Response to SEPA’s Flood Risk Management (Scotland) Act 2009 consultation: ‘Planning for floods – planning for the future’
We welcome SEPA’s ‘Planning for floods – planning for the future’ consultation and appreciate the considerable effort that SEPA has invested in considering the best options for flood risk management planning. However, we feel that some of SEPA’s proposals, particularly those in relation to the set up of local plan areas, will fall short of achieving sustainable flood management that is integrated with wider catchment issues, such as those relating to water quality, land use, biodiversity and climate change adaptation. In addition, we are concerned that the proposals will impede stakeholder engagement which could in turn result in poor implementation of the Flood Risk Management (Scotland) Act 2009.
We urge that SEPA gives further consideration to the alternatives that would reduce the number of local plan areas and that would better align the areas with existing structures, such as the River Basin Management Planning Area Advisory Groups. This will be essential to achieve not only sustainable flood management but other objectives that will deliver multiple benefits at a catchment scale.