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Local Flood Risk Management Plans - S37 Interim Update

Argyll and Bute Council · 11 September 2025
Back to Environment, Development and Infrastructure Committee — 11 September 2025 and its agenda

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ARGYLL AND BUTE COUNCIL ENVIRONMENT, DEVELOPMENT AND
INFRASTRUCTURE COMMITTEE 
ROADS & INFRASTRUCTURE
SERVICES 
11 September 2025 
LOCAL FLOOD RISK MANAGEMENT PLANS - S37 INTERIM UPDATE 
1.0.   EXECUTIVE SUMMARY 
This report provides an update on how the delivery of the Council's duties under
the Local Flood Risk Management Plans are progressing.  This is approximately
midway through the 2022-2028 Cycle 2 Plans. 
In accordance with the requirements of the Flood Risk Management (Scotland) Act
(2009) (‘the Act’), The Highland Council (as Lead Local Authority (LLA)) published
its second Local Flood Risk Management Plan (‘the Plan’) in December 2022,
setting out an ambitious range of flood risk management objectives and actions to
be completed in the first 6 year cycle (2022-2028).  
The Act also places a duty (under section 37) on the LLA to - review the Plan; and
- publish a report on the conclusions of the review, including information on the
progress that has been made towards implementing the measures. The interim
report must be made available for public inspection. 
The format of the Section 37 report has been developed by a Scottish Advisory
and Implementation Forum for Flooding Group, and agreed through the LLA
Forum, such that all local authorities, SEPA, Scottish Water and other responsible
authorities can input to a standard template and report in a similar format to
Scottish Government. 
The report requires noting the contents of the Section 37 Report and progress
made on the measures within the current Highland and Argyll Local Flood Risk
Management Plan; and agree to make the Section 37 Report for the Highland and
Argyll Local Plan District available to the public on the Council’s website; 
Whilst Argyll and Bute Council has identified and is working to implement schemes
identified as part of this report, it must be acknowledged that available budget and
resources play a major role in the ability to undertake these works.

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ARGYLL AND BUTE COUNCIL ENVIRONMENT, DEVELOPMENT AND
INFRASTRUCTURE COMMITTEE 
ROADS & INFRASTRUCTURE
SERVICES 
11 September 2025 
LOCAL FLOOD RISK MANAGEMENT PLANS - S37 INTERIM UPDATE 
2.0. INTRODUCTION
2.1 The Flood Risk Management (Scotland) Act 2009 (FRM Act) provides that the
Scottish Ministers, SEPA and responsible authorities (Local Authorities &
Scottish Water) must exercise their flood risk related functions with a view to
working together to reduce overall flood risk in Scotland and places certain
duties and responsibilities upon them.
2.2 SEPA are responsible for the development of Flood Risk Management Plans
(“FRMP”s) and certain Lead Local Authorities are responsible for the
development of LFRMP.
Local Flood Risk Management Plans (“LFRMPs”) are developed on a six
yearly cycle. Cycle One was from 2016-2022 and Cycle 2, currently in place,
runs from 2022 until 2028.
Argyll and Bute communities are in either:
i. The Highland and Argyll Local Plan District Area (LPD01) where The
Highland Council is the lead Local Authority.
ii. The Clyde and Loch Lomond Local Plan District Area (LPD11) where
Glasgow City Council is the lead Local Authority. 
Each Local Plan District has a FRMP and a LFRMP.
FRMPs coordinate efforts to tackle flooding in Scotland. They set the national
direction of future flood risk management, helping to target investment and
coordinate actions across public bodies. The plans explain what causes
flooding in high-risk areas as well as the impacts when flooding does occur.
Within the plans objectives for tackling flooding in high-risk areas are set
along with actions aimed at working towards those objectives.
LFRMPs include the actions recommended in the Flood Risk Management Plan
and add further details such as:
• Funding arrangements for each action
• Which organisation will be responsible for the delivery of the action.
• The timescale for delivery.
• Details of any coordination between authorities.

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2.3 The two current LFRMPs (Cycle Two 2022-2028) covering Argyll and Bute are:
i. Highland & Argyll Local Flood Risk Management Plan (Cycle 2)
ii. Clyde and Loch Lomond Local Flood Risk Management Plan (Cycle 2)
2.4 The Lead Authority for Argyll and Bute’s two Districts are:
i. The Highland Council for The Highland and Argyll Local Plan District
Area,
ii. Glasgow City Council for The Clyde and Loch Lomond Local Plan
District Area. 
2.5 Section 37 of the FRM Act states that each Lead Authority must prepare and
publish an Interim Report which reviews the LFRMP which has been in place for
2-3 years, and describes conclusions of the review including information on the
progress that has been made towards implementing the measures identified in
the implementation part of the plan.
2.6 To assist the two Lead Authorities with discharging their duties under the FRM
Act, Argyll and Bute Council are obliged to provide data on progress which has
been made towards implementing the measures identified for Argyll and Bute
Council in the implementation part of the two Local Flood Risk Management
Plans currently in place.
2.7 Once the final draft Interim Report is available, it is anticipated that this will
require EDI Committee approval. 
3.0. RECOMMENDATIONS
3.1 It is recommended that the Environment, Development and Infrastructure
Committee – 
i. endorse the report; 
ii. approve the content of the report and appendices to be provided to the
Lead Authorities to allow the Section 37 Interim Reports to be prepared;
and
iii. agree that the Section 37 Interim Reports are brought back to Committee
later in the year for approval. 
4.0. DETAIL 
4.1. Local Flood Risk Management Plan 2022-2028 
4.1.1. Objectives to be undertaken during Cycle 2 (2022 – 2028) for each target area
have been determined. 
4.1.2. SEPA have prioritised the Potentially Vulnerable Areas (PVAs) based on their
respective Benefit Cost Ratios (BCR). Table 3.1 has been extracted from the
Stage 1 prioritisation of flood studies submitted for FRM cycle 2 report from
SEPA:

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Table 4.1 
Flood study title  Scheme ID  Study Location  Flood source  BCR
BCR Class
(* MB increase)
Dunoon Surface Water Management Plan -
Black Park
18 Dunoon Surface water 16.80 1 (VH)
Dunoon Surface Water Management Plan -
Sandhaven
53 Sandhaven Surface water 5.70 1 (VH)
Lochgilphead Flood Study 15 Lochgilphead, Argyll and
Bute
River and coastal 2.31 2 (H)
Oban Flood Study 13 Oban, Argyll and Bute River, coastal and
surface water
2.20 2 (H)
Kilcreggan Surface Water Management Plan -
Tigh Dearg Road
56 Kilcreggan Surface water 1.70 2 (H)
Helensburgh Coastal Flood
Protection Study
17 Helensburgh Coastal 1.33 3 (M)
Tarbert Flood Study 14 Tarbert, Argyll and
Bute
Coastal 1.17 3 (M)
Clachan Flood Study 16 Clachan Village,
Tarbert, Argyll
River 1.11 3 (M)

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4.1.3. It can be noted that the two areas with the highest Benefit Cost Ratio are
located within the Cowal / Dunoon Areas within Argyll and Bute. 
4.1.4. A significant amount of work has been undertaken by the Council under the current
Local Flood Risk Management Plans. 
4.1.5. Works have been undertaken at a number of sites as part of Cycle 2 LFRMPs,
covered in sections 4.2-4.10 and further expanded on in Appendices A & B
which shall be submitted to the Lead Authorities subject to Committee approval. 
4.1.6. Should additional funding be made available from Scottish Government or from
other avenues, schemes are prioritised to allow progress to be made within the
remainder of Cycle 2. 
Study/ Scheme Works 
4.2. CAMPBELTOWN PVA (02/01/27)
Works have been delivered as part a £16 million pound scheme to improve the
surface water drainage in Campbeltown. The works were undertaken over an 18
month period. These works were 80% funded by the Scottish Government and
20% funded by Argyll and Bute Council. 
4.3. OBAN PVA (02/01/22)
Local Authority responsibilities:
4.3.1. All Local Authority duties for which the Council are responsible under the Flood
Risk Management (Scotland) Act 2009 have been carried out: 
4.3.1.1. Watercourse Inspection of Black Lynn Burn and its tributaries carried
out, 
4.3.1.2. No clearance and repair works have been identified which would
substantially reduce the risk of flooding of land due to the condition of
the Black Lynn or its tributaries.  Therefore, no clearance or repair
works can/shall be progressed under Section 18/59 of the Act. 
Additional works carried out to improve Oban’s resilience to flooding:
4.3.2. To improve the resilience of the Lochavullin Car Park pump system, works have
been ongoing since October 2023 and the final element of these works (the
relocation of the pump electrical units) is programme for Q3 2025/26. 
4.3.3. Hydrological study completed by in-house engineers for the Black Lynn Burn. 
The study indicates that dredging of the Black Lynn Burn would not reduce the
risk of flooding of land and that it would risk the downstream culverts being
overwhelmed.  Dredging of the Black Lynn Burn shall therefore not be
progressed. 
4.3.4. Japanese Knotweed survey undertaken and a report is expected to be available
by September 2025.  No works are anticipated to follow this report.

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Permanent Solution:
4.3.5. There is no identified funding for a major works solution at Oban. 
4.3.6. Any permanent Flood Protection Scheme / major works solution would be a long-
term project and likely to run into tens of millions of pounds requiring
attenuation/water storage and general climate change adaptation measures
aimed at mitigating or minimising disruption from severe weather events. 
4.3.7. SEPA’s potential revision of PVAs may affect funding prioritisation and
availability, however the outcome of their recent public consultation on this matter
for Oban is not yet known. 
4.3.8. All opportunities for securing any available funding to accelerate flood protection
works at Oban are being considered. This includes making representations to
Scottish Government seeking to make available funding to accelerate flood
protection works at Oban – including a proposal to progress a scheme separately
in smaller elements/stages, however Scottish Government still to confirm whether
this proposal would risk affecting their 80% funding. 
4.4. ISLE OF BUTE PVA (02/11/23)
Rothesay Flood Study and Flood Protection Scheme (FPS) Performance
Review
This study has been completed. This involved ground multiple on-site
investigations to be carried out such as Ground Investigations of both the areas
adjacent to the shore and the seabed. CCTV surveys were carried out to map
and gather data on the existing drainage network. Recommendations have been
provided 
4.5. HELENSBURGH TO LOCH LONG PVA (02/11/01)
Tigh Dearg Road, Kilcreggan
Works have been carried out to improve the surface water drainage system at
Tigh Dearg Road in Kilcreggan. This involved installing a 600mm surface
water drainage pipe from Argyll Road to the shore and simultaneously
installing a new 150mm sewer for which Scottish Water will adopt. The
completion certificate is expected shorty, after which a 52 week defect period
will apply. 
4.6. DUNOON PVA (02/11/22)
Dunoon Surface Water Management Plans
The schemes will be reviewed and works packages will be issued for works to
proceed should budgets allow. 
The schemes will be split into the respective areas – Black Park and
Sandhaven. 
4.7. Antrim View, Islay
Cooperation/ agreement is being sought from a landowner to reduce flood risk
to local properties, adopted road and their own business property. The Council
have undertaken Phase one of the works to increase culvert capacity in
anticipation of further works being completed by the landowner. Council’s

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Legal department is determining appropriate responsibilities. 
4.8  Flood Monitoring Network
A Flood Monitoring Network is in place which monitors and records water
levels and rainfall at key locations across Argyll and Bute. 
Email and SMS warnings are provided to our operations teams to manage
appropriate responses during flood events or blockages. 
The existing multiyear contract to provide maintenance, telemetry and warning
services is ending and a new contract is being tendered. Multiyear contract
allowed for improved financial forecasting as annual maintenance costs are
known, however breakdown/ failure of equipment has to be managed
appropriately.
Members should note that as part of the routine work carried out by Roads and
Infrastructure Services our teams carry out inspections and clearance of trash
screens, guard and culvert entrances at known areas of potential concern.
Inspections and clearance are generally carried out prior to a known weather
event, this work is designed to maximise the capacity and capability of various
waterways and reduce flood risk. 
4.9. WDM – Web Based Flood Risk Management System (WebFRMS)
A cloud-based Flood Risk Management System, WDM WebFRMS, has been
recently implemented. WDM also provide the asset management system for the
road network, bridge, retaining wall and coastal protection asset stock, street
lighting and other associated assets. WebFRMS allows remote access,
ensures data consistency, streamlines workflows, enhances collaboration and
enhances and assists in the recording and management of:
4.9.1. Flood Incident Recording,
4.9.2. Watercourse Inspections,
4.9.3. Waterbody Assessments,
4.9.4. Schedule of Clearance and Repair Works,
4.9.5. Flood Protection Schemes Asset Register,
4.9.6. Providing resilience for flood and weather events.
4.10. Watercourse Inspections / Waterbody Assessments
The deployment of WebFRMS allows for a clearer approach to prioritising,
implementing and recording watercourse inspections as necessary under the
Flood Risk Management (Scotland) Act 2009 to inform Waterbody
Assessments. 
WebFRMS has allowed for detailed inspection of a number of watercourses –
allowing for river features and observation to be plotted and mapped on the
web-based system. The full implementation of this system will allow for
inspections to be carried out more accurately, more reliably, and on clear
frequency; with frequencies being based on the appropriate risk assessment
of each individual waterbody.

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4.11. Coastal Change Adaptation Plans / Shoreline Management Plans
The Scottish Government has developed a guidance to support local authorities
in preparation of Coastal Change Adaptation Plans. 
Argyll and Bute Council has secured funding from Scottish Government to
conduct case studies for six locations (Campbeltown, Helensburgh,
Garelochhead, Cardross, Rothesay and Kilchattan Bay) based on actions
identified for development of Shoreline Management Plans and Coastal
Adaptive Plans by the Local Flood Risk Management Plan Cycle 2. 
The first stage of the case studies, which involved an initial assessment of all
six areas, focused on understanding the risk of coastal erosion and flooding,
evaluating the associated economic impacts and identifying opportunities for
adaptation initiatives and actions. This stage has been completed. 
The Second stage of the case study focuses on a site-specific study and is
currently at a tendering stage. 
Additional funding has been secured by Argyll and Bute Council via 3
applications to support further Coastal Change Adaptation Plan (CCAP) case
studies for three additional areas: Inverlussa in Isle of Jura, the Isle of Tiree and
Laggan Bay in the Isle of Islay following erosion reports and community
consultation. These new case studies are currently at a tendering stage. 
5.0. CONCLUSION
5.1. This report provides an update on progress with flood risk management activities
across Argyll and Bute including news actions which are in development. 
6.0. IMPLICATIONS
6.1. Policy – Works are in accordance with the Local Flood Risk Management Plan  
2022 – 2028 as endorsed by Council and the Council’s Flood Risk Management
Policy.
Local Authorities have powers under Flood Risk Management (Scotland) Act
2009 “to manage flood risk and to take forward a flood protection scheme.”
6.2. Financial – The current capital and revenue budget allocation is supporting the
ongoing projects activities.
6.3. Legal – Support is requested as required, primarily in relation to riparian
ownership responsibilities.
6.4. HR – None.
6.5. Customer Service – None Known.
6.6. Risk – SEPA currently have issues with recent cyberattack and there is some
risk in terms of times frames.

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6.7. Climate Change – Works are to discharge council’s duties under the Flood Risk
Management (Scotland) Act 2009 and to build resilience against climate
change. 
6.8. Fairer Scotland Duty – None.
6.9. Equalities - protected characteristics – None.
6.10. Consumer Duty – None Known.
6.11. Island Communities – Isle of Bute PVA (4.4.) and Antrim View, Islay (4.7.)
6.12. Children’s Rights and Wellbeing – None Known. 
Kirsty Flanagan, Executive Director with responsibility for Roads and
Infrastructure  
Councillor John Armour, Policy Lead for Roads, Transport and Amenity Services  
September 2025                                                           
For further information contact:  
Andy Summers, Head of Roads and Infrastructure Service
Andy.Summers@argyll-bute.gov.uk  
Elsa Simoes, Infrastructure Design Manager
Elsa.simoes@argyll-bute.gov.uk  
Jamie Salmon, Engineer
Jamie.salmon@argyll-bute.gov.uk 
Appendix A – Actions
Appendix B – LPD Wide