Strategic Environmental Assessment Environmental Report Draft

3 Context of the proposals on Sustainable Flood Management

3.1 Background to the development of the proposals

The consultation document offers a definition of the term "Sustainable Flood Management (" SFM")" as used in Section 2 of the Water Environment and Water Services (Scotland) Act 2003 ("the 2003 Act").

The 2003 Act transposes the EC Water Framework Directive into Scots Law. The 2003 Act makes the link between flood risk management and protecting the water environment by placing a duty on Scottish Ministers, SEPA and responsible authorities (including local authorities) to promote SFM when carrying out flood risk management functions. The term "sustainable flood management", however, is not defined in the 2003 Act. The Scottish Government considers that it is essential that a definition is provided in practical terms to ensure that this provision is implemented effectively and consistently across the whole of Scotland.

The proposals have been developed through work done initially by the National Technical Advisory Group on Flooding Issues ( NTAG) and subsequently by the Flooding Issues Advisory Committee ( FIAC). The first draft of the definition, objectives and principles - forming a draft framework for SFM - was developed by NTAG and was published in the paper "What is Sustainable Flood Management?"

In 2005 MWH-Jacobs Babtie were commissioned to carry out a Pilot Study to enable testing of the flooding framework to provide feedback and to inform on the production of the consultation paper. Following this a revised draft of the paper ( FIAC 2006(6)) was produced with an updated framework. The paper has been used as the basis for the present consultation for which this SEA is being carried out.

3.1.1 Description of the SFM proposals

The aim of the proposals contained within the consultation document is to present a concise and pragmatic definition of SFM applicable to all types of flooding. The consultation document proposes high level objectives (the goals that SFM aspires to achieve) and principles (which define how the objectives are achieved). The paper also includes suggested measurement indicators for the objectives intended to allow for assessment of progress and for comparison between flood management options from the national/strategic level down to the scheme/project level.

The complete consultation document is available on the Scottish Government's website at: http://www.scotland.gov.uk/Consultations/Current.

3.1.2 Sustainable Flood Management - definition

The proposed definition of SFM is:

"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."

(* where ' resilience' means 'ability to recover quickly and easily'. The Scottish Government uses it to deliver the 'four As': Awareness + Avoidance + Alleviation + Assistance.)

(** ' flooding' means all types of flooding: surface (pluvial), sewer, river, groundwater, estuarine and coastal).

3.1.3 Sustainable Flood Management - objectives

The proposed objectives for SFM are:

Overall - meet needs for flood resilience.

This objective should be met by integrating the following needs:

Social - enhance community benefit with fair access for everyone;
Environmental - protect and work with the environment, with respect for all species, habitats, landscapes and built heritage;
Economic - deliver resilience at affordable cost with fair economic outcomes;
Future generations - allow for future adaptability, with a fair balance between meeting present needs and those of future generations.

The consultation also includes a set of 21 indicators which have been developed in order to enable progress against the objectives to be measured. The indicators are clearly divided into groups for assessment of each of the five SFM objectives.

3.1.4 Sustainable Flood Management - principles

The following are the proposed principles setting out how the objectives might be delivered

1. [Strategic Approach] Sustainable flood management ( SFM) should reflect a strategic approach both nationally (across Scotland) and locally with links to the River Basin Management Plan Process and with phasing where appropriate. It should take account of the 2003 Act principles of co-ordinated management to achieve relevant objectives for all water bodies, and the planning policy contained in SPP7. It should use strategic environmental assessment and sustainability appraisal as they are introduced into Scottish methodology.

2. [Responsibilities] All stakeholders should be actively engaged in and share responsibility for achieving SFM. They are expected to collaborate constructively to meet the SFM objectives, with the lead taken by the appropriate party(ies) according to their statutory, legal, common law or commercial role(s).

3. [Options Appraisal] Sustainability issues should be considered from the earliest stages of investigating options. The options considered for flood management should include, through to full evaluation, at least one option that represents a 'most sustainable benchmark', addressing all four 'A's: Awareness, Avoidance, Alleviation and Assistance, even if regulatory or legal barriers appear to block implementation . Decision-making tools will include, but not be limited to, Cost Benefit Analysis and should make the 'values' applied explicit.

4. [Uncertainty] A long-term view of sustainability means acknowledging and taking account of current uncertainties - including current data and models - and future uncertainties (see Objective 5). Flood risk should be expressed clearly. It also requires explicit consideration of the implications of flood events that exceed design limits.

5. [Multiple Benefits]SFM should seek opportunities for multiple benefits, but also cover costs and frequency of loss (economic, rural, landscape or amenity enhancement), wherever possible and seek other relevant funding sources.

6. [Openness] The whole SFM process should be transparent; and there should be a common, shared source of information, from which all stakeholders can access and learn.

7. [Democracy]SFM should promote effective community engagement. Decisions should be taken at the local level, as far as possible, and reflect local community 'Agenda 21' or similar sustainability objectives. Parties should plan and manage to achieve community consents without the cost and delay of a Public Inquiry.

8. [Simplicity] Implementation of SFM should be understandable, aim for ease of delivery, and promote continual learning, and sharing of knowledge.

3.1.5 Proposals for flood risk management planning within Scotland

The consultation document includes suggestions for how the coordination and strategic management of SFM could be structured within Scotland. There are two significant changes to current practice proposed:

That SEPA is appointed as the competent authority with overall responsibility for coordinating flood risk management planning in consultation with "Responsible Authorities"
That Area Advisory Groups (or similar) are set up to provide a forum for the coordination of the Responsible Authorities

3.2 Relationship with other plans, programmes or strategies ( PPS) and environmental objectives

The Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes an outline of the relationships between the SFM Proposals and other relevant plans, programmes or strategies.

A review of relevant international and national plans, policies and strategies has been carried out during the scoping phase. A list of those plans reviewed can be se en in Table 3-1. The detailed review can be seen in Appendix 2.

Table 3-2 summarises the key issues which need to be considered in the preparation of the proposals.

At present the SFM proposals do not occupy a formal place within the plan and policy hierarchy within Scotland. The proposals are instead intended to inform what is meant by the phrase "sustainable flood management" as it should be applied by Responsible Authorities, and are designed to provide guidance for Responsible Authorities when they are fulfilling their statutory obligations. It is also expected that the guidance will inform future legislation and its implementation, in particular the recently implemented EC Flooding Directive and future national legislation on flooding and climate change.

Table 3-1 Summary of plans, programmes and strategies included in the review

International

Convention on Wetlands of International Importance 1971 (amended 1982 and 1987)

UN Convention on Biological Diversity (1992)

Council Directive 92/43/ EEC on the conservation of natural habitats and of wild fauna and flora ('Habitats Directive')

Council Directive 79/409/ EEC on the conservation of wild birds ('Birds Directive')

The Pan-European Biological and Landscape Diversity Strategy (1995)

EU Biodiversity Strategy (1998)

EU Thematic Strategy for Soil Protection, including proposals for a Soil Framework Directive (September 2006)

SEERAD - Scotland's Soil Resource - Current State and Threats (2006)

Water Framework Directive (2000/60/ EC)

Bathing Water Directive 2006 (2006/7/ EC)

Nitrates Directive (91/676/ EC)

EC Directive on ambient air quality assessment and management (1996)

UN Framework Convention on Climate Change (1994)

Kyoto Protocol (1998)

Proposed EC Directive on Flood Management

Council of Europe, European Landscape Convention (2000)

The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: . Working together for Clean Air (2000)

UK Climate Change Programme (2006)

DEFRA - One Future - Different Paths: The UK's shared framework for sustainable development 2005

Proposed Climate Change Bill: UK

Securing the future - UK Government Sustainable Development Strategy 2005

Scotland's National Transport Strategy (2006)

Sustainable Development and the Natural Heritage - The SNH approach (Scottish Natural Heritage Policy Statement No. 02/01 - 2002)

SPP1 The Planning System (2002)

Forestry Commission Scotland, The Scottish Forest Strategy (2006)

Civil Contingencies Act 2004

Scotland

Scottish Biodiversity Strategy

Nature Conservation (Scotland) Act 2004

"Scotland's Biodiversity - It's in Your Hands. A strategy for the conservation and enhancement of biodiversity in Scotland" (2004)

NPPG14 Natural Heritage (1999)

PAN60 Planning for Natural Heritage (2000)

NPPG 11 Sport, Physical Recreation and Open Space (1996)

SPP11 Physical Activity and Open Space (Consultative Draft) 2006

Scottish Executive - Improving Health in Scotland - The Challenge (2003)

Land Reform (Scotland) Act 2003

River Basin Planning Strategy for the Scotland River Basin District ( SEPA, December 2005)

Water Environment and Water Services (Scotland) Act 2003 ( WEWS Act)

Water Environment (Controlled Activities) (Scotland) Regulations 2005 and Amendment Regulations 2007

River Basin Planning Framework for the Solway Tweed River Basin District ( SEPA, August 2006)

Better Bathing Waters: Meeting the Challenges of the Revised Bathing Water Directive in Scotland (Scottish Executive, March 2006)

PAN79 Water and Drainage (2006)

PAN61 Planning and Sustainable Urban Drainage Systems (2001)

PAN69 Planning and Building Standards Advice on Flooding

SEPA Policy 19: Groundwater Protection Policy for Scotland

NPPG13 - Coastal Planning (August 1997)

Changing Our Ways - Scottish Climate Change Programme (2006)

Proposed Climate Change BiIl: Scotland

Framework for Economic Development in Scotland (2004)

Building a Better Scotland Infrastructure Investment Plan: Investing in the Future of Scotland (2005)

National Planning Framework for Scotland (2004)

Building Better Cities: Delivering Growth and Opportunities (2003)

Cities Growth Fund 2006-2008 (2005)

SPP1 - The Planning System (2002)

SPP 3 Planning for Housing (2003)

SPP 7 Planning and Flooding (2004)

SPP 15 Planning for Rural Development (2005)

Modernising the Planning System - Planning White Paper and forthcoming Bill

Scottish Natural Heritage ( SNH): Policy Statement - SNH and the Town and Country Planning Systems

Historic Scotland, Passed to the Future: Historic Scotland's Policy for the Sustainable Management of the Historic Environment (2002)

NPPG18 - Planning and the Historic Environment (1999)

NPPG5 - Archaeology and Planning (1998)

Memorandum of understanding Guidance on Listed Buildings and Conservation Areas, Historic Scotland (1998)

Seas the Opportunity: A Strategy for the long term sustainability of Scotland's Coasts and Seas (2005)

NPPG14 Natural Heritage (1999)

PAN60 Planning for Natural Heritage (2000)

NPPG 13 Coastal Planning (1997)

SPP15 Planning for Rural Development (2005)

SPP21 Green Belts

A Forward Strategy for Scottish Agriculture (2001)

Scottish Forestry Strategy (2006)

National Planning Framework (2004)

Choosing our future: Scotland's Sustainable Development Strategy

Table 3-2 Summary of environmental objectives of relevant plans, policies and strategies and implications for the SFM Proposals

Summary of environmental objectives	Summary of implications for the SFM Proposals
In relation to biodiversity, flora and fauna provision is made in European and National policy to protect species and habitats of particular importance - specified explicitly in UN Convention on Biological Diversity, and the Habitats and Birds Directives. Wetlands are identified in particular in the Ramsar Convention for their unique and vital ecological function. The EU Biodiversity Strategy along with the Scottish Nature Conservation Act move towards a more pro-active approach to anticipate losses and to actively 'further the conservation of biodiversity'. NPPG14 places emphasis on safeguarding and enhancing natural heritage outwith designated sites. PAN60 Planning for Natural Heritage also recommends cross-sectoral working to achieve shared biodiversity objectives - particularly relevant to SFM.	The proposals should support conservation of species and habitats with particular focus on designated habitats and species There is a need to encourage the protection, creation or remediation of particularly valuable or rare habitats outwith designated areas There should be acknowledgement of the role of flood management in achieving catchment-level biodiversity improvements The proposals should support networks of designated sites at all levels The proposals should encourage the reconnection and support of habitat networks particularly in respect of the impacts of climate change
The primary population and human health issue is the minimisation of the risk of death or injury to the public with additional consideration to minimising illness and mental stress. Secondary issues highlighted in national planning guidance NPPG11 and SPP11 involve the provision of accessible open space for active and passive recreation as a way of reducing health inequalities through promoting physical recreation.	The proposals should prioritise the reduction of risk of personal injury and illness. The proposals should promote measures that respect the current advice given in SPP7 and PAN69 with respect to new developments in flood risk areas. There is a need to maximise the opportunities to provide open spaces and facilities for public recreation. The proposals should support the viability of communities by minimising the fear and stress associated with flooding risks
Guidance related to soil is limited however some work has been carried out to identify key issues which are relevant. Issues identified in the Scottish Executive's Scottish Soil Resource report, include addressing man-made and natural pressures including erosion (coastal and fluvial), organic content loss and soil sealing. There is an emphasis on recreating or restoring the natural hydrological cycle. Climate change, and its effects, is identified as a principal national issue for Scotland's soils.	There is a need to restore or recreate the natural hydrological cycle particularly in relation to soil sealing and surface run-off The proposals should take account of nationally significant issues including water erosion and loss of organic matter The proposals should also take account of the effect of climate change on exacerbating existing issues and on creating new issues relating to soil
Issues relating to water are extensive and are driven largely by the EC Water Framework Directive ( WFD) and its transposition into Scots Law in the 2003 Act. Within the WFD there is a requirement to prevent the deterioration of aquatic ecosystems and to protect and improve the sustainable use of surface waters, transitional waters, coastal waters and groundwater. There is a statutory requirement to contribute to the mitigation of floods and to reduce pollution. The key objective is for all inland and coastal waters to achieve 'good ecological status'. Implementation of this is to be achieved through the development of River Basin Management Plans ( RBMP) which will integrate the management of land and water within River Basic Districts. The Controlled Activity Regulations ( CAR), which emanate from the 2003 Act, provide the primary mechanism for regulating the activities of water users and engineering works within the water environment. There is a range of planning guidance on water and drainage which place the emphasis on meeting the needs of householders and encouraging the uptake of Sustainable Urban Drainage Systems ( SUDS). There is also guidance and policy relating to bathing waters, nitrates, groundwater protection and coastal planning which require integration.	Policies, regulations and others measures promoting improvements to water quality, quantity and river basin hydropmorphology should be highly integrated into the proposals supporting the drive towards 'good ecological status' of all inland and coastal waters There is an overall need to restore the function of floodplains to help achieve quality, quantity and hydromorphological objectives of water bodies. Coastal water and bathing water quality improvements should be incorporated into the proposals Where possible the proposals should encourage approaches which mitigate against diffuse pollution There is a need to consider catchment-level strategies to minimise and mitigate the adverse effects of flooding Groundwater should be protected through the minimisation of pollution and through careful management of abstraction Where possible the proposals should streamline the flood prevention, planning and CAR processes to achieve effects at the strategic or catchment level
There are general objectives associated with air to minimise air pollution and its effect on human health and the environment.	At a very general level the proposals should minimise specific impacts from air pollution where applicable
Issues relating to climatic factors include achieving reduction in emissions of greenhouse gases as outlined in the Scottish Executive's "Changing our ways" (2006). There are also highly significant issues relating to mitigation and adaptation in respect of changes due to climate change - most importantly changes in precipitation and sea levels. Clearly this is an area of particular importance in flood management.	The proposals should have a strong emphasis on adapting to future effects of climate change as a key aspect of increased inland and coastal flooding Where appropriate, the proposals should encourage the minimisation of greenhouse gas emissions
Key strategic issues pertaining to Material Assets include the provision of flood risk management plans to protect private and commercial property. The National Planning Framework acknowledges that there are intense pressures for more housing in areas of high demand which will increase development pressures on floodplains. There are also issues over wastewater drainage capacity as a growth constraint in some parts of Scotland. SPP7 Planning and Flooding states the overall objective of preventing development which would be adversely affected by flooding or would increase flooding risk elsewhere. The policy also requires the use of SUDS wherever possible.	The proposals should consider the needs for increased development tied to economic growth and the resulting pressures on floodplains The proposals should promote the integrated provision and management of drainage and flood management assets. There is a need to support and encourage the use of SUDS SFM should strongly support the objectives associated with minimising flood risk in all types of property and development
Cultural Heritage priorities include the protection of designated sites and resources. There is also a requirement to consider resources as yet unknown. There is some requirement to assist in achieving enhancement of key resources where possible. Legislation to protect the historic environment comprises the Ancient Monuments and Archaeological Areas Act 1979, The Protection of Wrecks Act 1973 and the Planning (Listed Buildings and Conservation Areas)(Scotland) Act 1997.	Safeguard designated heritage resources and their settings from inappropriate development Attempt to enhance heritage resources where appropriate Protect non-designated heritage resources and their settings
Landscape policy relates to key areas of recognised value; however, there is an increasingly broad approach to the support and valuing of the natural heritage and natural beauty of urban and rural areas. Policies encourage the avoidance of loss of landscapes of particular character due to development and also encourage the regeneration and restoration of developed landscapes. There is also a need to consider locally important areas of distinctiveness of areas of particular scenic value. Particular focus is given to the water environment with particular focus on the value of watercourses and wetlands and there is emphasis on the restoration of culverted or canalised watercourses. In particular there is an acknowledgement of the particular role landscape plays in the wellbeing of the people and economy of Scotland, which must be reflected in flood management approaches.	The proposals should encourage consideration and respect of landscape of value and distinction taking into account both landscape character and quality but also local distinctiveness and areas of scenic value Landscape enhancement should be pursued where possible, especially where inappropriate change has happened previously Acknowledge that there may be a need for managed change of landscapes to meet wider needs of flood management
There is a wide range of broad issues relating to Sustainable Development. Many are incorporated into the subjects previously covered.	There are broad sustainable development aims incorporated into the above implications and which will be translated into the SEA objectives.

3.3 Relevant aspects of the current state of the environment

3.3.1 Environmental Baseline

Schedule 3 of the Environment Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of the "relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme." This section aims to describe the environmental context within which the proposals operate and the constraints and targets which result from this context.

Relevant environmental information was identified and reviewed in order to fulfil three main purposes within the SEA:

support the identification of environmental problems;
support the process of assessing the environmental effects;
provide a baseline against which future monitoring data can be compared.

The environmental baseline can only be considered at the Scotland-wide scale in terms of relevance to the SFM proposals. The baseline data is presented in

Appendix 3. Key aspects of the environmental baseline are presented below.

3.3.2 Biodiversity, Flora and Fauna

Increasing intensification of land use for agriculture, forestry and industry - combined with continued population growth - has led to significant and rapid declines in biodiversity in Scotland.

Of the UKBAP priority habitats and species found in Scotland by 2005 around 33% of habitats and 32% of species were stable or are improving whilst 30% of habitats and 14% of species were in decline. The conditions of many others remain unclear. Substantial decreases in semi-natural habitats have been identified in the period 1990-1998.

The impact of climate change is evident through reductions in some species ranges, extensions in others, and disruptions to food chains. This threat is expected to get worse. It is expected that some form of intervention or active management will be required to maintain the status of many habitats and species in Scotland.

3.3.3 Population

Population in Scotland is predicted to increase at a growth rate of around 1% to approximately 5.12 million by 2024. In recent years the population has been slowly increasing however changes to household structures, primarily increasing single occupancy households, have led to a quicker increase in household numbers. This is projected to continue and will require additional housing leading to potential increasing development pressures, especially in already urbanised areas.

Estimates of properties at risk of flooding stand at 73,000 properties at a 0.5% probability of fluvial flooding and 26,000 properties at a 0.5% probability of coastal flooding.

3.3.4 Human health

Scotland's health record remains poor with some of the highest levels of coronary heart disease in Europe combined with low levels of physical activity. These problems are particularly concentrated in households with low incomes.

Wider issues exist concerning mental health and wellbeing - particularly in relation to flooding. Particularly relevant are intangible losses from flooding (anxiety, stress, fear etc.) reported as having higher impact than material losses.

3.3.5 Soil

Soil erosion is identified as a continuing problem in Scotland, a problem expected to be exacerbated by climate change. There are also concerns about reductions of organic soil matter. Soil sealing, through the creation of impermeable surfaces, is a significant issue particularly relevant to flooding. Soil sealing interrupts the normal hydrological cycle and can lead to increased surface run-off and flood risk along with depletion of groundwater.

3.3.6 Water

There is an identified need for increased management of water resources - lochs, rivers and groundwater. Flooding risk may be increasing in some areas due to combined effects of changes in river flow patterns and changes in climatic effects (see later). Physical structures associated with watercourses and water bodies are significant in terms of habitat improvement and flood risk. It should be noted that additional flooding issues can be caused by existing flood prevention schemes which can also, in come cases, restrict more holistic approaches to flood management.

3.3.7 Air

Overall air quality in Scotland is improving and is generally good. Urban areas, however, still experience significant issues with local air quality resulting in adverse health effects.

3.3.8 Climatic factors

Climate change is affecting all areas of the environment causing changes in biodiversity, higher river flows and sea level rise. Increases in flood risk are particularly relevant when combined with other factors such as increased urbanisation and soil sealing. Sea levels are projected to rise by approximately 60cm around Scotland's coastline.

3.3.9 Material Assets

A large number of private and commercial properties are under risk of river, estuarine or coastal flooding.

Landfilling of biodegradable municipal waste (a contributor to air, water and soil pollution) has decreased over recent years with strict targets defined for the future. Energy generation from coal has declined over the last ten years; generation from oil and gas has increased. Hydropower still forms a significant proportion of Scotland's renewable generation capacity.

3.3.10 Cultural Heritage

Scotland has around 47,500 listed buildings and over 600 conservation areas. In terms of archaeology the actual extent of remains in Scotland is unknown, with the number of scheduled monuments only representing a minority of those for which records exist. The historic environment can be threatened by development, population change, neglect and land use. Issues can arise in terms of SFM where existing historical sites can create limitations on holistic flood management within an area.

3.3.11 Landscape

Scotland's landscape is a vital component in several human activities, from agriculture to tourism, and as a result is continually under pressure to be adapted to human needs. Incremental changes in land use can contribute to significant changes in landscape character within an area.

3.4 Summary of key existing environmental problems

Schedule 3 paragraph 4 of the Environmental Assessment (Scotland) Act 2005 requires that the Environmental Report includes a description of existing environmental problems, in particular those relating to any areas of particular environmental importance. The purpose of this section is to explain how existing environmental problems will affect or be affected by the proposals, and whether the proposals are likely to aggravate, reduce or otherwise affect existing environmental problems.

Environmental problems were identified through discussions with the Consultation Authorities and other stakeholders, and an analysis of the baseline data. Relevant environmental problems are summarised in Table 3-3.

Table 3-3 - Environmental problems relevant to the proposals

Key Environmental Problem(s)	Supporting data (where available at this stage)	Relevance to the SFM Proposals
Decline in overall area of semi-natural habitats in Scotland. Habitat loss and fragmentation through urbanisation and climate change effect.	Countryside Survey 2003 State of Scotland's Environment Report ( SEPA, 2006) Scottish Executive Key Environment Statistics 2007	Particularly sensitive habitats should be respected and their importance given due consideration at a local and strategic level when flood management options or strategies are being considered.
Changes in household structures, increasing numbers of households and population increases	Census data	Account should be taken of the increased pressures of development, particularly in already urbanised areas and within floodplains.
High levels of heart disease, low life expectancies and low levels of physical exercise	Scottish Health Survey 2003	Where possible there should be encouragement of the creation of multi function areas where flood management techniques have the opportunity to create new and accessible areas suitable for public recreation.
Effects of stress and anxiety due to fear of flooding	Scottish Executive - Exploring the Social Impacts of Flood Risk and Flooding in Scotland 2007	There should be consideration of minimising peoples' fears over flooding. There should be encouragement of education and awareness-raising over practical guidance to minimise the potential damage to personal property and possessions from flooding. Awareness-raising should also include issues such as insurance cover. Where possible there should be an emphasis on approaches which provide increased warning to the public.
Soil erosion caused by wind and water. Soil sealing, interfering with the hydrological cycle, resulting in increased overland flow and depletion of groundwaters	SEPA State of Scotland's Environment	Where possible the risks to soil should be given consideration during any flood management strategy development.
Ongoing diffuse pollution issues with regard to water quality	Scottish Executive Key Environment Statistics 2007	Account should be taken of current practice, particularly agricultural methods, and where possible approaches should encourage the consideration of schemes addressing diffuse pollution as well as flood management.
Flood risk in various areas of Scotland, exacerbated by development pressure, increased urbanisation and climate change.	Scottish Executive Key Environment Statistics 2007 SEPA Indicative River & Coastal Flood Map	There is a need to increase the "resilience" to flooding of all types. This is particularly relevant in urban areas - the general thinking behind the proposals needs to be the re-establishment and/or protection of the hydrological system and of the function of flood plains.
Climate change trends are already established and are predicted to continue requiring mitigation and adaptation responses. Significant changes in rainfall, temperature and sea levels expected to increase risks of flooding in many areas.	UKCIP02 scenarios Scottish Climate Change Programme	Climate change issues are particularly relevant to flooding due to increased precipitation and rising sea levels. There should be consideration of the long term potential problems associated with climate change and need to ensure that these are given due consideration during decision making on flood management strategies.
Pressures on the historic environment from increased development and management of flooding. Historic sites may restrict the adoption of sustainable flood management within an area.	NPPG5 NPPG18	Pressures on the historic environment will be present where any development is taking place. It should be ensured that flood management strategies give due consideration to the accessibility and protection of any areas or sites of significant cultural heritage value.
Landscape change, standardisation and loss of distinctiveness.	SNH Natural Heritage Framework	Due consideration should be given to the vital role that Scotland's landscape plays in the wellbeing of the population and the economic effects of tourism as well as respecting the inherent qualities of different landscape types.

3.5 Likely future without implementation of the proposals

As has been stated previously, under the 2003 Act Scottish Ministers, SEPA and the Responsible Authorities have a duty to promote sustainable flood management - and this duty would be present whether the SFM proposals were being developed or not. As such it needs to be assumed that sustainable flood management would be implemented in any case - however the approach would vary across Scotland depending on the individual interpretations of the requirements by Responsible Authorities who (under the present circumstances, will in most cases be the local authorities, under their duties as defined in the 1961 Act).

It is assumed that if a widely accepted definition for sustainable flood management is not developed and adopted then the approaches taken by the Responsible Authorities will be inconsistent across Scotland. A key aspect of SFM - namely a strategic, co-ordinated approach - is supported both by the definition, objectives and principles of SFM and also by the suggested administrative structures. Under these proposals the implementation of SFM would be overseen by SEPA and the strategic, catchment-based approach would be supported by the formation of some kind of regional or district advisory group. Without the adoption of these proposals there will be limited application of SFM at a catchment level - identified as being vital to the successful implementation of sustainable flood management.

Without the strategic, catchment level response offered by the proposals it is unlikely that the optimum opportunities for protecting and enhancing biodiversity, flora and fauna would emerge. Issues relating to habitat protection would be localised, and the impacts of flood risk management would not necessarily be considered in terms of habitat networks and effects on the loss or reduction of key habitats across the wide area.

Without the proposals considerations over management of flood risk, and hence effects on population and material assets, may not be considered across the whole catchment - contrary to the needs to adopt a holistic approach to flood risk management. Minimising flood risk in one area without consideration of effects on the larger scale may merely shift the problem to somewhere else. These considerations carry over into risks of increased flood frequency and magnitude which may expose certain areas to new or additional flood risk.

In summary - should the proposals on an accepted definition of sustainable flood management and suggested administrative structures not be accepted then there will be still be environmental improvements linked to flood risk management however these may not be strategic, holistic, consistent and optimal.

3.6 SEA Framework

The SEA Framework was developed during the Scoping Stage as a means for assessing the potential environmental impact of the proposals. This framework contained a set of objectives which underwent minor refinement after consideration of the responses from the Consultation Authorities. These updated objectives are presented in Table 3-4.

Table 3-4 SEA Objectives

SEA Topic	SEA Objective	SEA sub-objective
Biodiversity, flora and fauna	To maintain and enhance biodiversity with no net loss of species	conserve and enhance the integrity and function of ecosystems further the conservation of biodiversity, avoiding irreversible losses prevent damage to designated and non-designated wildlife and geological sites
Population and human health	To protect and enhance human health and well-being	protect the population from death and injury minimise stress and anxiety from fear of flooding contribute to education, increasing awareness and community ownership contribute to the viability and vitality of communities contribute to maintaining and improving health equalities help encourage healthier lifestyles by protecting and enhancing access to recreational, amenity and spiritual/well-being functions of the environment
Soil	To protect soil quality	safeguard and improve soil quality, quantity and function reduce erosion and its impact on water quality
Water	To protect and enhance the quality of the water environment	limit water pollution to levels that do not damage natural systems maintain water abstraction, run-off and recharge within carrying capacity maintain and restore key ecological processes and functional floodplains protect and, where possible, enhance waterbody status and the water environment reduce and manage risks from increased flooding frequency and magnitude
Air	Air has been scoped out of the SEA process. It is considered that the SFM proposals, which are operating at a national strategic guidance level, cannot significantly impact on localised air quality issues. This decision been accepted by the Consultation Authorities.
Climatic Factors	To reduce vulnerability to the effects of climate change and mitigate emissions of greenhouse gases	consider the risks posed from increased flooding integrate adaptation to likely climate changes into flood management minimise emissions of greenhouse gases from flood risk management
Material assets	To promote the sustainable use of natural resources and material assets	recognise the services that ecological and geological systems can provide protect and improve essential infrastructure (e.g. bridges, WTWs, power stations etc) encourage the appropriate phasing and timing of infrastructure require sustainable energy use and promote energy recovery require the use of sustainable materials and sustainable construction in design and operation
Cultural heritage	To preserve and enhance where appropriate the historic environment	preserve and enhance, where appropriate, historic buildings, archaeological sites, historic landscapes and other culturally important features preserve and enhance the setting of the historic environment
Landscape	Protect and enhance the landscape	protect, enhance and where necessary restore landscape character and quality conserve, protect and enhance landscape and scenic value, particularly in designated areas, and protect local distinctiveness improve the quantity and quality of publicly accessible open space

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3 Context of the proposals on Sustainable Flood Management