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Appendix 4 Assessment of the proposals

Assessment of the SFM Definition

The initial assessment is aimed at considering the environmental effects of the SFM definition in relation to the SEA objectives and sub-objectives defined previously.

The general approach taken throughout the assessment has been to consider the strategic effect of developing the SFM proposals - however the overall, national-level effects will be the accumulation of benefits offered by a range of regional/local implementations of sustainable flood management. Clearly the precise environmental effects offered by an SFM implementation for a particular flooding issue or area will be a result of the individual factors and environmental issues particular to that area and flood risk type and scale.

SEA Objectives

Commentary on the progression of the SFM Definition

Biodiversity, flora and fauna

To maintain and enhance biodiversity with no net loss of species

The definition explicitly includes "…protecting and working with the environment". This clearly includes conservation of ecosystems and biodiversity as detailed in SEA sub-objectives 1.1 and 1.2. Similarly, implicit in the definition is the avoidance of damage to designated and non-designated sites as in sub-objective 1.3.

However there no reference within the definition of the opportunities for enhancement and improvement of habitats and, hence, biodiversity offered by implementing SFM. SFM offers considerable opportunities for restoring or creating habitats - such as the creation of wetlands for flood attenuation or as part of the restoration of flood plains.

Population and human health

To protect and enhance human health and well-being

Sub-objective 2.1 is covered by the inclusion of the "awareness" and "avoidance" aspects of the resilience aspect of the definition. Similarly 2.2 is covered by the general inclusion of resilience in the definition. "Education" in 2.3 is explicitly covered by the delivery of "awareness".

2.4 mentions "viability" and "vitality" - while the inclusion of "…a way which is … affordable" clearly addresses economic viability. The concept of vitality in communities is not addressed.

2.5 addresses health equalities and is covered to some extent by the definition including"…in a way which is fair…" suggesting that inequalities should be minimised wherever possible.

2.6 discusses the encouragement of healthier lifestyles - there is no explicit mention of this, and there is no mention of the unique opportunities for recreational/amenity land opportunities offered by SFM (although this is covered to some extent elsewhere in the proposals, as discussed later).

Soil

To protect soil quality

Safeguarding soil "quality, quantity and function" as included in 3.1 is not explicitly included in the definition however it is covered by the general approach to "…protecting and working with the environment..."

Similarly objective 3.2 on soil erosion is covered by this same section in the definition.

Water

To protect and enhance the quality of the water environment

Objective 4.1 is covered by the reference in the definition to "…protecting … the environment". Similarly objective 4.2 is covered in the same way. Objective 4.3 refers to "maintain and restore" which is covered to some extent by the definition - however there is no explicit emphasis in the definition for optimising the opportunities for restoration offered by SFM. Objective 4.4 - "protect" is covered in the definition, however "enhance" is not explicitly included. Objective 4.5 - reducing and managing flood risks is well covered in the definition.

Climatic factors

To reduce vulnerability to the effects of climate change and mitigate emissions of greenhouse gases

Objective 5.1 on flooding is well covered by the definition. Objective 5.2 includes integrating adaptation which is well covered by the phrase in the definition referring to "…fair and affordable both now and in the future." Objective 5.3 referring to greenhouse gases is not explicitly addressed, however is implicit in the reference to "…protecting and working with the environment…"

Material assets

To promote the sustainable use of natural resources and material assets

Objective 6.1 on ecological and geological systems is covered by the inclusion of "working with the environment". Objective 6.2 is addressed by the inclusion of the use of "economic resilience" in the definition. Similarly 6.3 referring to phasing and timing is covered by the concept of "economic resilience". Objective 6.4 is not explicitly addressed, however is implicit in references to "working with the environment" and ways which are "fair and affordable". Objective 6.5 is similar to 6.4 being covered only in reference to "protecting the environment".

Cultural heritage

To preserve and enhance the historic environment

Preservation, in both 7.1 and 7.2, is well covered in the definition where it refers to "protect and work with". Enhancement (where appropriate) is not referred to in the definition.

Landscape

Protect and enhance the landscape

8.1, 8.2 both refer to protection which is included in the definition under "protecting and working with the environment". Opportunities for enhancement are not included explicitly in the definition.

Reference in 8.3 to improving quantity and quality of landscape is only implicitly referred to - although is covered to some extent by the use of "working with the environment, in a way which is fair".



Assessment of the SFM Objectives

In addition to the SFM Definition the proposals contain a set of SFM objectives which should drive implementation of SFM.

This stage of the assessment is based on looking at the compatibility between the SFM Objectives and the SEA objectives outlined previously. Assessment is based on how well the requirements included in the SEA objectives are covered across the range of SFM objectives - for each an assessment of compatibility is given. In some cases where the compatibility is unclear or undefined then this is indicated. In some cases it is felt that the compatibility between certain pairs of objectives is not relevant and the assessment marks this appropriately. Additional information on the explicit meanings behind the SFM Objectives is obtained from the Table A1 in the consultation document.

Broadly there are no significant incompatibilities between the SFM Objectives and the set of SEA objectives. This is largely to be expected given the strategy level and breadth of the SFM objectives. Generally the compatibility between the two sets of objectives was good; there was uncertainty relating to environmental impacts on soil, material assets and cultural heritage in some cases. Uncertainties were due to the inability to assess environmental impacts on the national strategic scale and potential effects will be more suited to assessment at the project level. It is expected that at a project level there are likely to be some significant effects in some cases - especially concerning cultural heritage.

Given the absence of significant adverse effects there is no requirement for specific mitigation measures.

SFM Objectives

SEA Objectives

Biodiversity, flora and fauna

Population and Human Health

Soil

Water

Climatic Factors

Material Assets

Cultural Heritage

Landscape

Comments

(reference should be made to the detail on SFM Objectives as contained in the proposals)

1

Overall - meet needs for flood resilience.

0

+

0

+

0

+

+

0

Population and Human Health are well covered in assessment of personal social impact. Material assets also covered by detail on damage to personal, commercial or public property. Some consideration of cultural heritage under inclusion of public property in SFM objective (although this does not extend to the full range of areas covered by the term 'Cultural Heritage').

2

Social - enhance community benefit with fair access for everyone.

0

+

0

0

+

0

0

0

Detailed meaning includes impact on local jobs - reflected well in SEA indicator on community vitality and viability. Good compatibility in terms of fair access to benefits of SFM - covering health equalities, recreation etc.

3

Environmental - protect and work with the environment, with respect for all species, habitats, landscapes and built heritage.

+

+

?

+

+

?

+

+

Detailed meaning takes account of water environment, floodplain ecological habitats and landscapes, BAPs, GHG emissions. No specific mention of soil or material asset related items however may be covered by (v) covering targets from non-water plans and programmes and (vi) covering other urban/rural benefits including amenity/aesthetics etc.

4

Economic - deliver resilience at affordable cost with fair economic outcomes.

0

+

0

+

+

+

?

0

Detail on delivery of SFM includes cost/benefit analysis and avoidance/awareness/assistance which is compatible with objectives on Population and Human Health. Material assets is compatible with whole life costing approach to SFM.

5

Future generations - allow for future adaptability, with a fair balance between meeting present needs and those of future generations.

0

+

?

+

+

?

?

0

Future generations objective explicitly takes account of increased climatic effects and uncertainty and also headroom. SFM objectives also explicitly consider catchment response - and hence SEA objectives on soil. Water issues adequately compatible with this objective through natural capacity for flood response. Material assets considered as part of detail on fail safe provision for design flood exceedance.

Key to Appraisal

+

Potentially compatible

-

Potentially incompatible

?

Uncertain

0

Not relevant to SEA objective

Assessment of the potential effects of the SFM Principles and Objectives

In addition to the definition and objectives the SFM proposals also include a set of Principles which are intended to set out the way in which the SFM process should operate and be applied in order to achieve the SFM objectives listed previously. These Principles include taking a strategic approach to SFM; approaches to collaboration between stakeholders; seeking opportunities for multiple benefits etc.

Similarly to previous parts of the assessment it has been necessary to consider what the effects of the SFM proposals will have when aggregated across Scotland as a whole. The particular benefits from a particular flood management scheme will depend on the unique environmental issues, risks and opportunities faced in that particular area or locality.

The assessment is presented in an amended form to the outline contained in the scoping report.

Potential effect and nature of effect

Supporting data or source of information

Opportunities for mitigation and enhancement arising from the SEA

SEA Objective: To maintain and enhance biodiversity with no net loss of species

Implementation of SFM offers the potential to actively protect and, in some cases, enhance habitats and the biodiversity on which they rely. Biodiversity benefits from SFM should be over the medium to long term and permanent but will be specific to the particular needs of the area at risk.

A strategic approach to SFM, as listed in the Principles, allows for the wider scale consideration of biodiversity and habitats - allowing for consideration on the scale of habitat networks, migration and movement of species.

Options appraisal specifies the inclusion of a 'most sustainable benchmark' which should fully consider the biodiversity opportunities offered by the SFM scheme.

Considering uncertainty in the implementation of SFM seems to be aimed primarily at climatic/extreme event uncertainty, however should be extended to consider uncertainty surrounding the effect on habitats and biodiversity.

SFM offers multiple benefits which extend across a range of subject areas, one of which is the protection, recreation and enhancement of habitats.

The environmental baseline discusses designated areas and status of UKBAP habitats. Also looks at habitat change and changes in plant diversity.

30% of UKBAP habitats and 14% of UKBAP species are in decline. Semi-natural habitats have been in significant decline over recent years.

Clearly SFM implementation offers benefits in terms of habitat protection, enhancement and creation. The strategic nature of SFM should be used to optimal effect to maximise the protection of existing habitat networks.

Clearly what is achievable on an individual SFM implementation will depend on the particular local issues however early involvement of stakeholders and consideration of the effects on the larger area (e.g. on the river basin catchment level) should allow for consideration of optimum habitat protection and enhancement.

SEA Objective: To protect and enhance human health and well-being

Protection of human health and well-being is based primarily on minimising the exposure to risk of the effects of flooding but also considers opportunities presented by SFM to contribute to community strength/viability/vitality and healthier lifestyles.

The principles include the concept of responsibilities where all stakeholders should be actively engaged.

Options appraisal promotes the consideration of a 'most sustainable benchmark' which should address all 'four 'A's' - awareness, avoidance, alleviation and assistance regardless of regulatory or legislative barriers. This should inform on maximum potential for minimising risk to human health and wellbeing through education and awareness-raising.

Uncertainty should be considered in SFM developments, again using the precautionary approach when considering future flood models and risk.

Multiple Benefits are offered by SFM, which include providing open spaces and contributing to the local vitality of communities.

Openness and democracy as fundamental principles of SFM should improve awareness of flood risk management and involvement of the individuals and particular issues facing communities.

Population is increasing as shown in baseline assessment; additionally there is increasing pressure on development from higher proportions of single occupancy housing.

Human health record remains poor in Scotland with low levels of physical activity. This is particularly linked with low-income households and areas.

Intangible impacts from flooding (anxiety, risk, fear) have been shown to be as relevant as physical losses of belongings.

SFM offers opportunities to involve communities in the protection that can be afforded in terms of flood risk. Awareness raising can assist in rationalising fears about flooding - but can also offer practical advice to minimise the amount of time require to get back to normal after disturbance and loss due to flooding.

Physical activity can be encouraged by the development of multi-use areas as part of SFM schemes - areas which provide leisure/recreational space at most times but which contribute to a wider SFM implementation.

SEA Objective: To protect soil quality

Key issues pertinent to soil are erosion, and increases as a result of climate change, along with increased impermeability of urban landscape leading increased runoff.

Strategic approach should lead to larger scale consideration of the effects of increased impermeability. Should also assist in considering issues associated with runoff from contaminated land.

Uncertainty of current data and models and future development of issues relating to rainfall, sea level and other flooding issues require precautionary approach. Benefits should be experienced in minimisation of soil erosion in urban and rural areas.

Baseline data on rainfall and runoff show increasing trends which can in some way be addressed by the implementation of SFM.

Management of runoff and associated flood risk are central to the SFM proposals and are already addressed. Wider considerations of soil are not specifically mentioned and should possibly be highlighted more within the proposals.

SEA Objective: To protect and enhance the quality of the water environment

Clearly water is one of the most significant of the SEA objectives in relation to the SFM proposals.

Application of the Strategic Approach will allow for the consideration of catchments as a whole - in many cases beyond the scale of individual local authorities. Severe issues such as diffuse pollution will be more effectively managed at a strategic, river basin level at which SFM should be applied.

Engagement of stakeholders who share responsibilities will also offer benefits in diffuse pollution and effective management of flood risk - as will full options appraisal and acceptance of inherent uncertainty in data and flood models.

Baseline assessment indicates the significance of diffuse pollution and its effect on water quality in Scotland. This is particularly relevant in terms of the large contributions from urban development and from agriculture - both areas of particular relevance to SFM.

The potential benefits offered by the proposals for the water environment are extremely important. Inevitably as water is the principle focus of the SFM proposals the benefits are largely already contained within the proposals as they stand. Possibly the most significant benefit is already explicitly mentioned in the Principles - that of a strategic approach to SFM.

SEA Objective: To reduce vulnerability to the effects of climate change and mitigate emissions of greenhouse gases

The particular relevance of climate change to SFM is the expected higher levels of rainfall and increased frequency and magnitude of flood events.

Again, the strategic approach offers benefits in terms of developing a co-ordinated approach to flood risk management at the waterbody or regional level.

Options Appraisal should provide a platform for considering SFM approaches which minimise emissions of GHGs.

Explicit in the principles is that of uncertainty in current data and future models which should offer benefits in terms of a precautionary approach to flood management. Benefits of awareness and education should also be provided by the consideration of events which exceed design limits.

As stated previously there are suggestions indicating increasing levels of precipitation across Scotland. Increasing mean temperatures are also expected to contribute to the frequency and magnitude of events.

Similarly to the case with the water environment, the driver behind the development of the SFM proposals are increased risk of flooding from increased precipitation and rising sea levels. Potential benefits associated with this issue are already well embedded in the SFM proposals.

SEA Objective: To promote the sustainable use of natural resources and material assets

Primary risks to material assets are those of damage due to flooding - but there are also considerations of energy and material use.

Adopting a strategic approach allows for the protection of significant infrastructure over the regional/river basin scale and allows for suitable phasing and timing to be considered in the implementation of flood management schemes.

Options appraisal will allow for consideration of the 'most sustainable benchmark' and will make explicit the decision making process and levels of risk and value attached to different property and infrastructure types and locations.

Baseline data indicates levels of properties at risk of flooding and estimates these risks in the future.

The SFM proposals have, at their core, the resilience from flooding and as such consider material assets considerably in terms of infrastructure, commercial and private property.

There is little explicit consideration of energy use and sustainable materials considered within the definition, objectives and principles however this is illustrated elsewhere in the consultation document.

SEA Objective: To preserve and enhance the historic environment

There is no explicit mention in the SFM Principles concerning historic environment, however it is implied.

Strategic approach should allow for consideration of alternative options based on the location and protection of the historic environment when applied on a regional or area scale.

The Principles consider the responsibilities of involvement in SFM of all relevant parties which will include those responsible for protection of historic environment.

The concept of multiple benefits should extend to the protection and, where appropriate, enhancement of the historic environment and could in some cases lead to increased accessibility for the general public.

The baseline data assessment makes reference to the scale of the historic environment within Scotland and indicates the likelihood of its relevance to SFM schemes.

The SFM proposals make little explicit reference to the historic environment, however it is implied. There is scope within individual SFM implementations to work closely with the historic environment in order to protect it and, in some cases, enhance sites and their setting.

SEA Objective: Protect and enhance the landscape

Making use of the strategic approach to SFM should allow for the protection and enhancement of those areas of particular national or local value.

Multiple benefits considerations are explicitly linked to landscape and amenity enhancement in the SFM Principles and should lead to the protection of areas of importance.

Openness and Democracy should support the preservation of valuable landscape and space.

Insufficient information available at present.

As with other issues, the strategic approach to SFM offers the most benefits in terms of landscape. Clearly landscape is of particular importance and value, particularly in relation to specific communities. The SFM proposals should place an emphasis on maintaining and supporting landscapes of particular importance.

Assessment of cumulative effects and their causes

Part of the environmental assessment involves consideration of the cumulative and synergistic effects of the proposals. Given the strategic approach that is being adopted in the Environmental Assessment it is difficult to consider these in detail as much will depend on the local implementation and relevant assessment which are carried out. The assessment was carried out using professional judgement. As detailed previously there were not significant adverse effects identified in previous sections of the assessment. Similarly there were no significant cumulative negative effects identified however there are a range of positive cumulative effects as detailed below.

Cumulative effect

Affected receptor

Causes

Strategic benefits

All areas

The sum of the proposals (namely the definition, objectives, principles and administrative structures) will offer cumulative benefits across the catchment and national levels through the strategic approach to the development of sustainable flood management measures. The use of Area Advisory Groups (or equivalent) will provide a mechanism for ensuring the consideration of flood risk management (and associated environmental effects) do not become too localised but instead consider options for flood risk management, and associated benefits, holistically and strategically.

Flood risk management

All areas

As a whole the proposals offer positive effects in terms of flood risk management, as would be expected. The proposals offer guidance on the benefits and values inherent in SFM and in general the strategic approach identified, when applied to the range of topics and SFM objectives details, can lead to significant positive effects on the regional and national scale.

Regeneration

Urban areas at risk of flooding

Opportunities are offered by sustainable flood management to promote and support regeneration in areas where flood risk has been an issue or may be in the future. This can be supported through opportunities for multiple use areas which offer flood protection while also providing facilities for the local community.

Benefits can also be offered through the strategic use of SFM to remove flood risk from an area to remove constraints of development.

Public engagement / strength of communities

Communities

The SFM proposals include ensuring the data used for decision making, and the decision making process itself, is transparent and accessible to interested parties. This supports the scope for public engagement with the process and promotes interest in the strength of the local community.

Stakeholder engagement similarly offers benefits for public and community involvement and representation of the needs of the local population.

Amenity improvements

Local landscapes

Opportunities are offered by SFM to improve the amenity value of areas by removal of culverts and increased access to watercourses as well as other visual and aesthetic improvements. This can contribute to issues such as community strength and public involvement in community issues.

Reduction in loads on infrastructure

Infrastructure

Suitable implementation of SFM can assist reduction in the existing loads on infrastructure such as waste water treatments works and increasing headroom. This can contribute to the removal of development constraints within an area.



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Page updated: Wednesday, February 13, 2008