Democracy Spraffa

Appendix 2 - Water, Wastewater and Drainage draft Consultation Response

Perth and Kinross Council · 7 February 2024
Back to Environment, Infrastructure and Economic Development Committee — 7 February 2024 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

Appendix 2
Water, Wastewater & Drainage Policy Consultation 
Respondent Information Form 
Please Note this form must be completed and returned with your response.
To find out how we handle your personal data, please see our privacy policy:
https://www.gov.scot/privacy/ 
Are you responding as an individual or an organisation?   
Individual 
Organisation
Full name or organisation’s name 
Phone number 
Address 
Postcode 
Email Address 
The Scottish Government would like your 
permission to publish your consultation 
response. Please indicate your publishing 
preference: 
Publish response with name 
Publish response only (without name) 
Do not publish response
We will share your response internally with other Scottish Government policy teams who
may be addressing the issues you discuss. They may wish to contact you again in the
future, but we require your permission to do so. Are you content for Scottish
Government to contact you again in relation to this consultation exercise? 
Yes 
No 
Perth and Kinross Council
2 High Street, Perth 
01738 475000
PH1 5PH
Enquiries@pkc.gov.uk
Information for organisations:
The option 'Publish response only (without
name)’ is available for individual
respondents only. If this option is selected,
the organisation name will still be
published. 
If you choose the option 'Do not publish
response', your organisation name may still
be listed as having responded to the
consultation in, for example, the analysis
report.

Page 2

Questionnaire 
Question 1
Do you agree that Scotland needs to set out a plan to manage our water resources, for
now and into the future? 
Yes 
No 
Question 2
To what extent do you agree that taking a national view of catchment risks will help
better protect drinking water sources from pollutants? 
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 3
To what extent do you agree or disagree that everyone in Scotland needs to use less
drinking water? 
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 4
How do you think people and businesses could use less drinking water? 
Please give us your views. 
Planning regulations could be used to encourage developments where less water would be
used such as micro homes. 
The Council has also undertaken a project to reduce the amount of drinking water used for
hand washing etc to reduce costs and support climate change.

Page 3

Question 5
Would you like to know how much water you use in your home? 
Yes 
No 
Question 6
Would you seek to reduce your water usage if this avoids building expensive new
reservoirs and water treatment works? 
Yes 
No 
Question 7
Would you know where to find information on using less water? 
Please give us your views. 
Question 8
To what extent do you agree or disagree that the process for responding to water
shortages should be changed so that appropriate action can be taken as soon as it is
needed?   
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 9
To what extent do you agree or disagree that all of Scotland’s plumbing should be made
lead-free? 
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree

Page 4

Question 10
Would you know where to get information on how to ensure that your pipes are not
affecting your drinking water? 
Yes 
No 
Question 11
Do you agree that all drinking water supplies, regardless of size or ownership, should be
tested and inspected to ensure that drinking water is safe? 
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 12
What support do owners and users of private water supplies require to ensure the
drinking water is safe? 
Please give us your views. 
Question 13
Do you have any further views on public and private drinking water supplies? 
Please give us your views. 
Those on private water supply require clear information regarding suitable domestic
treatment systems and their maintenance.  It should be made clear to those
purchasing properties served by private water supplies that they need looking after
carefully to produce consistent safe water. 
The present private water supply grant should be increased to encourage users of
failing supplies to seek more long-term solutions such as borehole drilling.  It would
be good to get a way to encourage groups of properties to work together to reduce
overall costs per household.

Page 5

Question 14
Who do you think has a role in changing how we manage rainwater in Scotland to adapt
to the impacts of climate change? (Please select all that apply). 
Individuals 
Homeowners 
Businesses 
Scottish Government 
Scottish Water 
Local Authorities 
Scottish Environment Protection Agency (SEPA) 
Land owners 
Farmers 
House builders 
Community groups 
Other (please use the text box below) 
Question 15
To what extent do you agree that you/your organisation have/has a role in changing how
we manage rainwater in communities to adapt to the impacts of climate change? 
Strongly agree 
Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Community Resilience Groups can also play an important role in helping their communities
respond to flooding and the effects of climate change.

Page 6

Question 16
What would you/your organisation be willing to do in your home/property to manage
rainwater differently? For example, disconnect your down pipes from the sewer, have
permeable driveways, install water butts and/or rain gardens. 
For the development of our new build Council housing and Council housing
refurbishment programmes we have recently developed a new Design Guide. This guide
outlines best practice in developing suitable, affordable and energy efficient housing
design. The Guide incorporates a range of recommended features which will ensure
new build homes and refurbishment programmes meet the individual needs of each
household, and are well connected to local services, jobs, and communities.
Within the Design Guide there are some elements in relation to the management of
rainwater and that the drainage design is listed as having to reference the following
guidance:
• Scottish Water guidelines 
• PKC Flood Risk Supplementary Guidance 
• PKC Open Space Provision for New developments
The Guide states that the sustainable drainage is to be integrated within site layouts,
streets and gardens. Preference is to capture all volume above ground but if this is not
achievable then a combination of below ground storage tanks and oversized pipes with
above ground strategies will offer an acceptable solution. Drainage should ensure that
flows directed away from homes with road surfaces kept lower than verges, footpaths
and homes where possible.
Developments should incorporate landscape features to support sustainable drainage
such as rain gardens and swales (shallow drainage channels). These can provide
opportunities within communities by supporting growing spaces, providing pleasant
green zones and spaces for children to play and learn.
In terms of driveways, we currently don’t build any properties with driveways but instead
provide communal parking areas; as the drainage is to be integrated at the time of the
build, the capacity should be considered in the design at the time of the proposals being
developed. 
Question 17
Would you know where to find information on how to best manage rainwater in your
property? 
Yes 
No 
Question 18
To what extent do you agree that there is a need to plan, build, maintain and make room
for drainage infrastructure to better manage rainwater in our villages, towns and cities?   
Strongly agree 
Agree

Page 7

Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 19
What should Scotland’s drainage systems look like in the future? 
Grey infrastructure only (drains, pipes, tanks) 
Blue-green infrastructure (rain gardens, green roofs, SUDS ponds, basins, wetlands,
swales, etc) 
A combination of both grey and blue-green infrastructure 
Question 20
Do you have any further views on how Scotland should manage rainwater in the future?

Page 8

Please give us your views. 
Question 21
Should investment be prioritised to address overflows that have a negative impact in the
environment? 
X Yes 
No 
The recent policy framework developments around blue-green infrastructure
enhanced the existing flood risk management approach but are unlikely to
dramatically reduce surface water flood risk. 
While blue-green infrastructure has its place and can play a limited role in future
rainwater management, it will not provide solutions in built-up urban catchments at
the highest risk of surface water flooding where little or no space is available. In such
circumstances, all other potential solutions must continue to be pursued (surface
water management planning, SUDS, Scottish water improvements in combined
sewer infrastructure, etc). Grey infrastructure solutions will therefore remain
necessary. 
While the aspiration of separating surface water out of combined sewers is
understood, the surface water and resulting flood risk still has to be managed. 
There remain many barriers to the delivery of effective surface water flood
management including: 
• Limited funding:-
o Surface water management schemes are often not economically viable and
therefore do not attract capital grant funding; the Scottish Government should
consider changes to existing legislation to address this.  
o Capital grant funding levels should be increased to meet the needs of the
climate emergency.
o At present Scottish Water are only funded to deal with internal property
sewer flooding. They should be provided with funding to deal with internal
and external property surface water flooding. 
• The current regulatory/legislative framework around surface water flood risk
management should be reviewed and strengthened, particularly with a view to
placing greater duties on Scottish Water. 
• A legal duty should be placed on Scottish Water to manage internal and external
property flooding due to surface water, as well as internal sewer flooding.
• Sustainable Urban Drainage Systems:-
o Legal duties should be placed on developers to provide well designed,
natural SUDS. This should be back up by Changes to Sewers for Scotland. 
o Additional Regulations should be considered to improve the design, adoption
and maintenance arrangements for SUDs.
• Landowners and farmers must act to reduce surface water runoff from private
and agricultural land as this makes a significant contribution to flood risk, and the
transport of significant volumes of sediment.

Page 9

Question 22
To what extent do you agree or disagree that more should be done to stop items being
disposed of down toilets or drains? 
Strongly agree
X Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 23
How do you think we can change behaviours to avoid the disposal of substances or
matter in the toilet/sewer (e.g. wet wipes, cotton buds, nappies and hygiene products
etc.)? 
Please give us your views. 
Question 24
It is already an offence for non-household properties to discharge fats, oils and greases
to the sewer. Do you agree that offences should be extended to:   
Include other pollutants, and specifically plastic? X Yes     No
Extend the offence to household premises?  X Yes     No 
Education and communication regarding harm to sewage systems along with
consequences i.e. costs of remediation.

Page 10

Please give us your views. 
Question 25
We currently undertake some monitoring of pollutants, do you agree that we should
extend our monitoring of wastewater to look for new pollutants, and monitor pathogens
in the community? 
Strongly agree
X Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 26
Do you agree that resource recovery is something that Scottish Water should be
undertaking? 
X Yes 
No 
Question 27
To what extent do you agree that Scottish Water should be able to use the money it
receives from customer charges to invest in resource recovery hubs? 
This could include use of scarce resources and increase recycling of reusable materials
that might otherwise be sent to landfill. 
Strongly agree
X Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
This would be particularly hard to enforce i.e. tracing the perpetrator of the
contamination would be very difficult and would likely be resource intensive. 
This view extends to Questions 25 & 26 in that the source will be difficult to pinpoint
without dedicated resourcing 
.

Page 11

Question 28
Do you agree that all wastewater treatment systems, regardless of size or ownership,
should be tested and inspected to ensure that they do not impact negatively on the
environment? 
X Yes 
No 
Question 29
What support do owners and users of private wastewater systems require to best protect
the environment? 
Please give us your views. 
Question 30
Do you think that owners of existing private wastewater systems should be required to
connect to the public system where connection is possible, beneficial and not
expensive?   
Strongly agree
X Agree 
Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 31
Do you have any further views on public and private wastewater systems? 
It is likely that owners of private wastewater systems are also on private water
supplies therefore, the same connection difficulties will apply.  For example, most
properties would like to be connected to main supplies but are too far away from the
sewage / water network.

Page 12

Please give us your views. 
Question 32
To what extent do you agree that changing our behaviours is essential to limit charge
rises? 
Strongly agree 
Agree
X Neither agree nor disagree 
Disagree 
Strongly disagree 
Question 33
Do you agree that we should recognise that there are three services (water, wastewater
and drainage)? 
X Yes 
No 
Question 34
Do you agree that using Council Tax Bands is the fairest way to charge for services
used by households? 
Yes
X No 
It is likely that owners of private wastewater systems are also on private water
supplies therefore, the same connection difficulties will apply.  For example, most
properties would like to be connected to main supplies but are too far away from the
sewage / water network.

Page 13

Other (please use the text box below). 
Question 35
In your view, how do we incentivise households/businesses to reduce water usage to
levels that are sustainable for Scotland? 
Please give us your views. 
Question 36
In your view, how could we incentivise households/businesses to manage rainwater
differently to reduce rainwater entering the sewer system to levels that is sustainable for
Scotland? 
Any charges should be linked to the demand on the systems, council bandings will
only indicate how many rooms a property has other than the demand on sewage
systems and mains water systems.
Education and communication regarding the use of water along with consequences
i.e. costs of shortage.

Page 14

Please give us your views. 
Question 37
To what extent do you agree that all households and businesses should pay for roads to
be drained?   
Strongly agree 
Agree 
Neither agree nor disagree
X Disagree 
Strongly disagree 
Please give us your views. 
Provide water butts for householders and advise on how to collect etc. 
Consideration of how to incentivise keeping gardens green and turning into
driveways/concrete areas which deter soak away of rainwater. 
This would sound like a double charge to householders and businesses who will
believe they already pay for this via the Council.