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3.1 Sustainable Flood Management
Question 1: Do you believe the definition of SFM is helpful and of practical benefit to flood risk management?
There were a total of 106 responses to this question. Table 6 describes the answers to Question 1.
Table 6 - Q1 Summary of responses
Response | No. |
|---|
Yes | 74 |
|---|
No | 31 |
|---|
Unclear answer | 1 |
|---|
No answer | 37 |
|---|
Question 1 asked the respondents whether they believed the definition of Sustainable Flood Management ( SFM) was helpful and of practical benefit. The question was based around the definition prepared by the Flooding Issues Advisory Committee ( FIAC) and described in Chapter 2 of the consultation.
FIAC proposed this definition of sustainable flood management:
"Sustainable flood management provides the maximum possible social and economic resilience* against flooding**, by protecting and working with the environment, in a way which is fair and affordable both now and in the future."
* 'Resilience' means: 'ability to recover quickly and easily'. The Scottish Government uses it to deliver the 'four A's': Awareness + Avoidance + Alleviation + Assistance.
** Flooding means all types of flooding: surface water run-off (pluvial), sewer, river, groundwater, estuarine and coastal.
An overwhelming number of the respondents (74 out of 106) considered the definition helpful, as shown in Figure 4. This analysis was based on interpretation of the responses, as many did not provide straightforward Yes or No answers.
Figure 4 - Respondents opinions on whether the definition of SFM is helpful and of practical benefit

Many considered the definition to be essential and considered this a reasonable attempt. A number of respondents specifically welcomed that it considered all sources of flooding. Although the response to the question was mainly positive, many people did express an opinion that this was conditional on several issues being addressed and considered the definition would require 'fine tuning'. The need for further guidance was raised on numerous occasions and that it would need to be flexible enough to accommodate any new technology which may be developed in the future. Many of the positive responses also raised the need for demonstration sites to allow the indicators to be tested.
Due to the overlap between Questions 1 and 2, more detailed analysis of this question can be found in the next section of the report.
Question 2: Do you think the definition is clear and simple to understand?
There was a total of 73 responses to this question, details of the findings are shown in Table 7.
Table 7 - Q2 Summary of responses
Response | No. |
|---|
Yes | 44 |
|---|
No | 23 |
|---|
Unclear answer | 6 |
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No answer | 70 |
|---|
Question 2 was considered to be a continuation of Question 1, which is reflected in the similarities of the responses. The question asked whether the definition of SFM was clear and simple to understand. Very few provided definitive 'Yes/ No' answers to this question and these results are based upon MWH's interpretation of the comments provided. We were unable to determine whether 6 of the respondents were saying Yes or No to this question, as the messages in their responses were unclear.
The findings of Question 2 reflect the results of Question 1, with the respondents being overwhelmingly positive about the definition (44 out of 73 agreeing it was clear and simple to understand). One respondent suggested that the definition has attracted interest from Europe and praised the Scottish Government for their innovative thinking.
More detailed analysis of the results suggested that many of the organisations were split over whether the definition was clear (Figure 5). Of the 20 local authorities who responded to this question, 14 provided a positive answer (70%), while 40% of statutory organisations felt the definition was not as clear as it could be. The non-governmental organisations who responded to this question also had split opinions, with 11 (65%) providing a positive response and 6 suggesting that they were unsatisfied with the definition.
SEPA suggested that the definition should be reworked to provide a solid foundation for SFM decisions under new legislation. If it cannot be reworked at this stage, they suggested that it should be supported by demonstration projects.
Figure 5 - Respondents views on the clarity and simplicity of the definition

General Issues relating to Sustainable Flood Management
Due to the overlap between Questions 1 and 2, it was considered appropriate to carry out an analysis of the issues raised consistently across both questions. Many of the responses were generally positive, but numerous potential weaknesses were also identified, as shown in Figure 6.
Figure 6 - Issues raised consistently in Questions 1 and 2

A total of 20 people expressed the opinion that more guidance was required on either the meaning of the definition or implementation of SFM. The need for demonstration sites was also cited as an important requirement.
The definition was generally understood by the stakeholders responding to this consultation, but concerns were expressed that it may not be so easily understood by the general public. Some felt it was open to interpretation and with the inclusion of sub definitions and asterisks to explain its meaning, considered it to be clumsy.
The objective of 'avoidance' was also raised. Several respondents considered that the definition did not convey the point strongly enough.
Other concerns which were raised included:
- Clarity on roles and responsibility;
- Interpretation of what is 'fair and affordable';
- The word 'integrated' is missing;
- The definition does not say what SFM is, does not describe processes or does not provide a sense of what has to be done to achieve SFM.
- Does not include for environmental impact, the evaluation of consumption of resources and the CO2 emissions for the construction of measures;
- Two respondents raised concerns over the wording 'maximum possible' which was considered meaningless;
- Two respondents noted that the definition failed to consider habitat enhancement or biodiversity;
- Lack of guidance on design and promotion of flood prevention schemes.
Several respondents provided alternative definitions, namely:
- A non-governmental organisation suggested 'Sustainable flood management is flood management which provides a high level protection against flooding and the results of flooding, while minimising environmental impact';
- A non-governmental organisation suggested 'To meet the objective 'maximum possible social and economic resilience' would add 'community' after 'protecting and working with the environment';
- A private sector organisation suggested ' SFM is an ensemble of actions by all concerned to protect people and the built environment from the consequences of all types of flooding in a way that respects nature and is fair and affordable both now and in the future';
- A statutory consultee suggested ' SFM seeks to safeguard society and the environment through proactive measures, utilizing a risk based approach, ensuring sustainable catchment and infrastructure resilience complies sufficiently against future climate change effects'.
Response from Workshops
The findings of the workshops reflected the results of the written consultation. As described in Appendix B, it was generally accepted that the definition was a reasonable statement of good intentions, but not easily understandable to the public. The importance of case studies and pilot projects was raised on numerous occasions. The attendees also highlighted the importance of this work being supported by appropriate funding.
Issues Raised at Public Meetings
The definition of SFM was not discussed at any of the meetings. However, the issue of incentives for farmers to set aside land to accommodate such schemes was raised, as well as the issue of how the farming community should be better represented in discussions of this type.
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