PVA Consultation Outcome Report 2018
Flood Risk Management in Scotland: 2018Consultation on Potentially Vulnerable AreasConsultation outcome report
ContentsExecutive summary1Introduction . 62Analysis of responses . 9Climate change and flooding. 9National Flood Risk Assessment method . 12Proposed Potentially Vulnerable Areas 2018 . 15Local Plan Districts . 19Future Consultation Arrangements . 213Other national themes . 234Conclusion and next steps . 26Annex 1: List of respondentsAnnex 2: Map of Local Plan DistrictsAnnex 3: Map of Potentially Vulnerable Areas2
Executive summaryFlood risk management planning is a matter of both national and local importance. Our aimis to ensure that national efforts of Responsible Authorities are targeted to areas of greatestrisk, and that these areas are informed by as much local knowledge of flooding as ispossible.To help direct efforts to reduce flood risk, the Scottish Environment Protection Agency(SEPA) identifies local catchments where significant risk exists now or is likely to occur inthe future. These are Potentially Vulnerable Areas which require the production of flood riskmanagement plans coordinating the activity of Responsible Authorities in reducing floodrisk. Scottish Ministers formally designate Potentially Vulnerable Areas, based on theadvice of SEPA and its consultation with partners and the public.Potentially Vulnerable Areas are derived from the National Flood Risk Assessment, which isupdated and published every six years. The National Flood Risk Assessment takes intoaccount past, current and future flood risk, using recorded events, observations andcomputer modelling. It considers flooding from rivers, the sea and from surface water.Embedding climate change knowledge in flood risk management planning will ensure thatour efforts help communities, infrastructure and way of life to adapt to climate change.Potentially Vulnerable Areas are a vital part of helping us to understand and prioritisewhere coordinated and planned efforts could be of most benefit.Since 2011, when Potentially Vulnerable Areas were first identified, SEPA and our partnershave been working hard to improve data and methods of flood risk assessment. As a result,we now have new information. This has resulted in changes to the Potentially VulnerableAreas. Although it is a science and evidence-led process, feedback is important to sensecheck our understanding, as there may be local impacts of which we are unaware. NewPotentially Vulnerable Areas have been added since 2011 due to an improvedunderstanding of risk, or because of future risk due to climate change, or land use change.Some local catchments have been proposed for de-designation where our more recent datashows less risk than the 2011 National Flood Risk Assessment. There have been boundaryadjustments to some Potentially Vulnerable Areas to better represent the distribution of riskwithin them. Many Potentially Vulnerable Areas remain unchanged but our understandingof the risk within them all has improved.We consulted on the Potentially Vulnerable Areas from 1 May 2018 for a three month periodto make sure we have got it right. This provided an opportunity for members of the publicand our partners to provide us with feedback on the proposed changes.As a consequence of the consultation, we have amended and added new PotentiallyVulnerable Areas. The broad support we had for the Local Plan Districts, the National FloodRisk Assessment and the consultation arrangements up until 2021, means that we and ourpartners can proceed with confidence to the next stages of flood risk managementplanning.3
PurposeThis document provides an analysis of the responses received to the Flood Risk Management inScotland – 2018 Consultation on Potentially Vulnerable Areas. It summarises the views wereceived and explains the actions we are taking in response. In addition to informing our view onPotentially Vulnerable Areas for 2021-2027, the consultation was also an important opportunity togather views on the retention of the Local Plan Districts and future consultation arrangements forflood risk management. This document also describes how we carried out the consultation andwho we consulted with.Summary of responsesIn total we received 263 responses: 256 online responses and seven separate written responses.We are grateful to individuals and organisations for considering the proposals and providingfeedback. Responses varied from detailed comments on Potentially Vulnerable Areas to othersthat were brief and focused on a single theme.Compared to the first consultation on Potentially Vulnerable Areas in 2011, there has been awelcome 417% increase in the number of responses. This is likely to reflect the increasedawareness the public has of flood risk management planning in Scotland as well as thestrengthened partnership working between SEPA and Responsible Authorities achieved inpreparation of Scotland’s first Flood Risk Management Strategies in 2015.We received general agreement from respondents on our proposals for new Potentially VulnerableAreas. Only 13% of respondents challenged areas we are proposing for designation. Similarly,only 14% of respondents requested additional locations to be identified as Potentially VulnerableAreas. Respondents who disagreed with our proposals generally felt that the proposed PotentiallyVulnerable Areas were too broad and included areas not at flood risk. Respondents also providedsuggestions for new areas that they felt should be included. Their justification for including theseareas often reflected past experiences with flooding and requests were sometimes accompaniedby comments asking for more action by authorities to manage flood risk.We received a good level of support for the National Flood Risk Assessment, the retention of the14 Local Plan Districts, and for the planned consultation arrangements for the period 2018-2021.We also received comments on a wide range of issues that, although not directly relevant to theNational Flood Risk Assessment or Potentially Vulnerable Areas, clearly illustrate areas of generalconcern for how flood risk is managed in Scotland. This included concerns around the use ofdredging and maintenance of watercourses to manage flood risk, building on the floodplain andinsurance companies using SEPA flood maps to influence premiums. These issues are alsosummarised in this report.4
What SEPA has done in response to the consultation?In taking account of the views received SEPA is proposing to amend one of the PotentiallyVulnerable Areas that we consulted on and identified two additional Potentially Vulnerable Areas.The new areas identified are Kirkmichael (South Ayrshire Council) and Beauly (Highlands Council)while the Potentially Vulnerable Area being amended is North Uist to include Baleshare (Comhairlenan Eilean Siar). SEPA has already undertaken a number of actions based on information andresponses provided during the consultation, such as discussing these with relevant localauthorities. We will continue to engage with our stakeholders and ensure working together iscentral to improving flood risk management in Scotland. Information provided on local flooding andother issues will be discussed with local authorities as appropriate. No changes have been madeto the Local Plan District proposals or the Statement on Consultation Arrangements as a result offeedback received.What will happen next?This consultation exercise has been an important part of the process for identifying PotentiallyVulnerable Areas. A revised set of Potentially Vulnerable Areas, amended as appropriate using theviews expressed during the consultation, will now be submitted to Scottish Ministers for approval.Following this a final set of Potentially Vulnerable Areas will be published by SEPA in December2018, alongside the updated National Flood Risk Assessment. The Flood Risk Management(Scotland) Act 2009 requires that for each Potentially Vulnerable Area identified: We will produce flood hazard and flood risk maps for the area. In fact, SEPA producesmaps with full national coverage, which are part of a rolling update programme; We, in consultation with our partners, will set objectives and identify actions to addressflood risk. These will be published in SEPA’s Flood Risk Management Strategies for theperiod 2022-2027; Local Flood Risk Management Plans will be produced by lead local authorities; and, Scottish Water will undertake an assessment of the risk of flooding from the seweragesystem.SEPA will continually engage with our stakeholders to help deliver successful flood riskmanagement for Scotland. The National Flood Risk Assessment will now inform future Flood RiskManagement Strategies which will be published in December 2021.Potentially Vulnerable Areas will be published on SEPA’s website by 22 December 2018.The Statement of consultation arrangements will be published on SEPA’s website by 22 December2018.5
Chapter 1: IntroductionBackgroundThe Flood Risk Management in Scotland: 2018 Consultation on Potentially Vulnerable Areasopened on 1 May 2018 for three months. This document provides a summary of the consultationexercise, views expressed by respondents and the action taken by SEPA in response to thoseviews.The consultation process forms part of the work to review and update the 2011 National Flood RiskAssessment, as required by the Flood Risk Management (Scotland) Act 2009. Our understandingof flood risk is constantly improving and periodic reviews and updates are essential to ensure wecan effectively support flood risk management in Scotland.Effective partnership working and engagement is central to how we deliver flood risk management.This consultation on Potentially Vulnerable Areas is an example of how we can achieve successfulpartnership working by incorporating local knowledge and information into the identification ofareas most at risk.Summary of actions taken by SEPA to publish and consult on thePotentially Vulnerable AreasTo promote the launch of the consultation, we published adverts in a number of publications bothin print and online including the Edinburgh Gazette, Daily Record, and The Metro. A digitalcampaign using social media and website platforms was also developed as well as a radiocampaign broadcasting throughout Scotland. We provided all local authority flooding teams withbriefing packs with access to draft article templates and social media messages which they coulduse to promote the consultation within their organisation and local area.We also wrote letters to Scottish Water, Scottish Natural Heritage, the Environment Agency,Cumbria County Council, Northumberland County Council, all Category 1 and 2 Respondersi,(Scottish) Members of Parliament and Members of the Scottish Parliament.Our Flooding Communications team circulated details of the consultation in a number of SEPApublications including our bi-annual Development and Delivery newsletter, Flooding Gatewaynewsletter and our quarterly Local Plan District Partnership e-bulletin.We promoted the consultation to our other partners through the National Flood ManagementiCategory1 and 2 Responders are defined as part of the Civil Contingencies Act 2004 which seeks tominimise disruption in the event of an emergency. Category 1 Responders are ‘core’ responders: localauthorities, police, fire and rescue services, ambulance service, NHS health boards, SEPA and the Maritimeand Coastguard Agency. Category 2 Responders are key co-operating responders in support of Category 1Responders. These include gas and electricity companies, rail and air transport operators, harbourauthorities, telecommunications providers, Scottish Water, the Health and Safety Executive and NHSNational Services Scotland.6
Group, Cross Border Advisory Group, Lead Local Authority Forum, Flood Risk Management LocalAdvisory Groups and Local Plan District Partnerships.Whilst it is SEPA’s statutory duty to prepare the National Flood Risk Assessment and identifyPotentially Vulnerable Areas, local authorities and others have important duties to manage floodrisk within them. To ensure the outputs of the assessment were a fair reflection of flood risk withintheir areas we invited all 32 local authorities and other Responsible Authorities to attend one-toone workshops prior to the consultation.Summary of consultation questionsThemeClimate change and floodingNational Flood RiskAssessment methodologyIdentification of PotentiallyVulnerable AreasLocal Plan DistrictsConsultation ArrangementsConsultation questionOur future Flood Risk Management Strategies must takeaccount of climate change. Do you think that flooding is oneof the major climate change challenges Scotland will face inthe future?Do you support or have any comments on the 2018 NationalFlood Risk Assessment?Are there areas that have been identified as PotentiallyVulnerable Areas that shouldn’t be?Are there areas that have not been identified as PotentiallyVulnerable Areas that should be?Local Plan Districts were consulted upon and agreed in 2011.With minor adjustments, we intend to retain the 14 Local PlanDistricts. Do you support the retention of the 14 Local PlanDistricts?Do you agree with the consultation arrangements outlined tosupport the delivery of flood risk management planning inScotland? Please provide suggestions of alternative oradditional arrangements that you would like to seeundertaken.Consultation responses and respondentsWe would like to thank all organisations and individuals that participated in the consultationprocessii. While the majority of responses followed the format of the online questionnaire, somerespondents submitted non-standard responses (such as emails or stand-alone documents).Although not all of these addressed the consultation questions directly, wherever possible themeswere identified and these have been included in the analysis.Some respondents also provided additional information in the form of photographs, images andlinks to other studies. We have considered these alongside the relevant comments.We received a total of 263 responses to the consultation. To aid analysis of responses,iiUnlessspecified, when referring to ‘responses’ and ‘respondents’, we mean both organisational andindividual responses and respondents.7
respondents were grouped into categories. Figure 1 shows the breakdown of respondents by eachcategory. These included 24 responses from Responsible Authorities, 10 from other public bodiesor non-governmental organisations, 4 from consultancies and academia, 9 from business and 197from individual members of the public or community groups. Nine respondents did not answer thequestion on respondent category and 10 chose the ‘other’ option. A full list of organisations thatresponded to the consultation is provided in Annex 1.Figure 1. Respondent categoriesChapter 2 on the analysis of the responses covers the key topic areas of the consultation: Climate change and flooding National Flood Risk Assessment method Proposed Potentially Vulnerable Areas Local Plan Districts Flood Risk Management consultation arrangements8
Chapter 2: Analysis of responsesThis section of the consultation report looks at the responses to the specific questions asked.Common additional themes identified are summarised in Chapter 3: Other national themes.Climate change and floodingConsultation question:Our future Flood Risk Management Strategies must take account of climate change. Do youthink that flooding is one of the major climate change challenges Scotland will face in thefuture?OverviewThere were 214 respondents (81%) who agreed that flooding is one of the major challengesScotland will face in the future and 21 respondents who disagreed. Nineteen respondents did notexpress an opinion while two did not answer the question.Of the 21 respondents who did not think that flooding was one of the major climate changechallenges Scotland will face in the future, the majority were members of the public or from acommunity interest group. Figure 2 summarises the responses received.Figure 2. Answers to question on climate change and floodingWhat you said and our responseThis section explains the main themes that have been raised through this question and SEPA’sresponse.Theme 1: Flooding is a major climate change challengeSummary of responsesMost respondents acknowledged that climate change would lead to more extreme weather events,increased rainfall and rising sea levels. Some respondents commented on the effect of warmertemperatures on snowmelt and the risk of flash flooding. Other respondents remarked on a trend ofmore frequent intense rainfall events during the summer months, increasing the risk of river and9
surface water flooding. Some responses remarked on the impacts of increased flood risk in relationto the environment, historic environment and infrastructure.Public bodies that responded to this question recognised that increased flood risk because ofclimate change presents a challenge for their organisations. Comments were received about theneed to be better prepared for example, by using property-level resilience measures or developingadaptation plans.Scottish Natural Heritage discussed climate change adaptation as a key component of theircorporate plan and provided a link to their publication Climate Change and Nature in Scotlandiii,while the Loch Lomond and The Trossachs National Park Authority discussed how climate changeand flooding is included in their National Park Partnership Plan.A few respondents believed that there was a lack of consensus on climate change trends inScotland. In particular, a few responses highlighted the potential for increased periods of drierweather as well as wetter weather.SEPA responseKey long-term climate change trends for Scotland indicate that the weather may become morevariable. Typical summers are anticipated to be warmer and drier and typical winter/autumnperiods milder and wetter. Sea levels are also expected to continue to rise. We can expect to seeincreased frequency and intensity of extreme precipitation events, an increase in summerheatwaves, extreme temperatures and drought and a reduced occurrence of frost and snowfall.The 2018 National Flood Risk Assessment considers the flooding impact associated with climatechange using scenarios based on the UK Climate Projections 2009 (UKCP09) analysis. SEPArecognises that the impacts of climate change will depend on regional variation as well as the localcharacteristics of an area.The next major update to UK climate change understanding will be UK Climate Projections 2018(UKCP18) which are expected to be published in November 2018. When the updated climatechange projections are made available, SEPA will begin work to take them into account in ourflood hazard mapping which will help to inform future flood risk management activities.Understanding the impacts of climate change on flood risk will help us to inform sustainable floodrisk management plans to manage both current and future flood risk.Theme 2: Not just climate change which increases flood riskSummary of responsesMany respondents believed that climate change was only one of a combination of factorsincreasing flood risk in Scotland and we received many comments on other trends that contributeto flood risk.Many respondents were concerned about the potential for flooding to be exacerbated bydevelopment on the floodplain.Other concerns included: field drains being used to remove water from agricultural land nature-scotland10
watercourses, poor clearance and maintenance of watercourses and drainage systems and anincrease in impermeable hard surfaces.SEPA responseSEPA acknowledges that a variety of factors is likely to exacerbate the impact of flooding in thefuture. In addition to climate change this includes demographic change, changes in land use andother societal changes.SEPA is a key agency in the land use planning process in Scotland and works to ensure it deliverssustainable flood risk management. This includes ensuring inappropriate development is avoidedin areas at medium to high flood risk. Furthermore, we are in the process of developing a FloodingStrategy that describes these wider influences on flood risk management and how Scotland canadapt to a future with higher sea levels and where rainfall is likely to be more intense and frequent.11
National Flood Risk Assessment methodConsultation question:Do you support or have any comments on the 2018 National Flood Risk Assessment method?OverviewThere were 153 respondents (58%) who expressed support for the National Flood RiskAssessment method. Twenty-seven respondents did not support the method, while 71 did notexpress an opinion and five did not answer the question. Figure 3 summaries the responsesreceived.Figure 3. Answers to question on the National Flood Risk Assessment methodWhat you said and our responseThis section explains the main themes that have been raised through this question and SEPA’sresponse.Theme 1: Support for the assessmentSummary of responsesThere was strong support for the National Flood Risk Assessment method. This included supportfor the assessment taking account of: more influencing factors which can be locally significant,especially in rural communities; inclusion of community scale impacts; inclusion of climate changeimpacts and the improved representation of building footprints. There was also anacknowledgement from respondents that this has been a collaborative process which has allowedthe national perspective to be translated to a local level.SEPA responseSEPA welcomes the support for the National Flood Risk Assessment method. Our understandingof flood risk is constantly developing and it is not a static field of work. A periodic review isessential to ensure we effectively support flood risk management in Scotland. The Flood RiskManagement (Scotland) Act 2009 requires SEPA to review and update the assessment every sixyears. The National Flood Risk Assessment will also be updated for the preparation of Flood RiskManagement Strategies to be published in 2021.12
Theme 2: Reasons for not supportingSummary of responsesRespondents who did not support the National Flood Risk Assessment method gave the followingreasons: Concerns that flooding issues outwith Potentially Vulnerable Areas would not beaddressed; Concerns that the assessment does not incorporate a consideration of potentialdevelopment sites; Concerns that flood protection schemes have not been considered; Concerns that there has been insufficient consideration of local knowledge; Concerns that the assessment focus is on larger urban settlements and misses smallerrural communities; and Concerns that the scale of the assessment has meant areas that have not flooded areincluded in Potentially Vulnerable Areas.SEPA responseConcerns regarding flooding outwith a Potentially Vulnerable AreaPotentially Vulnerable Areas identify areas of nationally significant flood risk. There will always beareas outside Potentially Vulnerable Areas that still flood and need action. Over 90% of homes andbusinesses at risk in Scotland are within Potentially Vulnerable Areas and Responsible Authoritiesare aware that flood risk management is not limited to these areas. However, locations outside ofPotentially Vulnerable Areas generally do not require the coordinated multi-agency response oftenneeded to manage flooding within Potentially Vulnerable Areas.Does not consider potential development sitesThe 2018 National Flood Risk Assessment does not deal with planned development sites asdetailed in Local Development Plans. SEPA will respond to site-specific Flood Risk Assessmentson a case-by-case basis to prevent development which would have a significant probability ofbeing affected by flooding or would increase the probability of flooding elsewhere. SEPA will usethe outputs of the 2018 National Flood Risk Assessment as additional information whenresponding to all Local Development Plans and individual planning applications.Consideration of flood protection schemesOur current flood hazard maps represent an undefended scenario except in areas where a moredetailed study has been incorporated which includes consideration of a flood protection scheme.This means that the majority of formal flood protection schemes have been taken into accountwithin the National Flood Risk Assessment based on current understanding of their effectiveness.Lack of local knowledgeDuring the process to identify Potentially Vulnerable Areas, we held workshops with localauthorities in Scotland and took proposals to local advisory groups. These workshops were anopportunity for local authority flood officers and others to contribute local knowledge to inform ourdecision-making process. The consultation provided an opportunity for other organisations andmembers of the public to comment on how our proposals could be improved. As a consequence,we feel the balance is right between taking forward a strategic national assessment and takingaccount of local issues.13
Inclusion of small rural settlementsThe 2018 National Flood Risk Assessment method has been amended since 2011 to moreexplicitly consider and represent remote and rural communities.A wider range of community facilities were considered, representing the many services andactivities which come together to allow a community to prosper. These included libraries, courts,job centres and other civic services. A community scale element has been incorporated in theassessment alongside the risk to community facilities to identify locations where the functionality ofa community is compromised by the proportion of properties at risk.Scale of assessmentPotentially Vulnerable Areas are local catchments within which there is significant flood risk. Thisdoes not mean that everywhere in a Potentially Vulnerable Area is at risk of flooding.14
Proposed Potentially Vulnerable Areas 2018We asked two questions about identifying Potentially Vulnerable Areas. The first question invitedrespondents to tell us where they disagreed with our proposed identification of a PotentiallyVulnerable Area. The second question asked respondents to identify other areas that they thoughtshould be Potentially Vulnerable Areas.We also gave respondents the option to comment in detail on a particular Potentially VulnerableArea. Up to 10 specific areas could be commented on via the online consultation questionnaire. Ifa respondent wanted to comment on more than 10 then they were requested to contact SEPA.These comments were reviewed to determine whether the respondent supported the proposal to(de-) designate the Potentially Vulnerable Area.OverviewConsultation question:Are there areas that have been identified as Potentially Vulnerable Areas that should not be?There were 72 responses to this question. Thirty-four respondents (13%) identified areas that theyconsidered should not be a Potentially Vulnerable Area. The rest of the respondents either did notchallenge our proposed Potentially Vulnerable Areas or did not express an opinion.Some respondents to this question identified areas they believed should be identified aspotentially vulnerable. These responses were analysed under the next question. Figure 4 providesa summary of the responses received in relation to areas that have been identified as potentiallyvulnerable that should not be.Figure 4. Answer to question on areas which should not be a Potentially Vulnerable AreaWhat you said and our responseThis section explains the main themes that have been raised through this question and SEPA’sresponse.Only 13% of respondents challenged the proposed identification of Potentially Vulnerable Areas.These responses fall into two main themes which are discussed below. The rationale provided inthe responses that challenged identification of Potentially Vulnerable Areas tended to question the15
likely extent of flooding in the proposed area or was of the view that the scale of the area was toolarge and not sufficiently locally-detailed. No objections were received from ResponsibleAuthorities.Theme 1: Elevated areas within Potentially Vulnerable AreasSummary of responsesA number of respondents pointed out that elevated areas (for example, hills) have been includedwithin the Potentially Vulnerable Area even though these areas are not at risk of flooding.SEPA responsePotentially Vulnerable Areas are local catchments where flooding is considered to be nationallysignificant and are identified to help prioritise where further investment or coordinated actionbetween authorities is needed to reduce flood risk. These areas are based on local catchments asit is within the context of the wider catchment that flooding can be best understood and managed.Within these catchment units there will be some areas that are not at flood risk, including areas ofelevated topography.Theme 2: Scale of Potentially Vulnerable AreasSummary of responsesWe received a number of comments on the scale of Potentially Vulnerable Areas. Manyresp
Assessment, as required by the Flood Risk Management (Scotland) Act 2009. Our understanding of flood risk is constantly improving and periodic reviews and updates are essential to ensure we can effectively support flood risk management in Scotland. Effective partnership working and engagement is central to how we deliver flood risk management.
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Country: Viet Nam Initiation Plan Project Title: For preparation and implementation of Project on Leveraging Viet Nam's Social Impact Business Ecosystem in Response to COVID-19 (ISEE-COVID) Expected UNDAF/CP Outcome(s): Outcome 1.1; Outcome 2.1; Outcome 4.1 Expected CPD Output(s): Outcome 1; Outcome 2; Outcome 3 Initiation Plan Start/End Dates: 20 May 2021 - 20 August 2021 (3 months)
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Consultation paper overview & next steps EIOPA carries out this consultation in accordance with Article 29(2) of Regulation (EU) No 1094/2010. This Consultation Paper presents the Supervisory Statement on ORSA in the context of COVID-19. EIOPA will consider the feedback received, 3 develop Impact assessment and publish a Final Report on the consultation and submit the Supervisory Statement for .
The results of the consultation activities will be summarised in a synopsis report annexed to the impact assessment and published on the consultation page. 5. Summary /overview on consultation activities by stakeholder groups and indicative timing The following table summarises the envisaged consultation activities, their stakeholder coverage and
