given, there is a need to decide on how long this permission should last given that standard planning consent lasts for 5 years.

Bureaucracy : Concerns were expressed that bureaucracy might detract from the ability to do 'real' work on the ground.

Expertise

Skill shortage: Concerns were expressed over the lack of technical expertise available to implement the proposed framework. Local authorities have very few hydrologists available and SEPA have little engineering experience. The creation of new local groups may lead to resource issues, especially if attendance is mandatory. Increasing use of consultants may be required.

Monitoring of the proposed framework: It was suggested that there need to appoint some form of commissioner or flooding regulator, with the technical expertise to link all of the processes together and ensure consistency. SEPA's role will be as a facilitator.

Education: Need a drive for hydrologists coming through universities.

Resources

Measurable targets: There should be performance targets set up within the framework to measure what has been achieved. Local authorities need to be answerable and the process needs to be transparent. It was suggested that it should be the Scottish Government's role to set high level objectives. Under the Floods Directive it is a requirement for the Scottish Government to report on progress. Local authorities will be able to feed information through their biennial reports.

Integrated approach: It is proposed that Scottish Water will have a duty to assist in the development of Catchment Flood Risk Management plans. It was suggested that Scottish Water's participation in the process is essential to ensure surface water is kept out of sewers. Further emphasis should also be put on the use of roads for overland flood flow routing.

Public engagement: Public engagement is key and this will need much more effort than the past.

Legislation

Climate change: It was suggested that it should be compulsory for appropriate consideration to be given to climate change. At present the approach generally adopted by local authorities is inconsistent. SEPA add an allowance of 20% for climate change based upon UKCIP research. It is easy to obtain climate change figures nationally, but this information is limited at local level.

Serving Notices: It was raised that there should be some way in which local authorities could serve a notice to ensure a landowner carries out maintenance of a watercourse as currently there is no mechanism to ensure landowners carry this out except through co-operation.

Framework: The framework must be visible, transparent and ensure that it does not appear that planning permission is being obtained through the back door.

Small scale projects: It is difficulty to see how smaller-scale (but more frequently occurring) problems will be able to compete for funding with larger urban areas
(e.g. Glasgow).

Existing legislation: The use of roads as waterways was raised. This may conflict with existing legislation Section 99 R (S) A84.

Water Commissioner: SEPA, as a regulator is seen by some as being historically inflexible and therefore an independent body is required to deal with any complaints.

Other issues

Funding: There is a general need for more funding to support increased responsibilities on local authorities.

Landowners: It was acknowledged that landowners have a key role to play, especially in rural areas. Concerns were expressed that landowners are inhibited by SEPA (as part of SEPA's Water Framework Directive role) from carrying out watercourse management which supports the principles of SFM. However, it was recognised that landowners could not be considered as responsible authorities, but would be included in the development of Flood Risk Management Plans.

It was also raised that local authorities should be given rights to reclaim costs due to landowners not carrying out maintenance.

Availability of data: SEPA flood maps only provide information on fluvial and coastal flooding and there is an issue obtaining sewer flooding data. Local Authorities often have issues obtaining data from Scottish Water on historic sewer flooding events.

Watercourse maintenance: More focus should be put on proactive schemes rather than being reactive to flooding.

Flood Advisory Groups ( FLAGs): FLAGs should be used to bring together political spheres.

Maintenance responsibilities: There is a need to define what comes under maintenance or improvement and what is repair or reconstruction. Need to set out what work can be carried out under the discretion of the local authorities without going through the full application process. Do we repair structures to their original standard, or to the standard which may be required in 50 years time?

Cross boundary cooperation: Whether ministerial or local authority approval is required, there will be a need for cooperation between local authorities. If the decisions are left for ministerial approval this would eliminate any bias towards specific local authority areas.

Definitions: We require better definitions such as 'what is classed as a flood?'

3. Discussion Group - The General Flooding Bill

Sustainable Flood Management

Question 1: Is this a useful delivery tool? Is it clear and simple to understand?

Question 2: Will they help to achieve a more integrated approach?

Definition: It is a declaration of good intentions but may not be easily understandable to the general public. Do we need the asterisks?

Funding: The consensus of opinion was that sustainable flood management was a great aspiration but it need to be supported by the appropriate funding.

Resources: It was envisaged that additional resources would be required to support this.

SPP7: It was envisaged that SPP7 would need to be reviewed as a result of the proposed legislation and that it would more aligned to PPS25 in England.

Options appraisal: There needs to be a balance between benefit/risk e.g. in Hawick the population were willing to accept the risk of flooding, as they did not want to build large walls along the banks of the river (i.e. a personal balance of risk vs. quality of life).

Uncertainty: The problem is that people often expect to be protected for all events. Events should be discussed in terms of probability e.g. 1% chance of flooding in any given year, rather than the 1 in 100 year event (to facilitate understanding). Language is crucial, as SEPA still refer to the 1 in 200 year flood event on their flood maps.

Checklist: A checklist against SFM objectives would be useful.

Resilience: There is not much evidence of resilience among the general public as far as flooding is concerned.

Flood Risk Management Planning

Question 3: Will the proposed framework provide the right balance between local and national planning?

Question 4: Will the proposed framework promote and achieve SFM?

Question 5: Are the roles clear?

(The audience were provided with Box 7 of the Consultation Paper)

Information Exchange: Information will need to be exchanged on a cyclical basis and fed from the bottom up as well as the top down. A strategic overview is required in the national plan, which will set the requirements of the more local plans. Local authorities may have better flooding information than the SEPA flood maps and it is important that this is communicated.

Definition of a catchment: The area of a catchment is very difficult to define. The sensible approach would be that it is based upon the catchment of rivers, otherwise it can be confusing. Problems will arise when more than one local authority share a catchment which is at risk. Roles need to be clearly defined.

Competent authority: SEPA do not have the experience that local authorities have on flood related issues and therefore may not be suitable as the competent authority.

Exchange of information: It is essential that there is a 2 way exchange of information between organisation - top down and bottom up.

Flood Risk Assessment and Mapping

Question 6: What are the key indicators in mapping/assessing risk?

Question 7: How should the competent authority gain the participation of responsible authorities?

Data availability: Historic information is available but how much has the landscape/climate changed? FEH has un-gauged catchments, which makes it difficulty to determine what flows to use. More data is required to make informed decisions on flood risk. SEPA Flood Maps were generally considered not as useful as they could be. The technical complexity of information cannot be underestimated. Maps need to show velocities and depths of flooding as well as extents. There are also many flood risk assessments which have been carried out as part of the planning process but there is no central point to access this information.

LIDAR: The coverage of LIDAR data needs to be improved, as only the Central Belt has a good coverage.

Duty to provide information: It was suggested that SEPA should have the powers to ensure that they receive the information which they require. It was raised that local authorities should have a duty to provide information of a reasonable standard, perhaps to some agreed minimum. However, the local authorities would require funding and resources to achieve an increased quality of data.

SFRAs: Although many local authorities carry out Strategic Flood Risk Assessment ( SFRAs) to inform their local plans already, this could be introduced as a requirement (which would be costly).

Funding: We should not underestimate the potential cost of the work which is required. Concerns were also expressed over how any money would be allocated and what areas would be considered as being a priority.

Consistency of requirements: There needs to be consistency between different local authorities over their planning requirements in relation to flooding.

General Discussion

Reservoirs: The proposals suggest a single enforcement authority for reservoirs. There was a consensus that this would assist in improving the situation. However, information on each reservoir should be held in a location which is easily accessible.

Definitions: More precise definitions are required: e.g. what is the proper definition of a catchment? What is a competent authority? What should SEPA's role be?

Roles and responsibilities: It is essential that roles and responsibilities are clearly defined.

Application of SFM: Up until recently we have taken a very engineered approach to Flood Risk Management. Social and environmental issues must be considered.

4. General Feedback

Roles of organisations: Roles and responsibilities need to be clearly defined.

Mapping: More detailed maps are required to show the extent of all sources of flooding. However, concerns were expressed they this may lead to properties being blighted.

Managed Retreat: Opportunities for managed retreat were discussed, however there are very few sites in Scotland where this would be applicable.

Rural vs. urban requirements: Rural areas have less properties at risk and concerns were raised that funding would be allocated to urban areas at risk.

The Future of Flood Risk Management in Scotland

Workshop 2 - Flood Risk Planning
Pittodrie Stadium, Aberdeen
3 April 2008

Workshop objectives

• To inform delegates about the Scottish Government's consultation 'The Future of Flood Risk Management in Scotland, and also the supporting principles and objectives, as laid out in the consultation paper;
• To provide opportunity for delegates to respond to the questions included in the consultation paper;
• To provide forum for open debate and to encourage learning between stakeholders.

1. Presentations

• David Balmforth ( MWH) - Flood Risk Management
• Debi Garft (Scottish Government) - The Future of Flood Risk Management in Scotland : A consultation

Issues Raised:

• The district and local flood risk management plans will require a 2 way exchange of information.
• how do you get all parties to formally agree the plans and objectives of the plan.
• The need for mid term review of the plans
• Process to mediate conflicts of interest needs to be established.

(Delegates were provided with details of the definition of Sustainable Flood management and information on the proposed District and Local Flood Risk Management Plans in their delegate packs)

2. Discussion Groups

Flood Risk Management Planning

Question 1. Will the proposed framework provide the right balance between local and national planning?

Funding priorities: Different stakeholders will have different priorities over funding. The question was also raised over how the various groups with identified roles would be funded.

Bureaucracy: Concerns were expressed that changes to, and additional, bureaucracy in the approval process may complicate matters. The original consultation document suggested creating Area Plans, these were subsequently removed for the proposals by the Scottish Government to avoid introducing an additional layer of bureaucracy.

Skills shortage: There is a general shortage of expertise available to carry out this work within local authorities.

Rural vs. urban areas: There is a lack of information available in rural areas and there is a fear that Local Flood Risk Management plans will focus on urban areas.

Definition of a catchment: How do you define a catchment? How many catchments/sub catchments will be included? How do these boundaries fit in with the requirements of the Water Framework Directive?

Balance between national and local: It was raised that the existing balance is correct at national level but not at local level. Plans need to be based at a local level, in addition to national, to ensure small local projects can be dealt with efficiently.

Cross boundary cooperation: If there is more than one local authority involved how will the funding contributions be determined?

Question 2. Are the roles and responsibilities clearly defined?

Flexibility of funding mechanism: There needs to be flexibility in the process to allow local authorities to work together to resolve cross boundary issues. The problem is that this will require a cultural change and may raise issues with the public that their local authority is spending money on a scheme which may only benefit people outside their local authority area.

Stakeholder engagement: There will be a duty on local authorities to set up a group to assist with the preparation of a Local Flood Risk Management Plan. These need to be auditable and require clear objectives. The focus of each group will need to be defined.

Knowledge sharing: It is essential that there is a 2 way system for knowledge exchange. There is a need to ensure that any groups share best practice and expertise with others.

Funding: Concerns were expressed how the funding mechanism would work, if more than one local authority was involved with a scheme. Block grants are provided but this can be affected by political decisions.

Flood Prevention (Scotland) Act 1961: Some local authority duties under the 1961 Act local will still be applicable including maintenance and biennial reports.

Question 3. How well will Local Flood Risk Management Plans fit into other existing plans?

Fitting into existing plans: Flood Risk management already fits into development planning, although it is not taken into account in the decision making process. However, it may be more difficult to integrate it into other similar plans. Timing is important.

Developer/political pressure: There is often significant pressure applied by developers to allow development to take place. This needs to be better controlled.

Review of SPP7: There will need to be a review of SPP7 as a result of the Flooding Bill.

Joined up thinking: Needs to be integrated with other planning issues, such as water quality and biodiversity.

Data quality: It is essential that the quality of data needs to be improved. The SEPA flood maps provide a rough initial assessment but for more detailed work need to be improved. Funding and resources require improve the robustness of the maps.

Planning gain: Some developers offer incentives to promote larger schemes. They can provide planning gain whereby developers provide a certain amount of money to management a watercourse or system over a period of time.

Question 4. Should SEPA or Ministers have the ability to reject or modify Local Flood Risk Management Plans?

Review of plans: SEPA should not be reviewing plans if they are helping to produce them. It was suggested that:

There should be a process for call in by Ministers

There should be an independent review of the plans.

Someone must have the ability to reject, but this should not be local authorities due to difficulties resolving cross boundary issues. It was suggested that a Flood Advisory Committee may undertake this role. The issue was raised whether a ministerial approach to approval would be undemocratic and /or lead to a lack of accountability. It would therefore be vital to retain the right to object to proposals on planning grounds.

Question 5. What role should community planning partnerships play?

Roles: Community planning partnerships have a powerful role and may be used to limit the influence of developers.

Communication: The probability of serious flooding occurring somewhere in Scotland is quite high and it is important to communicate that message to the public. SEPA do not communicate information in a proactive way and there are perceived to be many disincentives to communicating this information.

Flood Liaison Appraisal Groups: Existing FLAGS have an important role, as they are area specific liaison groups and involve relevant stakeholders. They allow local authorities to work together on a more strategic level. However, it is difficult to persuade more senior staff to attend these meetings and funding the resources required is an issue.

Funding: No additional funding will be provided to produce LFRMP's. Local authorities are currently provided with block grants. It was suggested that the Scottish Rural Development Funding, could be another source of funding, but has historically been over subscribed. SRDF could also provide a mechanism for supporting co-operation by riparian land owners.

Question 6. Should Local Authorities have a duty to carry out Strategic Flood Risk Assessments?

Value for money: It is important to avoid duplication of effort and ensure best value for money.

Relevance of SFRAs: The question needs to be asked whether anyone would read the document and whether an SFRA could provide anything meaningful. There is often an issue that stakeholders are reluctant to share information, which limits the usefulness of SFRAs. They should not be produced in isolation and require a response plan.

Funding: There is a need to avoid skewing investment based upon population. Some funding should be retained and determined locally, avoiding concentrating on large schemes.

Other objectives: There needs to be a link with other objectives including ecological objectives.

Flood Maps: SEPA have maps available, but they are very high level and developers still have to carry out specific flood Risk Assessments. They are aimed at planners. Local authorities often have more detailed flooding information, but sometimes do not interact and exchange this information.

Roles: Local authorities may stop their assessment at their own boundary so they fill their statutory obligations to SEPA, but this would prevent a more strategic view being developed. It was also raised what Scottish Water's role would be in this process and how do you ensure that all sources of flooding are considered?

Statutory Processes

Question 1. What do you feel would be the best option for providing deemed planning consent, ministerial confirmation or a local authority based approach?

Approval: The consensus of opinion was that there was no need for ministerial approval and it would be beneficial to streamline the process. It was considered appropriate that FRM proposals should go through the planning process like any other application. It was considered important to retain the appeal process. If ministerial approval is removed, it is unlikely to make the process much quicker, although there is potential for modest improvement.

Required development: Some flood defence measures do not require planning permission as people have the right to protect their own properties.

CAR: It is important that the CAR procedure is considered and built in the process. This may impact on timescales.

Sustainable Flood Management

Question 1. Is this a useful delivery tool?

Delivery tool: It was agreed that this was a useful delivery tool, however there are fundamental issues, including these discussed below.

Building regulations: The proposals may require change in building regulations.

Checklist: It was agreed that the checklist was a good idea to make it simple.

Resilience: This is a 'people' recovery issues, although there is not much evidence of resilience among the general public to date where flooding is concerned.

Question 2. Will they help to achieve a more integrated approach?

Stakeholder participation: It is essential that all relevant stakeholders are involved.

Funding: It was generally agreed that it would be beneficial, but the lack of available funding was raised as a concern.

Flood Risk Assessment and Mapping

Question 1. What are the key indicators in mapping/assessing risk?

Flood maps: The existing flood maps provide a high level filter. However, there is a huge gap in the data available. Limited information is available on groundwater and pluvial flooding. Questions were also raised over the accuracy of the SEPA flood maps.

Definitions: Better definitions are required e.g. what is a watercourse?

Suggested improvements: Too few resources and funding is available to prove the improvements required.

Regulation: The question was raised whether SEPA should have regulatory powers in relation to flooding.

Expertise/Resources: The availability of resources is directly liked to funding, although it is acknowledged that there is a general lack of hydrologists. It was suggested that local authorities develop a joint resourced pool of expertise.

Staged approach: There is a need for a staged approach to the compilation of more reliable maps:

• High Level Assessment
• Detailed Assessment
• Third tier of assessment

(This would be based upon resources and funding).

3. General Discussion

Roles: River Basin Management Planning, provides SEPA with powers to ensure that requirements are met. In relation to the Flooding Bill, there needs to be a similar authority to ensure all parties meet their requirements. A protocol is required to ensure consistency between different groups.

Arbitration: If agreement cannot be reached on the local flood risk management plans then there need to a designated authority to make the final decision and resolve any differences. There should also be a right to appeal. It was also suggested that there needs to be incentive to ensure that if a plan is not implemented, this information is fed back to the Scottish Government.

Prioritisation of resources: It is envisaged that the District Plans will be used to prioritise funding and it will be up to ministers to approve or reject these plans. This will be done to a degree through COSLA.

Funding: A concern was raised over how you align stakeholder funding, as all organisations have different funding mechanisms.

Integration: The key is getting stakeholders to work together, through networking, knowing who the key stakeholders are to share ideas and ensuring a framework is in place to ensure exchange this information.

Maintenance of watercourses: If a local authority are forced to carry out emergency works on a watercourse, there is presently no way to recover costs and obligation on landowners to provide money towards it.

The Future of Flood Risk Management in Scotland

Workshop 3 - Flood Risk Assessment and Mapping
East End Park, Dunfermline
15 April 2008

Workshop Objectives

• To inform delegates about the Scottish Government's consultation 'The Future of Flood Risk Management in Scotland, and also the supporting principles and objectives, as laid out in the consultation paper;
• To provide opportunity for delegates to respond to the questions included in the consultation paper;
• To provide a forum for open debate and to encourage learning between stakeholders.

1. Presentations

• David Balmforth ( MWH) - Future of Flood Risk Management
• David Seaman (Scottish Government) - The Future of Flood Risk Management in Scotland : A consultation

Issues Raised:

SEPA Flood Maps: There are 3 sets of maps available, but only 2 have been verified and contain substantiated data. Local authorities have access to all three: 1 in 100 year, 1 in 200 year and 1 in 100 year flood outlines. The maps were produced for planning purposes and do not show defences. These outlines only show the predicted extent of flooding from coastal and fluvial sources. The existing maps will be the basis for the Preliminary Flood Risk Assessment ( PFRA), but will need to be updated to show all sources of flooding.

SPP7: Scottish Planning Policy 7 will need to be reviewed in light of the Flooding Bill and the planning system strengthened.

UKCIP 2 and UKCIP08: On this basis of the findings of UKCIP2 (Climate change and nature conservation in Britain and Ireland) and UKCIP08 ( UK 21st Century Climate Scenarios) it is anticipated that the long term planning process will become very difficult. What is considered to be the 1 in 200 event year event now may become the 1 in 100 event.

Historic Flood Data: Historic analysis should not just go back 100 years; we need to look at data extending up to 300 years back to look at trends. There were high numbers of flooding instances in the past due to snow melt, which do not occur now.

Property Blighting: There is a general fear that improving the flood maps may lead to properties being blighted. There is a need to engage with the public and explain the content of the maps and to manage the website to ensure information is publicly available.

2. Discussion Groups

Flood Risk Assessment and Mapping

Question 1: What are the key indicators in mapping/assessing risk?

Flood Hazard Map: The PFRA will be used to look at the national situation and then focus on high risk areas, where the consequences of flooding would be greatest. The question was raised, how you would prioritise the impacts: human/social/environmental/financial/ infrastructure? There needs to be clear goals set from the outset to ensure these maps are compiled appropriately.

Hierarchical approach: A hierarchical approach to flood mapping may be: identify areas subject to flooding; identify high risk locations or identify potential consequences should flooding occur.

Climate change: It is essential that future trends are taken in account, avoiding too much reliance on historic data. History is no longer a good indicator of what is happening now.

Presentation of maps: Public perception of maps is important. It is essential that we present them in a way that they can be easily understood and cannot be misinterpreted. We also need to be able to communicate the level of certainty associated with the maps.

Development of maps: At present the flood maps only show areas potentially at risk from fluvial and coastal flooding, this should be updated to include sewer, groundwater and pluvial flooding.

Question 2: How should the competent authority gain the participation of responsible authorities?

Cooperation: There needs to a legal requirement to ensure responsible authorities cooperate with the competent authority. There needs to be a clear mechanism for the competent authority to engage with stakeholders and they must have clearly defined roles. There is a good history of co-operation between key stakeholders in Scotland, the issue is obtaining the required funding and resources.

Funding: Funding and resources are essential to ensure this process works. There is an issue that the money provided to the local authorities is not ring fenced and therefore it is likely political pressure will dictate how this money is allocated and it may used for schools or roads. Flooding is often high on the political agenda when it occurs but is then forgotten about.

In terms of Scottish Water they need to be allocated appropriate funding from the regulator to ensure they under stand the long term implications of flooding on their assets.

Data Compatibility: There is a need to standardise what information should be provided by local authorities. The format of the data gathered needs to be agreed as early as possible with SEPA. Guidelines should be produced setting out the standard of data required. Consistency in the format of data would assist with the task of interpreting the information. The problem will come when collating existing data which will be in different formats. There also is a licensing issue, which restricts data exchange. It is essential that historic, current and future flood risks are all considered in the production of the maps.

Maintenance of maps: The maintenance of any flood maps is crucial. There will be a need to ensure that any new data reaches SEPA on a regular basis.

Case studies: Demonstration sites were seen as being essential, such as the Glasgow Strategic Drainage Plan. Clear timescales will need to be defined.

Communication: It is essential to get the message across that flooding is a natural phenomenon and in some cases needs to happen, the key is how we manage it.

Competent authority: Concerns were raised that SEPA is a regulatory authority and it will require a culture change for them to adopt a more proactive approach.

Question 3: Do you think that integrated urban drainage plans should be included as part of a Local Flood Risk Management Plan?

Integrated Plans: One discussion group agreed it was essential that they are included as part of LFRMPs. However, the other group had the opposite opinion and suggested that they are usually based on a 5 year cycle which is not long enough and are mainly local in terms of area. It was also identified that it was important to consider rural as well as urban plans.

Drainage plans: It is important not to concentrate solely on flood risk, but consider drainage as a whole. Why not let roads flood rather than building larger sewers?

Other sources of flooding: Integrated drainage plans must consider all sources of flooding, including groundwater and sewer flooding.

Standards: More consistent standards are required. At present, drainage in urban areas are designed to accommodate the 1 in 30 year storm, fluvial and coastal defences are constructed to the 1 in 200 year standard and highway drainage is designed to deal with the 1 in 5 year storm.

Scottish Water funding: The Scottish Water funding route should be reviewed, as the current mechanism only allows investment to deal with the 1 in 30 year storm.

Definition: A definition of integrated urban drainage needs to be included in the Act. This should also include a better definition of sewers, watercourses and culverts.

Responsibilities: Landowners responsibilities need to be clearly defined.

Question 4: Should Flood Risk Management Plans inform the way that development plans are prepared?

Development Plans: It should be mandatory for FRMPS to inform the development plans. These would need to be subject to a Strategic Environmental Assessment ( SEA). If planning authorities take a more robust approach to flooding, development will benefit in the long term.

Responsible authorities: May wish to include the Met office and Hydro power providers as responsible authorities.

Timescales: Timescales vary significantly at present. New local plans are developed on a 5 year cycle, but this does not address the longer term. Local plans should respond to FRMP, with FRMPS being the drivers.

Abandonment: Abandonment of certain high risk areas may be a solution.

Modelling/management tools: There is a lack of tools available to assist in the compilation of maps. There is also a significant gap in the data which is available. There would be more trust/confidence in the data if it was held at a central point.

(Delegates were provided with details of the definition of Sustainable Flood management and information on the proposed District and Local Flood Risk Management Plans in their delegate packs)

Flood Risk Planning

Question 1: Will the proposed framework provide the right balance between local and national planning?

Framework: There needs to be a regulatory framework in place to ensure integration and that issues are not addressed in isolation. Nationally a process needs to be in place before any local frameworks are set up. Concerns were expressed that there would be no coherent approach locally and they would end up dealing with trivial issues. Protocols are essential at all levels of the process. Sufficient input is required from the top down as well as from the bottom up. The key to success will be the definition of duties for responsible authorities.

Catchment approach: There needs to be a catchment oversight, which needs to be revised on a cyclical basis.

Funding: Many organisations have different funding streams. Concerns were raised on how these streams would fit together to enable relevant organisations to contribute.

Planning Process: There is a parallel planning process that sits alongside the flood management process, links must be made between these 2 processes.

Conflicting requirements: There will be a need to ensure that local plans and schemes will meet national objectives. SEPA will need to have checks in place to ensure this is the case and have the power to call in local plans.

Question 2: Are the roles and responsibilities clearly defined?

Language: The language used to describe this process was not considered helpful and as a consequence delegates struggled to understand the proposed processes.

Statutory Processes

Question 1: What do you feel would be the best option for providing deemed planning consent, ministerial confirmation or a local authority based approach?

Appeal Process: An appeal process must be set up to ensure that the procedure is democratic.

Preferred option: No conclusion was reached on the preferred option, as there are pros and cons to each.

Sustainable Flood Management

Question 1: Is the framework a useful delivery tool?

Definition: The definition is not clear and members of the public would be unable to understand the complicated language which is used. People who have a non-technical knowledge are the individuals who need to understand it the most. However, it was agreed that it would be difficult to provide an alternative. The reference to the Scottish Government's 4 A's should be omitted and the additional jargon that comes with the definition should be removed.

Case studies: It is important to be able to provide examples of SFM for educational purposes.

Framework: The framework is the basis for SFM, but this will need to be developed before this can be successful.

Question 2: Will they help to achieve a more integrated approach?

Consistency: It may help the current situation and encourage responsible authorities to work together, but it will still not lead to consistency. There need to be a process where politicians can be held to account.

Funding: Appropriate funding is central to its success.

Pilot projects: Demonstration projects are essential in promoting this approach. Successful projects could be used to demonstrate the importance of SFM.

Additional Questions

Question 1: Do you agree that streamlining the CAR and flooding/planning processes can be managed through better guidance?

Guidance: Improved guidance is required, including a map which takes you through the whole process.

Streamlining: Time needs to be invested in reviewing the whole process and identifying opportunities for streamlining the procedure.

Question 2: How can we encourage more participator consultation from flood victims or those at risk?

Drivers: What is the driver for the public to provide information? Many members of some communities have extensive flooding knowledge and there needs to be a mechanism to extract this information. It is essential that communities are aware of risk and are engaged in the process. Public support is important in the promotion of schemes. The problem arises when you have to start managing their expectations.

Raising public awareness: The Pitt Report for England has suggested that the public should be required to apply for planning permission to pave their driveways unless they employ permeable paving. This will raise the public's awareness of flooding issues and be more aware of the consequences of their actions.

Other Issues

Funding: Do SEPA and Scottish Water have the capacity to deal with their proposed new duties? It was suggested that the cost of these proposals would be comparable with the costs of implementing the Water Framework Directive.

Resources: There is a general resource shortage, particularly with a lack of available hydrologists.

Streamlining processes: Needs to link into existing structures such as those used to implement the Water Framework Directive.

Conflict with existing legislation: There may be conflict with existing EU legislation such as the Water Framework Directive and Habitats Directive. Under the Habitats Directive the shape of an estuary (such as the River Forth around Grangemouth) cannot be changed. This may require defences to be built to maintain the shape of the estuary.

Climate change: There needs to be the capacity in drainage networks to deal with the implications of climate change. It should be mandatory to consider this throughout the whole process. UKCIP 08 will provide more realistic figures on climate change than was previously available.

Demonstration projects: Case studies are important, not only to educate but also to allow them to be used to identify issues and determine potential solutions.

Flexibility in level of protection: There needs to be some flexibility in the standard of defences required. Some residents would prefer for these homes to be protected to a lower standard, avoiding high walls and providing minimal impact on the visual appearance of a watercourse.

Urban regeneration: New development on brownfield sites offers the opportunity to improve the existing situation by introducing retrofit solutions to deal with surface water drainage.

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