Flood risk and water management - Engagement version
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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Topic: Flood risk and water management
Engagement version – August 2025
Requirements addressed in this section
Table 1 Information required by the Town and Country Planning (Scotland) Act 1997, as amended, regarding the issue addressed in this section.
| Section | Requirement |
|---|---|
| Section 15(2A) | A local development plan is to include a statement of the planning authority’s policies and proposals as to the provision of public conveniences. |
| Section 15(2B) | A local development plan is to include a statement of the planning authority’s policies and proposals as to the provision of water refill locations. |
| Section 15(5)(a) | the principal [physical], cultural, economic, social, built heritage and [environmental] characteristics of the district. |
Table 2 Information required by the Town and Country Planning (Development Planning) (Scotland) Regulations 2023, regarding the issue addressed in this section.
| Regulation | Requirement |
|---|---|
| Regulation 9(2)(e) (iv) | The information and considerations are-… |
| The following plans and strategies, insofar as relating to the local development plan area— | |
| any river basin management plan, | |
| Regulation 9(2)(e) (v) | The information and considerations are — … |
| The following plans and strategies, insofar as relating to the local development plan area— | |
| any flood risk management plan, | |
| Regulation 9(2) (e) (vi) | The information and considerations are — … |
Cairngorms National Park Authority Ughdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
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| Regulation | Requirement |
|---|---|
| The following plans and strategies, insofar as relating to the local development plan area— | |
| any local flood risk management plan, |
Links to evidence
• Water Framework Directive https://environment.ec.europa.eu/topics/water/water-framework-directive_en • National Parks Act (Scotland) 2000 https://www.legislation.gov.uk/asp/2000/10/contents • Flood Risk Management (Scotland) Act 2009 https://www.legislation.gov.uk/asp/2009/6/contents • Town and Country Planning (Scotland) Act 1997 https://www.legislation.gov.uk/ukpga/1997/8/contents • Environmental Protection Act 1990 https://www.legislation.gov.uk/ukpga/1990/43/contents • Water Resources (Scotland) Act 2013 https://www.legislation.gov.uk/asp/2013/5/contents • Water Intended for Human Consumption (Private Supplies) (Scotland) Regulations 2017 https://www.legislation.gov.uk/ssi/2017/282/contents • Directive 2000/60//EC of the European Parliament and if the Council of 23 October 2000 establishing a framework for Community action in the field of water policy (Water Framework Directive) https://eur-lex.europa.eu/resource.html?uri=cellar:5c835afb-2ec6-4577-bdf8- 756d3d694eeb.0004.02/DOC_1&format=PDF • National Planning Framework 4 https://www.dpea.scotland.gov.uk/LibraryDocument.aspx?id=2094
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• Securing a green recovery on a path to net zero: climate change plan 2018 – 2032 – update https://www.gov.scot/binaries/content/documents/govscot/publications/strategy- plan/2020/12/securing-green-recovery-path-net-zero-update-climate-change-plan- 20182032/documents/update-climate-change-plan-2018 – 2032-securing-green- recovery-path-net-zero/update-climate-change-plan-2018 – 2032-securing-green- recovery-path-net-zero/govscot%3Adocument/update-climate-change-plan-2018- 2032-securing-green-recovery-path-net-zero.pdf • Scottish National Adaptation Plan 2024 – 2029 https://www.gov.scot/binaries/content/documents/govscot/publications/strategy- plan/2024/09/scottish-national-adaptation-plan-2024 – 2029‑2/documents/scottish- national-adaptation-plan-2024 – 2029/scottish-national-adaptation-plan-2024- 2029/govscot%3Adocument/scottish-national-adaptation-plan-2024 – 2029.pdf • Water-Resilient Places: A Policy Framework for Surface Water Management and Blue – Green Infrastructure 2021 https://www.gov.scot/binaries/content/documents/govscot/publications/advice-and- guidance/2021/02/water-resilient-places-policy-framework-surface-water- management-blue-green-infrastructure/documents/water-resilient-places-policy- framework-surface-water-management-blue-green-infrastructure/water-resilient- places-policy-framework-surface-water-management-blue-green- infrastructure/govscot%3Adocument/water-resilient-places-policy-framework- surface-water-management-blue-green-infrastructure.pdf • A National Mission with Local Impact: Infrastructure Investment Plan for Scotland 2021 – 2022 to 2025 – 2026 https://www.gov.scot/binaries/content/documents/govscot/publications/strategy- plan/2021/02/national-mission-local-impact-infrastructure-investment-plan- scotland-2021 – 22-2025 – 26/documents/national-mission-local-impact- infrastructure-investment-plan-scotland-2021 – 22-2025 – 26/national-mission-local- impact-infrastructure-investment-plan-scotland-2021 – 22-2025- 26/govscot%3Adocument/national-mission-local-impact-infrastructure-investment- plan-scotland-2021 – 22-2025 – 26.pdf • Our Sustainable Future Together: Long-Term Strategy https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Strategic-Plan/Long-Term-Strategy/Our-Sustainable-Future- Together_Scottish-Water-Long-Term-Strategy.pdf
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• Scottish Water Strategic Plan – A sustainable future together https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Strategic-Plan/030220StrategicPlanASustainableFutureTogether.pdf • Scottish Water Climate Change Adaptation Plan 2024 https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Climate-Change/290224ScottishWaterAdaptationPlan.pdf • Scotland’s National Water Scarcity Plan 2020 https://www.sepa.org.uk/media/219302/scotlands-national-water-scarcity-plan.pdf • Scottish Biodiversity Strategy to 2045: Tackling the Nature Emergency in Scotland https://www.gov.scot/binaries/content/documents/govscot/publications/strategy- plan/2024/11/scottish-biodiversity-strategy-2045/documents/scottish-biodiversity- strategy-2045-tackling-nature-emergency-scotland/scottish-biodiversity-strategy- 2045-tackling-nature-emergency-scotland/govscot%3Adocument/scottish- biodiversity-strategy-2045-tackling-nature-emergency-scotland.pdf • Cairngorms National Park Partnership Plan 2022 – 2027 https://cairngorms.co.uk/wp-content/uploads/2022/09/Cairngorms-National-Park- Partnership-Plan-full-version-FINAL.pdf • Cairngorms National Park Local Development Plan 2021 https://cairngorms.co.uk/wp-content/uploads/2021/03/CNPA-LDP-2021-web.pdf • Cairngorms Nature Action Plan 2019 – 2024 https://cairngorms.co.uk/wp- content/uploads/2019/02/CairngormsNatureAction19_24PlanFinal.pdf • Guidance for planning authorities on Strategic Flood Risk Assessment (2023) https://www.sepa.org.uk/media/3psdfwce/sfra-guidance-for-planning- authorities.pdf • National Flood Risk Assessment 2024 https://informatics.sepa.org.uk/NFRA2018/
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• National Flood Risk Assessment for Flood Risk Management in Scotland 2024: Review Summary https://beta.sepa.scot/media/u12bwpdw/report-national-flood-risk-assessment- review-summary.pdf • Potentially Vulnerable Areas for Flood Risk Management in Scotland 2024: consultation summary report https://consultation.sepa.org.uk/evidence-and-flooding/potentially-vulnerable- areas/results/public_consultation_report_final.pdf • Assessment of Potential Application of the Reservoir Inundation Maps for Land Use Planning Purposes Position Statement https://www.sepa.org.uk/media/594633/reservoir-position-statement.pdf • The River Basin Management Plan for Scotland 2021 – 2027 https://www.sepa.org.uk/media/594088/211222-final-rbmp3-scotland.pdf • Flood Risk Management Plan for the Findhorn, Nairn and Speyside Local Plan District https://www2.sepa.org.uk/frmplans/documents/lpd5-findhorn-nairn-and-speyside- frmp-2021.pdf • Flood Risk Management Plan for the North East Local Plan District 2021 https://www2.sepa.org.uk/frmplans/documents/lpd6-north-east-frmp-2021.pdf • Flood Risk Management Plan for the Tay Local Plan District 2021 https://www2.sepa.org.uk/frmplans/documents/lpd8-tay-frmp-2021.pdf • Findhorn, Nairn and Speyside Local Flood Risk Management Plan 2022 – 2028 http://www.moray.gov.uk/downloads/file145841.pdf • North East Local Flood Risk Management Plan 2022 – 2028 https://www.aberdeenshire.gov.uk/media/27479/local-flood-risk-management-plan- 2022 – 2028.pdf • Tay Local Flood Risk Management Plan 2022 – 2028 https://www.pkc.gov.uk/media/50689/Tay-Local-FRM- Plan/pdf/Tay_Local_FRM_Plan_Final.pdf?m=638101523092000000
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• Dee Catchment Management Plan Summary https://www.deepartnership.org/wp-content/uploads/2020/06/DCMP- SummaryFORWEB.pdf • Dee Catchment Partnership Delivery Plan 2022 – 2027 https://cairngorms.co.uk/wp-content/uploads/2025/04/Dee-Catchment-Partnership- Delivery-Plan-2022 — -2027.pdf • Spey Catchment Management Plan https://speycatchment.org/spey-catchment-management-plan/ • Aviemore, Rothiemurchus and Glenmore Community Action Plan Looking to 2030 https://cairngorms.co.uk/uploads/documents/Aviemore-Rothiemurchus-Glenmore- Community-Action-Plan-2024.pdf • Ballater and Crathie Community Action Plan 2023 https://cairngorms.co.uk/uploads/documents/Ballater-Crathie-CAP-2023-Final.pdf • Blair Atholl Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Blair-Atholl-Struan-Community-Action- Plan-2023-final.pdf • Breamar Community Action Plan 2017 https://cairngorms.co.uk/uploads/documents/2017-BraemarAction-Plan.pdf • Carrbridge Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Carrbridge-Community-Action-Plan- 2022.pdf • Cromdale and Advie Community Action Plan 2013 https://cairngorms.co.uk/uploads/documents/2013CromdaleAdvieActionPlan.pdf • Dalwhinnie Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/DalwhinnieCAP2023Report.pdf
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• Dulnain Bridge Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Dulnain-Bridge-Community-Action- Plan-2024 – 1‑2.pdf • Kincraig and locality Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Kincraig-and-locality-Community- Action-Plan-2024.pdf • Laggan Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Laggan-Community-Action-Plan- 2022.pdf • Nethy Bridge Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Nethy-Bridge-Community-Action-Plan- 2023.pdf • Newtonmore Community Action Plan: Looking to 2030 https://cairngorms.co.uk/uploads/documents/Newtonmore-Community-Action-Plan- 2022.pdf • Strathdon Area Community Action Plan 2016 https://cairngorms.co.uk/uploads/documents/2016-Strathdon-Action-Plan.pdf • Cairngorms National Park Local Development Plan 3: Strategic flood risk assessment 2024 https://cairngorms.co.uk/wp-content/uploads/2024/03/Cairngorms-Strategic-Flood- Risk-Assessment-2024.pdf • PCS 20000559 Scottish Environment Protection Agency response to Cairngorms National Park Authority draft Strategic Flood Risk Assessment https://cairngorms.co.uk/wp-content/uploads/2025/04/PCS-20000559-SEPA- Response-to-CNPA-Draft-Strategic-Flood-Risk-AssessmentRedacted.pdf • Cairngorms evidence report – version 3.0 flood hazard maps correspondence https://cairngorms.co.uk/wp-content/uploads/2025/04/RE-Cairngorms-evidence- report-version-3_0-flood-hazard-maps.pdf
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• Scottish Environment Protection Agency reservoir inundation map https://map.sepa.org.uk/reservoirsfloodmap/Map.htm • Cairngorms Nature Action Plan 2019 – 2024 https://cairngorms.co.uk/wp- content/uploads/2019/02/CairngormsNatureAction19_24PlanFinal.pdf • Upper Spey beaver translocation – monitoring and mitigation plan https://cairngorms.co.uk/wp-content/uploads/2023/12/Redacted-Appendix-14- Monitoring-and-Mitigation-Plan-2023.pdf • Scottish Environment Protection Agency water classification hub https://www.sepa.org.uk/data-visualisation/water-classification-hub • Scottish Environment Protection Agency water environment hub https://www.sepa.org.uk/data-visualisation/water-environment-hub • Cairngorms National Park – Waterbody information https://cairngorms.co.uk/wp-content/uploads/2024/12/Cairngorms-National-Park- waterbody-information.pdf • Scottish Pollutant Release Inventory https://informatics.sepa.org.uk/SPRI/ • Nitrate Vulnerable Zones: maps https://www.gov.scot/publications/nitrate-vulnerable-zones-maps/ • The Urban Waste Water Treatment (Scotland) Regulations 1994 https://www.legislation.gov.uk/uksi/1994/2842/contents/made • Urban Waste Water Treatment Directive Sensitive Areas 2024 https://www.gov.scot/binaries/content/documents/govscot/publications/map/2016/0 1/urban-waste-water-treatment-sensitive-areas-map/documents/urban-waste- water-treatment-sensitive-areas-map- 2019/urban-waste-water-treatment- sensitive-areas-map- 2019/govscot%3Adocument/UWWT%2BSA%2BMap%2B2024.pdf • Loch Morlich bathing water information https://bathingwaters.sepa.scot/locations-and-results/results/?location=366986
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• Cairngorms National Park – Protected site information https://cairngorms.co.uk/wp-content/uploads/2025/01/Cairngorms-National-Park- protected-site-information.pdf • Scottish Environment Protection Agency Planning Advice Note for Planning Authorities: Local Development Plan Evidence Gathering: Water Scarcity https://www.sepa.org.uk/media/op5dcbka/pan-for-water-scarcity-evidence‑3.docx • Climate Crisis: Informing Scotland’s actionable mitigation and adaptation response to water scarcity https://www.crew.ac.uk/sites/www.crew.ac.uk/files/publication/CRW2022_07 M ain%20report%20and%20appendices_2024_04_15_V3_FINAL.pdf • Climate Crisis: Informing Scotland’s actionable mitigation and adaptation response to water scarcity https://www.crew.ac.uk/sites/www.crew.ac.uk/files/publication/CRW2022_07 M ain%20report%20and%20appendices_2024_04_15_V3_FINAL.pdf • Water scarcity in Scotland https://storymaps.arcgis.com/stories/f9bc4491b0a6409aa7cd1aa757bac6cb • Future predictions of water scarcity in Scotland: impact on distilleries and agricultural abstractors https://www.crew.ac.uk/sites/www.crew.ac.uk/files/publication/CRW2023_05_Main_ report_and_appendices_FINAL_V2.pdf • Drought Risk Assessment Tool https://www2.sepa.org.uk/drought-risk-assessment-tool • 8010 – River Spey at Grantown river monitoring data https://nrfa.ceh.ac.uk/data/station/info/8010 • 12003 — River Dee at Polhollick river monitoring data https://nrfa.ceh.ac.uk/data/station/info/12003 • Scottish Water guide to living or working in a drinking water protected area https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Energy-and-Sustainability/Sustainable-Land- Management/200320SWProtectedDrinkingWaterV4Lrweb.pdf
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• Public Water Supplies (Scotland) Regulations 2014 https://www.legislation.gov.uk/sdsi/2014/9780111024782/contents • Drinking water protected areas Scotland river basin district: maps https://www.gov.scot/publications/drinking-water-protected-areas-scotland-river- basin-district-maps/ • Scottish Water List of Precautions for Drinking Water and Assets – General https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Energy-and-Sustainability/Sustainable-Land- Management/091120SWListOfPrecautionsForDrinkingWaterAndAssetsGeneralEdD. pdf • Scottish Water List of Precautions for Drinking Water and Assets – Housing and mixed use https://www.scottishwater.co.uk/-/media/ScottishWater/Document-Hub/Key- Publications/Energy-and-Sustainability/Sustainable-Land- Management/131120SWListofPrecautionsforDrinkingWaterandAssetsHousingand mixeduseEdE.pdf • Private water supplies https://data.spatialhub.scot/dataset/private_water_supply_properties-is • Private Water Supplies and Climate Change: The likely impacts of climate change (amount, frequency and distribution of precipitation), and the resilience of private water supplies https://www.crew.ac.uk/sites/www.crew.ac.uk/files/publication/CRW2018_05_report _FINAL.pdf • Septic tanks https://data.spatialhub.scot/dataset/septic_tanks-is • Scottish Water Top up Taps https://www.yourwateryourlife.co.uk/find-my-nearest-tap/
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Summary of Evidence
Policy Context
National Planning Framework 4
National Planning Framework 4’s policy 1 Tackling the climate and nature crises states that local development plans must address the global climate emergency and nature crisis by ensuring the spatial strategy will reduce emissions and adapt to current and future risks of climate change by promoting nature recovery and restoration in the area.
Policy 2 Climate mitigation and adaptation states that local development plans should support adaptation to the current and future impacts of climate change by taking into account climate risks, guiding development away from vulnerable areas, and enabling places to adapt to those risks.
The risks associated with the requirements of these two policies include those from flooding and water scarcity.
Policy 22 Flood risk and water management aims to strengthen resilience to flood risk by promoting avoidance as a first principle and reducing the vulnerability of existing and future development to flooding. For planning purposes, at risk of flooding or in a flood risk area means land or built form with an annual probability of being flooded of greater than 0.5% which must include an appropriate allowance for future climate change.
It sets out that local development plans should strengthen community resilience to the current and future impacts of climate change, by avoiding development in areas at flood risk as a first principle. Resilience should also be supported by managing the need to bring previously used sites in built up areas into positive use; planning for adaptation measures; and identifying opportunities to implement improvements to the water environment through natural flood risk management and blue green infrastructure.
National Planning Framework 4 states that local development plans should take into account the probability of flooding from all sources and make use of relevant flood risk and river basin management plans for the area. A precautionary approach should be taken, regarding the calculated probability of flooding as a best estimate, not a precise forecast. For areas where climate change is likely to result in increased flood exposure that becomes unmanageable, consideration should be given to alternative sustainable land use.
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Policy 18 Infrastructure first sets out the requirements for all types of infrastructure, including water supply and water waste management infrastructure. It states that for local development plans and delivery programmes should be based on an integrated infrastructure first approach. Local development plans should: • Be informed by evidence on infrastructure capacity, condition, needs and deliverability within the plan area, including cross boundary infrastructure. • Set out the infrastructure requirements to deliver the spatial strategy, informed by the evidence base, identifying the infrastructure priorities, and where, how, when and by whom they will be delivered. • Indicate the type, level (or method of calculation) and location of the financial or in- kind contributions, and the types of development from which they will be required.
Local development plans should align with relevant national, regional and local infrastructure plans and policies and take account of the Scottish Government infrastructure investment hierarchy and sustainable travel and investment hierarchies in developing the spatial strategy.
National Planning Framework 4 also encourages consistent early engagement and collaboration between relevant stakeholders to better inform decisions on land use and investment.
Policy 20 Blue and green infrastructure have spatial strategies that identify and protect blue and green infrastructure. These may have benefits for natural flood management. Detail on blue and green infrastructure will be covered in a separate evidence paper to be engaged on later in 2025.
Policy 10 states that the spatial strategies of local development plans should consider how to adapt coastlines to the impacts of climate change. This should recognise that rising sea levels and more extreme weather events resulting from climate change will potentially have a significant impact on coastal and islands areas, and take a precautionary approach to flood risk including by inundation. The Cairngorms National Park does not have a coastline and therefore the requirements of policy 8 do not apply.
Policy 32 states that local development plans should guide new aquaculture development in line with National and Regional Marine Planning. Since the Cairngorms National Park lacks a coastline, this element of the policy does not apply. Due to the lack of a coastline, or large freshwater lochs, the National Park does not have any pressure for aquaculture developments and therefore there are no implications for the local development plan’s spatial strategy in this regard, either.
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Where the local development plan may support the policy, is through the safeguarding of migratory fish species. It is noted that barriers to fish migration is the most common pressure responsible for waterbodies not achieving overall good status in the Cairngorms National Park (see Figure 14). This is mostly related to hydroelectricity generation (see Table 6). While the Proposed Plan can do little about existing schemes, it should ensure that proposals for new hydroelectric schemes and associated works do not negatively impact migratory fish.
It is also noted that Atlantic salmon are a qualifying feature of both the River Dee and River Spey Special Areas of Conservation and the Proposed Plan will need to take account of this species in the preparation of its spatial strategy and assessment of allocations. This will be assessed through the habitats regulations appraisal process in consultation with NatureScot. Further information on protected sites and their qualifying features is provided in the Natural heritage evidence paper: • https://cairngormsldp.commonplace.is/en-GB/proposals/v3/natural-heritage- survey?step=step1
National Parks Act (Scotland) 2000
The National Park has four distinct aims as set out in The National Parks (Scotland) Act 2000). All four are of relevance to the matters discussed in this paper: • To conserve and enhance the natural and cultural heritage of the area. • To promote sustainable use of the natural resources of the area. • To promote understanding and enjoyment (including enjoyment in the form of recreation) of the special qualities of the area by the public, and • To promote sustainable economic and social development of the area’s communities.
The aims are all to be pursued collectively. However, if there is conflict between the first aim and any of the others, greater weight is given to the first aim (as set out in Section 9(6) of the 2000 Act).
Securing a green recovery on a path to net zero: climate change plan 2018 — 2032 – update
The document provides an update to the 2018 Climate Change Plan. Since that Plan Scottish Government have set new ambitious targets to end its contribution to climate change by 2045. Scottish Government have committed to reduce emissions by 75% by 2030 (compared with 1990) and to net zero by 2045. As Scotland emerged from COVID-19 the Government identified an opportunity to rebuild the economy in a
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way that delivers a greener, fairer and more equal society. This Plan sets out the Governments approach to delivering a green recovery and sets out a pathway to deliver its climate change targets. In line with the 2018 plan, the focus is on the period up to 2032.
The Plan sees nature-based solutions, such as natural flood risk management, as a key element in Scotland’s response to climate change and prioritises its delivery under the land use, land use change and forestry theme. The Plan also recognises the importance of nature-based solutions in achieving better water security.
Scottish National Adaptation Plan 2024 – 2029
The Scottish National Adaptation Plan sets out actions to build Scotland’s resilience to climate change. The Adaptation Plan sets out a long-term vision and defines Scotland’s priorities for action over the years 2024 – 2029.
Scottish Government’s vision is for a resilient, inclusive and well-adapted Scotland as the climate continues to change. The Plan contains five outcomes, of which the following four are of direct relevance to flood risk and water management: • Outcome One: Nature Connects (NC) • Outcome Two: Communities © • Outcome Three: Public Services and Infrastructure (PS) • Outcome Four: Economy, Business and Industry (B)
Outcome One: Nature Connects (NC) supported by six objectives, of which the relevant ones are summarised here:
Objective: Nature-based solutions (NC1)
Action to increase resilience to the impacts of climate change is delivered through nature-based solutions including street trees, parks, raingardens, green roofs, improved walking, wheeling and cycling and water ways. Water resource planning to support drought and flooding resilience, improve water quality and quantity, and protect biodiversity is a key part of improving nature-based solutions. Actions include: • Investment in blue and green infrastructure. • A review of water industry policy, and a continual assessment on how water, sewerage and drainage services can adapt to the impacts of climate change to avoid water scarcity through future legislation (This is linked to Objective PS3). • The preparation of a Scottish Flood Resilience Strategy (see page 20), that will set out what needs to be done to make Scotland’s places more resilient to warmer, wetter winters and increased instances of storms and flash flooding. The Strategy
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will encourage delivery partners to take a whole catchment approach and support interventions to increase resilience to river, coastal and surface water flooding. The Strategy will also out a role for nature-based solutions in helping to create flood resilient places.
Objective: Landscape scale approaches (NC2)
Working for climate resilience at a landscape scale involves land management. It in