Policy paper

Strategic environmental assessment: statement of particulars

Updated 18 April 2023

Applies to England

1. Introduction

1.1 Purpose of this statement of environmental particulars

This statement of environmental particulars (SOEP) is a statutory requirement under the Environmental Assessment of Plans and Programmes Regulations 2004 (the strategic environmental assessment (SEA) regulations). The SEA regulations require that a statement of particulars is made available as soon as reasonably practicable after the adoption of the Anglian river basin district (RBD) flood risk management plan (FRMP). This SOEP is the final stage in the SEA process.

This SOEP sets out:

• how we have integrated environmental considerations into the Anglian RBD FRMP
• how we have considered the findings of the SEA
• how the opinions expressed in response to the consultation on the SEA environmental report have been considered
• the reasons for selecting the Anglian RBD FRMP as adopted
• how we will monitor the likely significant environmental effects of implementing the Anglian RBD FRMP

1.2 Flood risk management plans (FRMPs)

The second cycle Anglian RBD FRMP is a strategic plan for the period 2021-2027 to manage significant flood risk in nationally identified flood risk areas (FRAs). These are areas where there is believed to be significant flood risk. Producing the plan for these areas and updating them every 6 years is a requirement of the flood risk regulations (2009). It is recognised that there are areas at risk of flooding outside of these FRAs. The Environment Agency and risk management authorities (RMAs) actively plan for and manage the risk of flooding to all communities. This is regardless of whether they are in an FRA or not.

FRMPs highlight the hazards and risks from flooding. They describe how RMAs will work together, and with partners and communities to manage flood risk in the places where we live, work and play.

We have worked with lead local flood authorities (LLFAs) and other RMAs to prepare and develop the final FRMP.

FRMPs:

• align with the national flood and coastal erosion risk management (FCERM) strategy for England and the FCERM strategy roadmap
• describe the sources and risks of flooding within a river basin district
• include information about how RMAs plan to work with communities and businesses to manage and reduce flood risk
• help to promote a greater awareness and understanding of the risks of flooding, particularly in communities at significant risk
• encourage and enable householders, businesses, and communities to take action to manage the risks

FRMPs, together with other plans and strategies, help everyone involved in managing flood risks to make decisions that are best for people and the environment. These other plans include:

• river basin management plans (RBMPs)
• local flood risk management strategies (LFRMS)
• shoreline management plans (SMPs)
• drainage and wastewater management plans (DWMPs)

Alongside flood risk management planning, we work with others to protect and improve the quality of the water environment through river basin management. We have co-ordinated production of the FRMPs and the RBMPs (RBMP 2022) to encourage better join-up in the management of flood risk and the water environment. This will help to deliver more integrated water solutions that help both flood and drought resilience as well as water quality issues. We have worked with LLFAs and other RMAs to develop joint measures in both FRMPs and RBMPs to reduce flood risk and improve the wider water environment. Aligning measures helps to simplify and improve the efficiency of the delivery of outcomes.

The final Anglian RBD FRMP provides further information.

1.3 The SEA process

SEA is a process that ensures consideration is given to the environment during the development of certain ‘plans and programmes’. In doing so, it contributes to the promotion of sustainable development and environmental protection.

Detailed requirements for SEA are set out in the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations). In accordance with the SEA regulations the Environment Agency determined that the second cycle FRMPs required an SEA.

The SEA process requires us to:

• identify, describe and evaluate the likely significant environmental effects of implementing the strategy and any reasonable alternatives
• identify measures to prevent, reduce or as fully as possible offset any significant adverse effects
• provide an early and effective opportunity to engage in the preparation of the FRMP through consultation
• monitor the implementation of the FRMP to identify any unforeseen environmental effects and take remedial action where necessary
• report all the above in an environmental report, drawn up during the preparation of the FRMP and before its adoption.

We published the SEA environmental report together with the draft Anglian FRMP as part of the public consultation. This was held between 22 October 2021 to 21 January 2022. For further information on how the SEA was undertaken and its findings please see the SEA environmental report. You can request a copy of the environmental report from the Environment Agency National Customer Contact Centre.

The SEA recognises that many of the measures in the FRMP are carried over from the first cycle FRMP or are ‘agreed measures’ (measures that are already being implemented) and as such have already been subject to environmental assessment. It also recognises that the strategic nature of the FRMP and many of the measures mean that we’ll need to investigate to decide the nature and extent of flood risk management activity at a project level. As such, at this stage the nature and extent of activity is not known and therefore cannot be assessed. Project level environmental assessments will be undertaken, where relevant, and many will require planning consent.

Our process of business case approval and assurance associated with flood and coastal risk management grant in aid funding, will help to further assure that environmental implications are being considered in the implementation of projects.

2. Integration of environmental considerations into the Anglian RBD flood risk management plan

2.1 Introduction

This section explains how we integrated environmental considerations when developing the FRMP. A number of interrelated activities supported this. These are outlined and relate to the:

• development of the Anglian RBD FRMP
• consultation
• Anglian RBD FRMP SEA
• habitats regulations assessment (HRA)

2.2 Development of the Anglian RBD FRMP

The environment and sustainability were considered throughout the preparation of the Anglian RBD FRMP.

In preparing the FRMPs, we and other relevant RMAs developed 18 nationally consistent objectives for each FRMP in England. In setting the objectives we and other RMAs gave regard to the flood risk regulations’ aims. These are to:

• reduce the adverse consequences of flooding for human health, economic activity and the environment
• reduce the likelihood of flooding

FRMPs are one of many important steps in achieving the ambitions of the national flood and coastal erosion risk management strategy for England (FCERM strategy) and the government’s 25 year environment plan – A Green Future: Our 25 year plan to improve the environment (25 YEP). They also support the direction set by government policy in the FCERM policy statement. These objectives reflect this. Climate change was also taken into account when developing these objectives.

The objectives have been developed to be consistent with the national FCERM strategy ambitions of:

• climate resilient places
• today’s growth and infrastructure resilient in tomorrow’s climate
• a nation ready to respond and adapt to flooding and coastal change

The 25 year environment plan has also been an important influence, in particular, in relation to the ambition:

• to leave the environment in a better state than we found it
• improving the long-term resilience of our homes, businesses and infrastructure at risk of flooding and coastal change
• using more natural flood management solutions

Taking this context into account all FRMPs include the following strategic objectives that specifically deal with environmental aspects:

• objective 6: By 2027, risk management authorities will have worked with communities, landowners and catchment, coastal and estuary partnerships, to identify and carry out schemes which work with natural processes to reduce the risk of flooding and coastal change
• objective 8: By 2027, actions by risk management authorities to address current and future risk of flooding and coastal change will have helped achieve the environmental objectives set out in the river basin district’s river basin management plan
• objective 9: By 2027, risk management authorities will have worked with catchment and coastal partnerships, landowners and managers and communities to make use of nature-based solutions to reduce the risk of flooding and coastal change and contributed to achieving wider environmental benefits
• objective 10: By 2027, risk management authorities will have worked with Natural England and other partners to ensure that the delivery of flooding and coastal change risk management programmes have contributed to the local nature recovery strategies so that new and restored habitats contribute to reducing flood and coastal risk

The Anglian RBD FRMP also includes the following national and FRMP specific measures in relation to environmental aspects.

National measures:

• between 2021 and 2027, the Environment Agency will invest in flood risk management projects in England to contribute to the resilience, adaptation and improvement of the natural, built and historic environment where appropriate across all river basin districts
• between 2021 and 2027, the Environment Agency will plan all flood risk management projects in England to achieve biodiversity net gain where appropriate and wider environmental benefits across all river basin districts
• between 2021 and 2027, the Environment Agency will plan all flood risk management projects in England to help achieve the objectives in the appropriate river basin management plan across all river basin districts
• between 2021 and 2027, the Environment Agency will work with catchment partnerships, communities and other risk management authorities to maximise the use of nature based solutions in England to reduce the risk of flooding from all sources across all river basin districts
• between 2021 and 2027, the Environment Agency will drive down carbon emissions and deliver the required flood risk management outcomes when planning and carrying out flood risk management works in England to achieve its net zero by 2030 target across all river basin districts
• between 2021 and 2027, lead local flood authorities may work with other risk management authorities, communities, and all relevant partners to identify a programme of nature based approaches in their area to reduce the risk of flooding from all sources
• between 2021 and 2027, lead local flood authorities may start implementing steps to work towards net zero carbon in their area to mitigate the effects of climate change
• between 2021 and 2027, lead local flood authorities may plan flood risk management projects to achieve wider environmental benefits where appropriate in their area to work towards biodiversity net gain

Local measures:

In total, 416 measures have been developed for the Anglian RBD. The proposed measures fall under the following elements of flood risk management:

• preventing – avoiding putting people or the environment at risk of flooding
• preparing – taking actions that prepare people for flooding
• protecting – protecting people from the risk of flooding
• recovery and review – learning from flood incidents

More than half of the local measures for the Anglian RBD FRMP are in the protecting category. 22% are in the preventing category. A similar number are preparing type measures. Only a small proportion, 2%, are categorised as recovery and review measures.

Our ambition for the period 2021-2027 is to continue to drive catchment-based delivery in the Anglian RBD that offers multiple benefits to communities and the environment. We worked with LLFAs and other risk management authorities (RMAs) to develop joint measures in both FRMPs and RBMPs. Where possible we have adopted a place-based approach when developing measures for FRAs. We included water and biodiversity objectives wherever possible. The measures encourage partnership working and support wider environmental and growth ambitions.

RBD-scale measures reflect high level strategic challenges and opportunities within the Anglian RBD. Those RBD measures linked to objectives 6, 8, 9 and 10 that deal with environmental aspects across wider areas than the management catchments are:

• between 2021 and 2027, the Environment Agency will work with risk management authorities and water resources east in East Anglia to manage water holistically to achieve a greater level of resilience to both floods and droughts in the Anglian river basin district
• between 2021 and 2027, the Environment Agency will work with catchment partnerships and communities in Essex, Norfolk, and Suffolk to develop projects that can help to reduce the risk of flooding and contribute to the delivery of environmental and water quality benefits in areas where previous assessment has shown that a capital scheme is unviable in the Anglian river basin district
• between 2021 and 2027, the Environment Agency will work with Natural England and local authorities to seek opportunities in East Anglia to align flood risk management projects with the development of nature recovery networks to contribute to the improvement and connectivity of the natural environment and where appropriate achieve biodiversity and environmental net gain across East Anglia in the Anglian river basin district
• between 2021 and 2027, the Environment Agency will investigate opportunities associated with carbon offsetting and biodiversity loss from development proposals in East Anglia to contribute towards flood risk management projects implementing nature based solutions and where appropriate achieve biodiversity net gain across East Anglia in the Anglian river basin district
• between 2021 and 2027, the Environment Agency will continue to work with risk management authorities and other partners to progress the Great Ouse strategic intervention study in the Great Ouse catchment to understand how flood risk can be better managed now and adapted as the climate changes and the catchment faces significant economic growth, how managing flooding and water resources can be better aligned, and how working closer with natural processes can support sustainable growth, the local economy and environment across the Great Ouse catchment in the Anglian river basin district
• between 2021 and 2027, the Environment Agency will develop innovative solutions to reduce and offset carbon emissions from the construction, maintenance, and operation of flood and coastal defences in the Anglian river basin district to help achieve the net zero by 2030 target in the Anglian river basin district

A fifth (85) of all measures for the Anglian RBD are linked to environmental objective 6. Almost a quarter (92) of all measures for the Anglian RBD have the potential to contribute to environmental objective 8. Almost 13% (53) are linked to objective 9. A small percentage (16) have the potential to contribute to objective 10. We will refine our understanding of how individual measures link with objectives during the implementation of the measures. For example, the percentages may increase when measures involving investigations and studies evolve into projects.

Most measures are for either flood risk areas or management catchments. 53% (221) are for FRAs and 31% (127) are at a management catchment level. Many key locations within the RBD show a bias towards the implementation of measures with positive environmental outcomes. For example:

• habitat creation in the Fens and Lowlands strategic area will benefit people and nature recovery and carbon sequestration
• in the combined Essex management catchment there is an over-riding theme of nature-based solutions, and options which improve water quality and the resilience of designated sites
• in the upper Bedford Ouse management catchment, there is a drive towards investigating nature-based schemes with one-third of the measures exploring NFM and blue/green infrastructure across the catchment
• Cam and Ely Ouse management catchment has a similar skew towards NFM investigation with pilot projects explored to increase the resilience of chalk streams
• significant positive effects on landscape are likely from the implementation of measures within the Nene management catchment, which focus on habitat biodiversity, land management and river restoration
• partnership ways of working are common to all FRAs. Engagement measures with landowners and land managers such as RSPB will set a framework for positive environmental outcomes related to flood risk for the future. In the Witham management catchment three quarters of the measures are collaborative.

2.3 Consultation

In preparing the Anglian RBD FRMP we worked in partnership with LLFAs and other RMAs.

A public consultation on the draft FRMPs and associated SEA environmental reports (including the Anglian RBD FRMP and SEA environmental report) ran for 3 months, from 22 October 2021 to 21 January 2022. The consultation ran on the online consultation tool Citizen Space, and we engaged with stakeholders both nationally and through Area teams to encourage responses. We also ran stakeholder events and a social media campaign to advertise the consultation.

We received 255 responses in total. 29 of these were responses applied to all of the FRMPs being undertaken in England, and 29 responses were specific to the Anglian RBD. Responses received were from both individuals and organisations/groups. A range of environmental organisations responded to the consultation including Natural England and Historic England. Overall, there was broad support for the information and measures included in the FRMPs. The responses expressed through the consultation have helped to shape the final FRMP. The summary of response document was published on 18 May 2022.

Sections 4 and 5 below outline how consultation responses were addressed, and the changes made to the FRMP resulting from the consultation. For further information on the consultation responses and how we acted on these responses please see the FRMP You Said, We Did document.

2.4 Anglian RBD FRMP SEA

We carried out a SEA of the Anglian RBD FRMP. This ensured we took environmental effects into account throughout the development of the FRMP. We also took technical, economic and other factors into account.

The SEA environmental report sets out the findings of the assessment. It outlines:

• the likely significant environmental effects of implementing the FRMP and of reasonable alternatives
• mitigation measures to prevent, reduce and as fully as possible offset potential negative effects
• enhancement opportunities to help realise greater environmental benefits

For further information on the SEA environmental report and its findings please see section 3 below, and the SEA environmental report. You can request a copy of the environmental report from the Environment Agency National Customer Contact Centre.

The FRMP sets out how to manage significant flood risk in nationally identified FRAs and how RMAs will work together, and with partners and communities to manage flood risk. It is a framework for RMAs to undertake other plans and individual FCERM projects. Many of these local level plans and projects will also undergo separate environmental assessments. These environmental assessments are at a more relevant scale to consider the potential effects of managing flood risk in different places.

2.5 Anglian RBD FRMP habitats regulations assessment

We carried out a habitats regulations assessment (HRA) in accordance with The Conservation of Habitats and Species Regulations 2017 (as amended) for the Anglian RBD FRMP. The HRA considers the potential implications of the FRMP on designated European conservation sites. These sites contain species and habitats that are important at a European scale. The sites include the following designations: special areas of conservation, special protection areas and ramsar sites.

We have consulted with Natural England in the production of the HRA. The FRMP HRA recognises that many strategies, plans, and projects developed within the framework set by the FRMP will be subject to their own requirements for HRA. This provides a local level framework to appropriately assess the effects of specific risk management policies and actions on European sites. Section 5.3 provides a summary of the conclusions of the HRA.

Read the full Anglian HRA.

3. The findings of the SEA

The SEA environmental report sets out the findings of the assessment carried out as part of the draft strategy preparation. Overall, the assessment identified mainly positive or neutral environmental effects for the Anglian RBD.

The measures developed within the Anglian RBD FRMP aimed to reflect the overarching RBD ambitions to:

• continue to drive catchment-based delivery
• seek multiple benefits to communities and the environment
• meet net zero carbon targets, along with low carbon innovation and carbon offsetting
• achieve biodiversity net gain targets as per the government’s ‘25 Year Environment Plan’
• encourage partnership working

As a result, environmental and sustainability considerations were integral to the development of the measures.

Section 2.4 above outlines how the SEA process informed the preparation of the strategy from an early stage. At the local plan level, we held stakeholder workshops which included discussions on environmental opportunity and challenges as key agenda items. Sustainability issues, adaptation and climate resilience were also considered. Place-based discussions looked at alternative ways to achieve flood risk management objectives for the FRAs with the least adverse effect on the environment. For example, benefits of small natural measures for flood storage were discussed as an alternative to large scale engineered structures. NFM and environmental land management approaches to FCRM were also explored. This flagged a need for increased awareness and capacity building around environmental land management opportunities that has been reflected within specific measures. These conversations and overarching themes helped to shape the final measures which were developed.

A large proportion of measures within the Anglian RBD FRMP set out preliminary actions for the future investigation and development of business case appraisals and options. For these measures further planning processes and supporting environmental assessments will focus on alternatives at a programme and project level. The SEA has concentrated on elements where the environmental assessment has identified that significant adverse environmental effects are likely.

Below is a summary of the key findings of the SEA with respect to potential effects, mitigation, and enhancement. Full details are set out in the environmental report. Where the conclusions identified a neutral effect, this often reflected a mix of positive and negative effects. Often effects were local and not considered significant at a RBD scale.

Table 1: SEA topic, questions and conclusion of assessment

Topic	SEA question	Conclusion of assessment
Biodiversity, including flora and fauna	Does the plan protect and recover nature?	Predominantly positive. Increasingly positive over time.
Population and human health	Does the plan improve health, wellbeing and equality?	Significant positive
Soil	Does the plan improve and sustain resources?	Overall neutral. Positive and negative.
Water	Does the plan protect and improve the water environment?	Overall Neutral. Positive and negative
Climatic factors	Does the plan help to mitigate and adapt to climate change?	Overall Neutral. Increasingly positive over time.
Material assets	Does the plan support communities and a prosperous economy?	Significant positive
Cultural heritage	Does the plan conserve and enhance the historic environment?	Uncertain
Landscape	Does the plan conserve and enhance landscape and seascape character?	Overall neutral
Inter-relationships	Does the plan have implications for the relationship between the environmental topics?	Yes.

Biodiversity, including flora and fauna

The SEA review found that the plan could have both negative and positive effects on biodiversity. It considered effects were likely to be increasingly positive over time. Revised policy and planning requirements for nature recovery and improved biodiversity will drive this positive change. A common theme within the plan is the appraisal of nature-based solutions and partnership schemes that seek positive environmental outcomes. This aligns strongly with the local and national policy context.

The environmental report found biodiversity outcomes from delivery of these schemes are likely to be positive. Positive effects from delivery of the plan will be dependent on these schemes being taken forward and successfully delivering biodiversity net gain. Hard engineered solutions such as those proposed for coastal defence projects are likely to result in local adverse effects on biodiversity. In general, construction activities across all types of schemes may result in local adverse effects requiring mitigation at a project level.

Population and human health

The environmental report found significant positive effects are likely for people living and working within the RBD, including those vulnerable and at risk. Flood protection measures are likely to have significant positive impacts on low lying fenland and coastal communities through reduced flood risk to life and property.

Some FCRM schemes within the FRA seek to achieve urban regeneration. Protecting measures in communities such as Boston and Lowestoft will support economic revival and improved investor confidence. Improved flood forecasting, flood warning and awareness across 9 management catchments and 17 FRAs is likely to have positive impacts on individual community members wellbeing. Nature based schemes were also likely to impact positively on health and wellbeing.

Some localised negative effects on communities will result from delivery of the plan but these can be managed at a project level and are not likely to impact at a RBD level.

Material assets

Measures are providing flood protection to key industries and prime agricultural land. Farming in the Anglian RBD is of fundamental and increasing importance to national food security. Protecting measures in coastal areas will benefit critical alternative energy and international port infrastructure. Tourism dependant economies which are particularly volatile will also benefit from positive outcomes. The environmental report did not identify any potential significant negative effects on material assets from delivery of the plan.

Soil and Water

The SEA found both positive and negative effects were likely on the soil and water environment from implementation of the plan. Specific NFM, environmental land management and catchment sensitive farming interventions may contribute positively to protecting and conserving the soils within the RBD and improving resilience to degradation. These activities are also likely to reduce run-off and improve water quality and groundwater recharge. Habitat restoration and rewetting the fens will also be beneficial. There is interaction from these types of measures, linking improved soil, WFD delivery and nature recovery.

More traditional approaches to FCRM delivery, surface water management and maintenance schemes are likely to result in a negative effect on both soil and water. These approaches include sediment management, artificial structures and embankment raising.

Climatic Factors

The environmental report considered the effect of the measures on climatic factors is likely to be increasingly positive over time as the Environment Agency and Local Authorities embed net zero targets and trial climate innovation. Collectively the measures were found to convey the need to manage and adapt to flooding and coastal risks related to climate change.

In the context of the climate crisis some specific protecting measures may result in significant negative effects unless net zero objectives are realised. For example, the manufacture of construction materials used within tidal barrier and coastal schemes traditionally generates high levels of carbon dioxide emissions. Investment in carbon offsetting may be a requirement at a project level.

Potential positive effects were associated with increased carbon sequestration related to peatland restoration in the fens and other local NFM and habitat restoration type measures. Local NFM and habitat restoration type measures that involve planting activities, or creation of saltmarsh will impact positively on the climate.

Other measures such as planning and development controls; modelling; and recovery and review actions support the adaptation to climate change.

Cultural heritage

Most measures within the plan are likely to have either a neutral or uncertain effect on cultural heritage. This is mainly due to the uncertainty of works proposed at this stage. Any excavation work that involves groundworks has the potential to uncover or destroy archaeological remains. These risks are currently uncertain and will depend on the heritage sensitivities of the local area likely to be affected. The effects of property level resilience (PLR) measures are also uncertain. They can have an adverse visual effect but can contribute to long term protection.

The plan includes measures that encourage risk management authorities to improve the natural and historic environment through their flood risk management plans and projects. This is anticipated to have a significant positive impact on cultural heritage at a local level.

Landscape

The SEA found the overall effect on landscape is likely to be neutral. There are unlikely to be any significant negative impacts from implementation of the draft plan. The assessment of national and local measures shows the potential for both positive and negative effects on the character of urban and rural landscapes. As with cultural heritage, measures linked to the delivery of flood risk management activities and solutions have the greatest potential to affect landscape character. Partnership working arrangements have the potential to deliver amenity and education benefits.

The environmental report references possible positive effects from capital works that implement blue/green infrastructure, SuDs and NFM (such as in Alconbury and Chelmsford). Blue/green infrastructure projects are generally landscape-led and can provide multiple benefits to people, wildlife and water management.

Interrelationships and cumulative effects

Interrelationships among the topic areas were identified during the assessment. Measures that enhance biodiversity have clear benefits to soil and climatic factors. Measures that support green infrastructure and habitat creation are also likely to enhance carbon sequestration. There are interrelationships with landscape across many of the topic areas.

Measures impacting conservation areas such as those in Boston show interactions between cultural heritage and landscape. Measures that enhance local landscapes also support biodiversity, recreation, and wellbeing. A natural capital approach used during the project level appraisal process would enable these interrelationships to be identified and support the delivery of these benefits.

Section 6.6 of the SEA environmental report concludes that the plan aligns well with other relevant plans programmes and strategies. There is a clear intent to adopt nature-based first principles and deliver on the ambition of the national environment plan, ‘A Green Future’.

The Anglian RBD FRMP has been developed in direct alignment with the National FCERM strategy. High level links with the shoreline management plans (SMPs) for the Anglian RBD coast (SMP3 through SMP 8) were also taken into account The Environment Agency has co-ordinated production of the Anglian RBD FRMP and the Anglian river basin management plan (RBMP) updated 2022 (RBMP 2022) to encourage better join-up in the management of flood risk and the water environment. This will help to deliver more integrated water solutions that help both flood and drought resilience as well as water quality issues.

Interaction with the Anglian water, water resource management plan 2020-2045 provides potential to integrate water resource management with flood risk planning and create wider benefits going forward. The drainage and wastewater management plan (DWMP) is scheduled for the period 2025-2050. Delivery will result in little or no cumulative effects with the FRMP as activities to 2027 will focus on engagement. A long-term measure has been included within the FRMP for EA to work together with Anglian water to develop and implement strategic plans. The overall ambition is to create a combined vision and joint strategies for future flood risk management.

Measures are incorporated for the strategic area of the OxCam arc and overall alignment of the plan with the OxCam arc is likely to be positive. Likewise the measures for the Fens and lowland strategic area reflect a partnership approach and positively support next steps for the evolving Fens 2100 strategy. The planned Boston to Peterborough wetland corridor will have clear interaction with the measures in the FRMP for Boston and Spalding FRAs and the wider Witham and Welland catchments. The proposal could potentially result in flood relief for the area and the creation of a significant new wetland corridor could contribute to wider biodiversity, wellbeing and amenity benefits.

National processes driving mitigation and enhancement

Mitigation and enhancement opportunities are largely driven by national processes. This helps set a level of aspiration for sustainable outcomes and provides a delivery framework and enabling environment to achieve them. Examples include:

• targets for net zero carbon by 2030 and delivery of 20% BNG as set within the Environment Agency’s sustainable business strategy, eMission 2030
• independent assurance of the Environment Agency’s environmental management system to ISO14001
• the Environment Agency’s area sustainability plans which embed sustainable development principles within the design and delivery of FCERM schemes
• the use of BREAM Infrastructure (formerly CEEQUAL) to embed sustainability within the appraisal, design and construction process - this supports solutions that offer wider benefits and drives responsible delivery
• partnership working on both Environment Agency led and LLFA led schemes - consultation and engagement will ensure positive environmental outcomes
• the Environment Agency has an established, robust approach to environmental assessment and management across its capital programme. Adherence to minimum technical requirements for environmental design and management is a contractual obligation
• all Environment Agency projects will have an environmental action plan (EAP) produced. The EAP clearly identifies ecological risk and measures needed to mitigate and manage them. An environmental clerk of works may be employed to actively ensure the EAP is implemented where risk is higher
• the delivery of flood projects is subject to rigorous assurance
• an understanding of robust environmental baselines early in the appraisal process is key to informing potential opportunities and reducing environmental risk. Use of biodiversity metrics will be important to ensure delivery on BNG goals. Establishing early heritage baseline is important to inform the archaeological significance of a site
• landscape visioning is promoted and used on relevant schemes to identify high-level goals for landscape restoration and enhancement - it has successfully supported stakeholder engagement

Mitigation

The assessment has shown that adverse effects of the Anglian RBD FRMP are primarily local in nature. Adverse effects will depend upon the nature and design of works taken forward for a particular location as well as local environmental sensitivities. This highlights the importance of undertaking local level environmental assessment of strategies, plans and projects where relevant. EIA processes will support mitigation of negative effects from protection works at a project level. Local level assessments will help to identify ways to avoid, reduce or mitigate any potential negative effect.

A range of mitigation measures to support the delivery of FCERM proposals are highlighted within the SEA environmental report with some key considerations summarized below.

The environmental report recognises that RMAs will need to comply with legal requirements for protecting and enhancing the environment. Consenting and licensing processes will ensure mitigation measures are applied to any likely effect on designated sites and protected species and habitats. In areas with the presence of SPA and SAC designations, careful programming of works must consider the risk of disturbance to over wintering and nesting birds. Due regard to obligations under the eel regulations will improve fish and eel passage and include consideration for fish friendly infrastructure for pumping stations. Negative environmental effects from the construction phase of maintenance and minor works will be mitigated through standard environmental management and best practice. Good practice application of pollution prevention standards and legal compliance with the water framework directive will help to mitigate any adverse effects on the water environment. Adverse effects on soil will be supported through good practice techniques for stripping, stock piling and spreading soil and sustainable sourcing of materials.

Adopting the mitigation hierarchy as a design principal at the project level is key across the topic areas. Areas of environmental sensitivity and conservation designations should be avoided as far as possible. The design stage should aim to design out the need for materials that impact heavily on the environment.

Driven by policy and contractual requirements, contractors are already taking steps to alleviate carbon impacts on FCRM schemes. Innovation has supported the move to net zero carbon for example in the delivery of low carbon concrete and use of carbon negative aggregate. Energy choices for compound and welfare unit facilities should be driven by low carbon/climate neutral preference.

Similarly, net zero carbon ambitions should be applied across the supply chain, and to all transport and travel decisions. There is some uncertainty that the appropriate mechanisms will be fully in place to effectively measure and mitigate operational and whole life carbon impacts within the life of this plan. Thus, mitigation for large scale schemes with likely significant effects may need to focus on carbon offsetting in the short term.

The association of drainage authorities plans to develop existing carbon calculator tools to help the internal drainage boards with carbon emissions reduction.

The Environment Agency and local authorities have set their own ambitious carbon targets and have refined measuring and assessment tools. Use of a carbon planning tool is embedded within the project assurance process within the Environment Agency and its use is best practice by other RMAs.

There is a national policy impetus towards nature recovery with legal requirements for BNG. To support the NFM initiatives being explored there will be funding opportunities. For example, through the nature climate fund and other incentives related to the Environment Bill.
Exploring water attenuation as a flood risk option presents the opportunity to work with stakeholders to integrate water management with flood risk prevention, especially in areas where agriculture is dominant. The bias is towards nature-based attenuation as the preferred option. Soft solutions for embankments, and coastal solutions which work with nature should be explored as the default.

Adverse impacts that can result from NFM measures during both construction and operation phases must be considered. For example, suitable site selection is important for pond creation. Pond creation on land of existing high conservation value should be avoided. NFM effectiveness may also vary based on environmental factors such as soil type, topography and climate. Gaining an understanding of the rich diversity of invertebrates and botanical species present along the coastal defences should be included in survey work. This will help to identify mitigation actions and opportunities to improve nature recovery.

For measures which include tree planting, it is important to select the right trees for the right place. The positive effects on biodiversity can be enhanced through species selection with careful attention to appropriate provenance.

For capital maintenance works project teams are encouraged to work with land managers to find alternatives to desilting. For example, exploring methods to reduce soil erosion and sediment transfer. Maintaining green buffers to waterways is a simple mitigation. An adaptive management approach is also recommended.

Opportunities

Opportunities to support local ambitions and increase positive effects are described within section 5.1 through to section 5.8 of the SEA environmental report. A number of enhancement proposals were similar across multiple SEA topics considered within the assessment. There are clear opportunities within the Anglian RBD to

• link flood defence works with urban regeneration, amenity improvements and local ambitions for sustainable transport and blue/green corridors
• enhance fish passage, improve habitat and deliver BNG through green/natural design elements and soft engineering
• deliver on the statements of environmental opportunity of national and local landscape character assessments
• prioritize urban and rural SuDs for town and agricultural environments
• reduce the number of conservation areas, listed buildings, scheduled monuments and historic parks and gardens at risk of flooding and promote heritage education

Early conversations with stakeholder groups can identify opportunities and synergies for long term environmental benefit. Improved modelling and flood risk data will help to launch discussions with private sector partners to invest in flood risk planning and protection. Risk management authorities (RMAs) are encouraged to work with land managers to find innovative and holistic solutions for flood risk management.

4. How opinions expressed in response to the consultation have been taken into account

4.1 Introduction

The consultation on the draft Anglian RBD FRMP and the SEA environmental report took place between the 22 October 2021 to 21 January 2022. This section only refers to the views expressed in relation to the SEA environmental report. It summarises the key issues raised in the consultation and how we have taken them into account in finalising the Anglian RBD FRMP. Almost half of the responses were from environmental management organizations. The ‘you said, we did’ document provides a full outline of the responses received on the draft FRMP and outlines how we took them into account in finalising the FRMP.

The consultation included questions on the SEA environmental report. The questions asked the following:

• do you agree with the conclusions of the environmental assessment?
• are there further significant environmental effects, either positive or negative, of the draft flood risk management plans (FRMPs) which you think should be considered?
• are there further opportunities to enhance any positive or mitigate any negative environmental effects that should be considered for the final FRMPs?

Of those respondents that answered, the majority (75%) agreed totally or partially with the conclusions of the environmental assessment. The lack of detail on the delivery of measures was flagged as a challenge. A need for further local level assessments as plans or projects progress was identified.

Over a third of the respondents that answered were satisfied that negative and positive effects had been adequately addressed. One third felt that there were other significant effects to consider. Just over 50% felt that there were further opportunities to enhance potential positive effects and mitigate negative effects. The points raised through the consultation are detailed in 4.2 below.

4.2 Cross cutting themes

Many of the responses received in relation to the SEA environmental report relate to the content and measures within the FRMP and were cross cutting across the FRMPs. Cross cutting themes raised through consultation are discussed below, alongside our response to these. Please see the ‘you said we did’ document for further information.

Historic environment

Historic England outlined the importance of the historic environment in place-shaping, local and cultural identity and how it can support the resilience of places and people. Whilst heritage assets and the historic environment can be affected by flooding and flood risk management, they can also play a positive role through, for example, supporting community engagement with flood risk management, learning from traditional water management practices and living with water. There are opportunities for the historic environment to support natural flood management and help build climate resilience and adaptation to flooding and coastal change.

Historic England described how it was important to consider how FRMP measures impact on the historic landscape character and sense of place, as well as specific designated assets. Both direct and indirect effects (for example, through water level changes or mitigation measures for other environmental effects), both positive and negative effects, of flood risk measures should be considered. They would like to have increased collaboration and early engagement as measures progress to ensure that effects are adequately assessed, and opportunities maximised.

Historic England outlined the need for strengthened objectives and measures within the FRMPs to provide a consistent strategic approach to the integration of flood risk management and the historic environment. This should be consistent with the requirements for conserving and enhancing the historic environment set out in the national planning policy framework.

The SEA undertaken was proportionate to the strategic nature of the FRMP and many of the measures mean that we’ll need to investigate to decide the nature and extent of flood risk management activity at a project level. As such, at this stage the nature and extent of activity is not known and therefore cannot be assessed with any certainty. Project level environmental assessments will be undertaken, with Historic England and other relevant stakeholders consulted early in the process. The assurance of project proposals provides additional safeguards that make sure environmental implications are considered in the implementation of the second cycle FRMP.

Within the FRMP itself the national measure relating to historic environment has been strengthened to include resilience and adaptation as well as improvement to the natural, built and historic environment. This measure appears in each FRMP and reflects the national FCERM strategy measure. The updated measure can be seen below:

Between 2021 and 2027, the Environment Agency will invest in flood risk management projects in England to contribute to the resilience, adaptation and improvement of the natural, built and historic environment where appropriate across all river basin districts.

The national FCERM strategy roadmap and delivery plan will support the delivery of this FRMP measure and we will continue to work with Historic England and other partners to achieve this.

The wording in relation to early engagement and partnership working has also been strengthened, with further detail provided on our partnership approach.

Biodiversity and designated sites

Consultees outlined that an HRA should be undertaken, and that it is important to consider the impact of the FRMP on protected sites, priority habitats and protected species. Natural England felt that the SEA documents lacked detail and documentation which made it hard to understand how the assessment had been undertaken and on what basis, this was particularly with respect to designated sites. In addition, it was suggested that the SEA assessment criteria with respect to biodiversity should be strengthened to include the consideration of conservation objectives associated with designated sites and that the SEA should provide details on favourable condition tables, site improvement plans and supplementary advice on conservation objectives (SACOs).

Natural England identified that many schemes and measures carried over from the previous FRMP cycle have been indicated as not requiring an SEA at the scheme level due to no significant changes in the design. They were concerned that this approach does not consider changes in the ecological and policy context that may have occurred since the first cycle FRMP leading to potential environmental effects not being mitigated.

We have carried out an HRA in accordance with The Conservation of Habitats and Species Regulations 2017 (as amended) for the Anglian RBD FRMP. The HRA considers the potential implications of the FRMP on designated European conservation sites and provides figures to show the locations of these sites. These sites contain species and habitats that are important at a European scale. The sites include the following designations: special areas of conservation, special protection areas and ramsar sites. Please see section 5.3 of this report for further information on the conclusions of the HRA for the Anglian RBD FRMP.

The SEA undertaken was proportionate to the strategic nature of the FRMP and many of the measures mean that we’ll need to investigate to decide the nature and extent of flood risk management activity at a project level. Many strategies, plans and projects developed within the framework set by the FRMP will be subject to their own requirements for environmental assessment and HRA and will be subject to planning or other consenting regimes. This provides a local level framework to appropriately assess the effects of specific risk management policies and actions on designated sites and biodiversity, including project specific design considerations.

For the second cycle FRMP SEA we revised and updated the baseline and policy context used to ensure that the latest information was being used to set the scope and assess effects. When deciding which measures to assess within the detailed assessment of individual measures or considered as part of a cumulative assessment, the type of measure and the nature of the activity involved was considered.

• Measures that were carried over from the first cycle FRMP and were already being implemented or constructed were considered in the cumulative assessment.
• Measures which were yet to be implemented but had not changed significantly were considered in the cumulative assessment. This is because they had previously been through the SEA process. Updated baseline and policy context was taken into account during the assessment of cumulative effects.

The SEA methodology is outlined in further detail within the SEA environmental report.

Agriculture and land management

FRMPs will help to create a better place for people and wildlife. Consultees considered that when assessing and managing flood risk, there is a need to consider all land uses and land management practices. Adequate integration with planning to achieve more sustainable development was also raised.

The recognition of the importance of agricultural land in the SEA was appreciated. However, some respondents considered that the benefits that the farming community and agriculture bring should be better represented in the FRMPs. These include economic and environmental benefits, ecosystem services, biodiversity, carbon sequestration, water quality, landscape character, recreation, and tourism. These benefits could be jeopardised if agricultural land is regularly flooded.

Consultees highlighted that the land use change impact on food production should be a key consideration that the FRMPs should cover. They explained that there needs to be a balance between flood risk management, including natural flood management, land use change and agricultural land loss. They wanted more consideration of the value of agricultural land regarding future flood protection and food production. There were also concerns that using agricultural land for flood protection could have serious implications for the economy.

References to land management have been updated within the FRMP to provide additional information and emphasis on the significance of flood risk to agricultural land and food production. Wording has also been strengthened in relation to partnership working.

The FCERM strategy roadmap also includes actions that will support farmers and landowners to help adapt their businesses and practices to be resilient to flooding and coastal change. It outlines how we will work with others to develop land management practices that enhance flood resilience alongside sustainable food production.

Nature-based solutions

Comments related to nature-based solutions were primarily focused on the FRMP itself. They were focused on:

• the positive benefits of nature-based solutions
• the need for a balance between nature-based and engineered solutions
• the need for alignment with the national FCERM strategy

Please refer to the ‘you said we did’ document for our response to these comments and the changes made to the FRMP.

Catchment-based approach

Comments related to catchment-based approaches were primarily focused on the FRMP itself.

There was broad support for existing measures and a greater emphasis on a catchment- based approach for flood risk management. It was suggested that the focus on flood risk areas within the plans appears inconsistent with a catchment- based approach, which is vital to manage the movement and storage of water at the catchment scale and to maximise the use of nature- based solutions and looking at flood risk management more holistically. Consultees set out the need for collaborative working to optimise the benefits of a catchment-based approach. Please refer to the ‘you said we did’ document for our response to these comments and the changes made to the FRMP.

Alignment of plans and strategies

Respondents outlined the need for greater clarity as to how the FRMPs fit with other plans and strategies (including, the national FCERM strategy, RBMPs, local nature recovery strategies, drainage wastewater management plans, shoreline management plans). They considered the alignment of strategies and plans to be essential to ensure a comprehensive approach and effective delivery.

The alignment between FRMPs and RBMPs was welcomed to optimise environmental opportunities and benefits.

Please refer to the ‘you said we did’ document for our response to these comments and the changes made to the FRMP.

SEA plans, policies and programmes review

Some consultees proposed additional plans, policies and programmes for consideration in relation to the SEA. These included the chalk stream restoration strategy and the UK peatland strategy, details of which are summarised below.

Chalk stream restoration strategy (CaBA, 2021)

A plan to address the ecological health of chalk streams across the UK. It considers three main themes alone and in combination: water quantity; water quality; and physical habitat quality. Recommended actions across a range of organisations are proposed to strengthen the protection for chalk streams. New actions and improving actions in existing plans, policies and programmes are proposed. These include RBMP measures, catchment abstraction and wastewater treatment. Nature based solutions are promoted in chalk stream catchments. The FRMP aligns with and supports the actions set out in the chalk stream restoration strategy, in particular regarding objectives and measures relating to natural flood management, catchment-based approaches, and partnership working

The UK peatland strategy (IUCN, 2018)

The UK peatland strategy aims to capture and embed a shared vision for peatlands across the UK. It has a 2040 vision that ‘Our peatlands are protected, enhanced, sustainably managed and are recognised for their intrinsic value and the public benefits they provide’. It sets out six key goals to support the achievement of the 2040 vision:

• conserve, restore and enhance the best peatlands
• restore damaged peatlands to functioning ecosystems
• adapt management of drained peatlands
• sustainably manage healthy peatlands with compatible land uses
• maintain a programme to oversee process against strategic goals.
• communicate value of peatlands to a wide audience

The FRMP aligns with the strategy, in particular with regards to objectives and measures relating to natural flood management, catchment-based approaches and working in partnership. There are also specific measures regarding peatland areas, where relevant.

In summary, the FRMP aligns with both strategies and aims to work with natural processes to deliver flood risk management. It also outlines how we will work in partnership with others and use catchment-based approaches to maximise outcomes.

4.3 Themes specific to the Anglian RBD FRMP

Climate change

Most respondents agreed totally or partially that the FRMP considered the likely flood risk impacts associated with climate change. It was noted that the environmental report stressed the important roles of peatlands, saltmarsh and wetlands for carbon storage.

The recognition of potential adverse impacts that flood risk management activities on these habitats was welcomed. The need for more emphasis on the opportunities presented by flood-risk management activities and mitigation actions to adapt to climate change was raised. It was felt that greater ecosystem-based adaptation focus was needed. For example, creating wetlands as a buffer against flooding and tree planting to promote cooling. One respondent questioned whether the impacts of the measures on the ability for wildlife to adapt had been considered.

The climate benefits of peatland restoration were raised as being particularly relevant to the Anglian RBD. The consultation highlighted increasing environmental pressures from climate change and a greater urgency to act.

Comments included more research to understand the impacts of climate change and how land management can support climate adaptation. Impacts of wetter winters leading to surface water flooding and prolonged rainfall/heavy storm events impacting sewage networks were noted as requiring more attention.

Comments have been considered in the revisions to the Part B narrative. Recent modelling data predictions on peak river flows have been included to inform predicted fluvial flooding. Additional text has been included on the multiple benefits of natural flood management and nature-based solutions. More details have been added in Part B on the multiple initiatives underway in the Fens to deliver resilience and adaptation to the changing climate.

It is expected that up-to-date information on climate will be used during delivery of the measures. Within the SEA methodology climate change questions assessed whether the plan supports adaptation to the wider effects of climate change and whether the plan provides carbon benefits.

Positive effects on carbon from individual measures such as peat restoration and others that support carbon sequestration were noted. Local NFM and habitat restoration type measures that involve planting activities, or creation of saltmarsh were assessed as impacting positively on the climate. Measures that support habitat enhancement, BNG and improved water quality were assessed as improving the resilience of wildlife to adapt to climate change.

Section 6.4 of the SEA environmental report also noted that Preventing and Preparing measures help support community adaptation to climatic factors.

Making people and places resilient to climate is a key pillar of the national FCERM strategy. The FCERM roadmap to 2026 includes an objective for new approaches to conserve protected sites, species and natural landscapes that enable adaptation to sea level rise and a changing climate.

The Environment Agency flood and coastal erosion risk management (FCERM) appraisal guidance has recently been updated to make it easier for risk management authorities and partners to produce business cases for projects that improve resilience to flooding and coastal change. This should help to mainstream ecosystem adaptation approaches within the optioneering and appraisal process of local level FCERM plans and proposals. This is an important opportunity given the high proportion of appraisal and feasibility measures which are included within the Anglian RBD FRMP.

Agriculture and land management

Land management was a key theme of the Anglian RBD FRMP consultation response. Farming and agriculture are specific areas of comment. The high value of the agricultural land within the Anglian RBD was highlighted by respondents.

The consultation raised concerns that impacts of measures on food production needs more recognition within assessments. Also, that NFM or nature-based solutions may result in the loss of agricultural land. There was general support for measures that protect valuable agricultural land. Agri-environment measures that work alongside farming and food production to achieve additional environmental benefits, including flood risk were supported.

The consultation noted that the positive role of future agri-environment land management schemes is flagged within the SEA environmental report.

Other concerns of relevance to the Anglian RBD were linked to the historical role of land drainage. Increased rates of run-off, flow rates and sedimentation of the deepened, straightened waterways increase flood risk. More engagement with risk management authorities (RMAs) and farmers was suggested to improve the delivery of FRMP measures. Engagement measures to support landowners are included within the Anglian RBD FRMP and have been considered as part of the overall strategic assessment.

The national measures include specific reference to the Fens and will address the issue of proper and appropriate valuation of agricultural land which was welcomed by the respondent. In response to the consultation additional information recognizing the value of agricultural land has been incorporated within the agriculture and land use section of Part B. The key role of agriculture in flood management is noted. Landowner engagement and the need for partnership working has been reiterated. When assessing significant impacts of the measures, the importance of the region’s agriculture to the national economy has been considered within the SEA.

Agriculture’s future role in adaptation to climate change and sustainable management of water and soil was also considered within the environmental report. The FCERM roadmap to 2026 also supports the work of the future Fens: integrated adaptation taskforce, which is developing ways of adapting to flooding and drought in low lying, agricultural catchments within the Anglian RBD. During plan delivery it will be important to consider agricultural land value within FCERM appraisal and decision-making.

The updated green book project appraisal guidance directs users to embed a natural capital approach into the appraisal process. This will allow for a better local understanding of the impacts to people and wildlife and the wider benefits of a scheme.

As noted within the consultation, the results of the DEFRA environmental land management scheme (ELMs) pilot will be beneficial to guide future project level decision making.

Engagement and partnership

Engagement and partnership measures are included within the Anglian RBD FRMP. The respondents welcomed the opportunity to work in partnership and support the delivery of FRMPs. The strategic flood alliance in Norfolk was raised as a good example of a recent focussed effort to improve resource coordination and effectiveness of RMAs and other bodies.

The FRMP and the SEA environmental report acknowledge the value of working in partnership. Integrated working is instrumental to the roll out of the national FCERM road map. In response to the consultation some additional text has been added to Part B to strengthen this commitment. Stakeholders include catchment and coastal partnerships, water companies, flood action groups, internal drainage boards, and other community and environmental groups. Early stakeholder engagement and community involvement are notable actions flagged within the environmental report to maximize sustainable outcomes associated with FCRM activity.

The EA has recently adopted the stakeholder engagement risk assessment (SERA) tool for implementation on capital schemes to identify stakeholder engagement risks early in a project life cycle and prioritise stakeholder engagement and resources.

Nature based solutions

Responses generally indicated support for NFM and agreement on associated positive environmental effects. Appropriate siting, and costs of managing and maintaining NFM measures over the long term was flagged. It was felt that NFM measures needed to be part of a cohesive and carefully planned package of measures across the catchment looking at both upstream attenuation and downstream conveyance to address shorter- and longer-term flood risk. Loss of good quality agricultural land to large scale NFM opportunity was noted as a potential concern relevant to the Anglian RBD.

In response to the consultation additional narrative has been included in Part B relating to appropriate NFM and the outcomes of the NFM programme. Project level assessment as detailed in the section on land management above will play a key role to ensure the delivery of appropriate NFM and avoid and mitigate adverse effects.

Catchment based approach

The consultation indicated support for a catchment-based approach. This would align with the approach taken with other water-related plans and projects within the area. One respondent felt that some individual measures within the plan have not taken an obvious catchment level approach. An example was provided from the combined Essex management catchment of a highway widening project upstream potentially impacting NFM initiatives downstream. There was a concern that the assessment of catchment level impacts reported within the environmental report lacked clarity.

The diverse type and scale of measures represented within the plan is a result of the complex and tiered nature of the FRMPs. Although holistic approaches to flood risk management may not be explicitly referenced within individual measures, partnership working, and early engagement will be key to driving an integrated approach. Collaborative working is needed to deliver the benefits of a catchment scale approach. The Environment Agency is committed to working with catchment partnerships and other stakeholders. This is reflected in the engagement and partnership measures included within the Anglian RBD FRMP. Part B of the Anglian RBD FRMP has been updated to reiterate the ambition and benefits of catchment-based delivery.

The nature of the FRMPs influenced the approach taken to the assessment. The environmental assessment for significant effects undertaken for measures in key locations fed into the overall assessment. The large number of measures within the plan which are early exploratory and feasibility stage actions have resulted in uncertainty around delivery and on the ground effects. The strategic nature of the plan means that further investigation and assessment of environmental effects will be required at a project level. At a project level, business cases will consider local catchment-scale strategies and management plans. Cumulative effects with other upstream and downstream initiatives will also be explored during project level environmental assessment.

Links with other plans and projects

The consultation process has raised the need to align with other national and local plans and projects, so delivery is more effective. Strategies and plans of relevance to the Anglian RDB FRMP include the 2021 chalk stream strategy launched by catchment based approach’s (CaBA) chalk stream restoration group (CSRG) and the UK peatland strategy as noted in section 4.2 above.

Other local level plans and projects noted in the consultation include:

• east inshore and east offshore marine plans which provide a clear approach to managing the marine resources of the east coast from Bridlington to Felixstowe to ensure sustainable development - the environmental report notes that the plans point to offshore wind farms, to help achieve the UK carbon reduction goals
• diffuse water pollution (DWP) Plans which agree catchment-scale measures to tackle diffuse water pollution pressures within the plan area. They are primarily concerned with improving water quality and DWP impacts to Natura 2000 sites.
• the Cranbrook / counter drain FRM strategy which aims to deliver multiple benefits including flood water storage
• restoration work led by the Broads Authority under the government’s nature for climate peatlands discovery grant scheme.

The Environment Agency has co-ordinated production of the FRMPs and the river basin management plans updated in 2022 to help to deliver holistic, integrated water solutions. Measures within the Anglian FRMP have been included to address water quality issues and diffuse pollution. The HRA has concluded that many of the measures involve natural flood management approaches which are likely to reduce diffuse pollution from agriculture. As a response to the consultation Part B of the Anglian RBD FRMP has been updated to include information on the Broadlands future initiative and the Future Fens initiative. The measures within the Anglian RBD FRMP which encourage joined-up working will help to deliver more integrated water management solutions that align with those local plans and strategies noted within the consultation.

Monitoring

There seems to be a general agreement with the conclusions of the SEA. However, consultation has pointed out that the high level of content and lack of detail increases the importance of environmental assessment and monitoring as projects progress. There was agreement that the solutions should follow an adaptive approach as proposed. However swift action was encouraged to adopt and deliver those measures with potentially positive environmental effects. A high priority was placed on monitoring delivery of those schemes with potential wider benefits. The challenges associated with monitoring the effects of wider benefits was acknowledged. Further assessment at a later stage of the FRMP cycle to improve understanding of the potential significant environmental effects of implementing the proposed measures was welcomed.

Some dissatisfaction was expressed with regards to the monitoring plan outlined within the environmental report. The monitoring plan for the water environment was felt to be limited. One consultation respondent suggested the following to more effectively monitor the water environment:

• impedance of flow
• barriers to ecology
• the impact of FRM activities on hydrological processes
• surveys to monitor significant effects on water-dependent habitats and species

The importance of water dependant habitats within the Anglian region is acknowledged within the SEA environmental report and the HRA. The proposed monitoring of the water environment is based on mechanisms in place to meet the requirements of the water environment regulations. Those wider elements monitored beyond water quality will need further clarification at a project level. Impacts of FRM on hydrological processes, flow, fish passage etc will be assessed during project appraisal through Water Environment (Water Framework Directive) Regulations 2017 compliance assessment. See Section 6 below for details on monitoring of the final Anglian RBD FRMP.

5. Reasons for adopting the Anglian RBD FRMP

5.1 Introduction

This section provides an outline of the main factors taken into account in finalising the Anglian RBD FRMP. The main factors include the:

• findings of the SEA process as described in the environmental report including the assessment of reasonable alternatives
• consultation responses to the draft FRMP
• consultation responses to the environmental report
• findings of the final HRA

In section 5.2 below we summarise the main changes made to the FRMP as informed by the consultation. In section 5.3 we outline the relationship to the SEA process.

5.2 The final FRMP

A variety of changes have been made to the FRMP including the supporting text in Part A and Part B and to measures. Changes have also been made to the flood plan explorer (FPE).

The types of measure changes can be split into three categories:

• wording/supporting information for existing measures
• geographical extents
• measure(s) to be added or removed

When considering proposed changes, we assessed the associated environmental effects as part of the SEA. This enabled us to understand the environmental effects of changes and to feed into the decision as to whether to implement changes. We agreed the changes with relevant partners before making them.

We made changes to the functionality and maps on the FPE to make finding information easier, particularly in places where there are many measures near to each other. We also created a guide to support FPE navigation.

There were a number of cross cutting themes from the consultation on the draft FRMP, which led to changes across all FRMPs. The changes reflect areas where responses identified common themes for improvement, or which needed to be further clarified. Some of the general changes we have made include:

• explaining more about our approach and commitment to partnership working
• expanding on the information about NFM including its types, benefits and outcomes
• providing additional details about the role of Catchment partnerships and the importance of the catchment-based approach
• clarifying how the FRMPs align with other plans and strategies including the national FCERM strategy and RBMPs
• greater clarity on the historic environment, with a change to a national measure to include adaptability and resilience of the historic environment, and additional wording to explain how we will work with others to maximise opportunities and minimise effects.
• providing additional information on the significance of flood risk to agricultural land and food production
• increased clarity with regard to climate change and the contribution of FRMP measures to climate resilience
• explained the methodology used to identify FRAs the preliminary flood risk assessments and provided clarification that no groundwater FRAs have been identified
• greater explanation with regard to funding
• made improvements to flood plan explorer

Some of the comments we received could not be addressed through changes in the FRMPs. Some comments identified local issues which needed consideration at a local level. These were passed to our and LLFA’s local teams and these are being considered. In addition, some comments related to our and the government’s wider remits. The ‘you said we did’ document provides further detail on these aspects.

The public consultation showed broad support for the information and measures included within the Anglian RBD FRMP. The changes reflect areas where responses identified common themes for improvement or further clarification. The bulk of the change at a local level has been addressed through changes to the supporting text or narrative. Changes for the second cycle Anglian RDB FRMP include:

• further highlighting the ambition to drive a catchment-based approach that delivers multiple benefits to communities and the environment
• strengthening the importance of partnership working and the intention to further develop positive partner relations
• the value of working collaboratively to identify, develop and deliver FCRM solutions has been emphasized - additional recognition has been given to the contributions partners make by: linking people and groups, bringing in local knowledge, data and expertise, and developing and delivering projects
• additional data has been incorporated on peak river flow predictions for 2115. Data is included for the management catchments across the RBD
• additional commentary further highlighting the economic importance of agriculture and its particularly vulnerability to flooding
• additional information is included on NFM and its wider benefits
• stronger emphasis on the potential key role that farming plays in flood risk management
• more information is included on the Broadland futures initiative and its approach to partnership building and integrated planning

additional information has been included on the future Fens integrated adaptation taskforce integrated approach to flood risk management

Very limited change has been considered necessary to the measures. A total of 19 measures have undergone revision as a response to feedback through the consultation process. The majority (11) were very minor changes to wording and information within the measure. Of these, 3 were corrections to spelling only. 6 measures were changes to spatial extent, one of which also included a change to wording. The implementation time frame for 3 Milton Keynes FRA measures was reduced from 2027 to 2025. Only 3 measures (less than 1% of the total measures of the plan) were entirely removed. No new measures have been added.

The ‘you said, we did’ document summarises the responses received on the draft FRMP also how we took them into account in finalising the FRMP.

5.3 Review of the changes

We have reviewed the changes to the FRMP as part of the SEA process. The main purpose of this was to determine whether they could change the significant environmental effects identified in the assessment of the draft FRMP (see section 3 for an overview of these effects).

Overall, there was broad support for the information and measures included in the FRMP. This supports the SEA conclusions on the assessment of alternatives and its approach to assessing the potential significant environmental effects of the FRMPs.

A substantial proportion of the changes to the FRMP are associated with additions to the supporting text or narrative. In some places the supporting text has also been restructured. These changes have primarily sought to provide additional information and help clarify aspects following the consultation responses. Changes made to the Part A national objectives and the Part B national measures have been minor text changes to clarify or strengthen them.

A substantial proportion of the changes made to Part B of the Anglian RBD FRMP are associated with additions to the supporting narrative. These changes have primarily sought to provide additional information and help clarify or strengthen aspects building on consultation feedback.

For example, additional information recognising the value of agricultural land has been incorporated within the agriculture and land use section of Part B. There is no change to the conclusions within the SEA as the assessment had considered this worth when assessing effects on material assets and population. Potential local impacts through loss of high-grade agricultural land through NFM are acknowledged, however overall effects at a RBD level are likely to be significantly positive. Catchment based approaches to NFM, project level assessment and sustainability appraisal should guide decisions and mitigate any adverse effects at a local level. Another example is the addition in the Part B narrative on the effectiveness and value of partnership delivery. The amendments support the mitigation and enhancement recommendations within the environmental report for early engagement and partnership working.

With the exception of removed measures, the activities within the revised measures have not changed. The screening determination has therefore not changed. Three measures have undergone a temporal change which will mean that outcomes may be delivered 2 years earlier. The timescale remains within the medium-term delivery of the plan. No detailed on the ground works are established and there is no change in effect at the strategic level. Likewise, the spatial changes to measures are unlikely to result in changes to the overall findings, with limited local level impacts.

For those measures removed, their removal is unlikely to change the overall conclusions of the assessment for the following reasons:

• one measure is a duplicated activity
• one measure involves partnership working with no on the ground physical works. Its removal is not likely to change the overall positive approach to partnership working that is reflected within the plan
• one measure is an engagement measure at RBD level with no certain on the ground activity. It was screened out of the detailed assessment. The measure promoted a sustainable approach to surface water management and was screened into the cumulative assessment. Removal of this measure is unlikely to change the conclusions of the assessment as there are remaining engagement and partnership measures that support SuDs, rainwater harvesting and green/blue infrastructure across the FRAs.

We have concluded that the changes made to the FRMP do not materially affect the SEA findings and likely significant effects identified. It also takes into account the changes made in response to the Anglian FRMP environmental report’s recommendations for mitigation and enhancement.

In addition, we have prepared a final HRA to assess potential effects on European sites. We consulted with Natural England in preparing the final HRA. None of the measures in the Anglian FRMP were identified to result in likely significant effects (LSE) on any European site. This conclusion applies to both alone and in-combination effects.

A robust HRA appraisal (including Appropriate Assessment) was deferred to the planning application stage for 50 measures. These measures have the highest impact potential on European sites but lack detail for assessment purposes. The measures are sufficiently broadly expressed that they could be delivered without adverse effects, but this will need to be reassessed as actual schemes are developed. Potential negative impacts regarding hydrology, water quality, loss of functionally linked habitat and visual / noise disturbance should be adequately considered. The HRA process at the project stage will ensure that adequate mitigation measures are incorporated where needed and the integrity of European sites will be protected.

Many of the flagged measures involve natural flood management approaches which are likely to result in long-term benefits. For example, by addressing impacts currently affecting European sites, such as inadequate water levels, and reducing diffuse pollution from agriculture. A range of measures have the potential to improve the hydrological condition of European sites across the RBD. Particularly in the Broads SAC and Broadland SPA / ramsar, where four specific measures are targeted towards habitat restoration and water level management. Overall, it was shown that the FRMP represents a positive framework that will help achieve the Conservation Objectives of the SPA / ramsar sites.

It was concluded that the final Anglian RBD FRMP would not result in likely significant effects on any European site, alone or in-combination. An appropriate assessment was not required on the plan. Application of the HRA process at the project stage will ensure the integrity of European sites will be protected.

Overall we consider the changes made to the FRMP are covered by the findings of the SEA, HRA and consultation processes.

6. How monitoring of the significant environmental effects of the implementation of the FRMP will be carried out

6.1 Introduction

The SEA Regulations require significant environmental effects of the final FRMP to be monitored. This section outlines the actions we will take to monitor the significant environmental effects of the second cycle FRMP.

We will use existing monitoring and reporting mechanisms to monitor environmental changes. This information will be used to determine whether the second cycle FRMP might contribute further to reducing potential environmental conflicts or make a greater contribution to the achievement of environmental objectives It will not be possible to determine whether any changes can be directly attributed to the second cycle FRMP because there are too many other influences on environmental change for a direct relationship to be identified.

The environmental topics that are being proposed for monitoring are identified below. The SEA only identified potential positive significant effects in relation to population and human health and material assets. However, given the uncertainty that has been acknowledged in this report over the likely impacts of the plan on other environmental topics, it is proposed to monitor a wider range of topics. In particular, the overall positive effect on biodiversity, flora and fauna is dependent on delivery of biodiversity net gain on development schemes. Regular review and monitoring of this delivery is fundamental.

Monitoring of progress towards the national FCERM strategy objectives, via the FCERM Strategy Roadmap, and of the FRMP will help to identify areas that need review and action in relation to the environmental ambitions of the plans. Please see FRMP Part B for further information on how we will monitor implementation of the FRMP.

In addition to the monitoring proposed below, our process of business case approval and assurance associated with flood and coastal risk management grant in aid funding, will help to further assure that management, mitigation and monitoring occurs at a project level. Project level environmental assessments will be undertaken, where appropriate, and many projects will require planning consent.

6.2 Population, human health and material assets

We are required to periodically report to the minister about flood and coastal erosion risk management outcomes. Data on the changes in the number of households and businesses at risk of flooding and those better protected from flooding is already collected and reported on for outcome measure 2.

Strategic objective 1.1 of the national flood and coastal erosion risk management strategy for England action plan states that ‘between now and 2050 the nation will bolster its resilience to flooding and coastal change’ and outlines a number of actions to help deliver it. Monitoring conducted to understand the extent to which this objective is achieved will also be relevant to understanding the extent to which second cycle FRMP resilience objectives and the respective benefits for people and human health are being achieved across RBDs.

6.3 Biodiversity, flora and fauna

Annual monitoring is already undertaken to determine the length of rivers improved to help show progress toward meeting the Water Environment (Water Framework Directive) Regulations 2017 objectives. Over the lifetime of the plan, we would expect to see the number of rivers reduce where flood risk management is a contributing factor in a rivers failure to achieve good status or potential.

We and other RMAs also report on outcome measure 4 (OM4), which measures

• km of waterbody improved
• hectares of habitat improved
• hectares of habitat created

We will also undertake monitoring associated with the implementation of biodiversity net gain (as set out in the 25 year environment plan and included in the Environment Act 2021).

6.4 Water

We undertake monitoring of the water environment to meet the requirements of the Water Environment Regulations. Indicators used include water quality, ecology (for example, invertebrates, fish) and morphology. Over the lifetime of the plan, we would expect to see a reduction in the number of rivers where flood risk management is a contributing factor to its poor status.

6.5 Climatic factors

The second cycle FRMP include measures that aim to help adapt to and increase resilience to climate change. General reporting and monitoring on implementation of these measures and their effectiveness will form a good indicator of progress. Furthermore, under the Climate Change Act 2008 we are required to report to Defra on climate change adaptation. Elements of the report that are relevant to Anglian RBD FRMP include:

• working with our customers and partners to adapt to a changing climate
• climate resilient investment
• building the evidence base

Tools and methods, such as carbon budgets, are being developed by us to manage the reduction of carbon emissions to contribute our ambition to be a net zero carbon organisation by 2030. While a significant number of local authorities have declared a climate emergency and might be expected to reduce their carbon emissions there is no consistent method of monitoring this. It is therefore likely that our data will be used as an indicator of the performance of the wider programme.

7. References

CaBA, 2021. Chalk stream strategy. Chalk Stream Strategy - CaBA

IUCN, 2018. UK peatland strategy. UK Strategy. IUCN UK Peatland Programme

List of abbreviations

Abbreviation	Description
BNG	Biodiversity net gain
CEEQUAL	CEEQUAL is an evidence-based sustainability assessment, rating and awards scheme for civil engineering, infrastructure, landscaping and works in public spaces
Defra	Department for Environment, Food and Rural Affairs
DWMP	Drainage and wastewater management plan
DWP	Diffuse water pollution
EAP	Environmental action plan
ELMS	Environmental land management scheme
FCERM	Flood and coastal erosion risk management
FRMP	Flood risk management plan
LLFA	Lead local flood authority
LNR	Local nature reserve
NFM	Natural flood management
NNR	National nature reserve
OxCam Arc	Oxford to Cambridge Arc
PLR	Property level resilience
RBD	River basin district
RBMP	River basin management plan
RMA	Risk management authority
SAC	Special area of conservation
SEA	Strategic environmental assessment
SERA	Stakeholder engagement risk assessment
SMP	Shoreline management plan
SPA	Special protection area
SuDs	Sustainable drainage systems
SSSI	Site of special scientific interest
WFD	Water Environment (Water Framework Directive) Regulations 2017

Glossary

Area of outstanding natural beauty (AONB): areas formally designated under the National Parks and Access to the Countryside Act (1949) to protect parts of the countryside of high scenic quality that cannot be selected for national park status as they do not have opportunities for outdoor recreation.

Adaptation: adaptation means anticipating appropriate action to prevent or minimise the likelihood and consequences of flooding and coastal change. It has been shown that well planned early adaptation action saves money and lives late.

Baseline: a description of the present state of the environment with the consideration of how the environment would change in the future in the absence of the plan/programme/project as a result of natural events and other human activities.

Baseline studies/ survey: collection of information about the environment which is likely to be affected by the project.

Biodiversity net gain: an approach to development that aims to leave the natural environment in a measurably better state than beforehand by creating or enhancing habitat.

Catchment: a surface water catchment is the total area that drains into a river. A groundwater catchment is the total area that supplies the groundwater part of the river flow.

Coastal erosion: the loss of land due to the effects of waves and, in the case of coastal cliffs, slope processes (such as high groundwater levels). This may include cliff instability, where coastal processes result in landslides or rock falls.

Conservation area: an area designated under the Town and Country Planning Act, 1990 to protect its architectural or historic character.

Cumulative impacts: the combined impacts of several projects within an area, which individually are not significant, but together amount to a significant impact.

Department of Environment Food and Rural Affairs (Defra): government department responsible for safeguarding our natural environment and setting environmental policy.

Environmental impact assessment (EIA): an assessment process applied to both new development proposals and changes or extensions to existing developments that are likely to have significant effects on the environment.

Environmental land management scheme (ELMS): the cornerstone of the government’s new agricultural policy. The scheme means farmers and other land managers may be paid for delivering public goods such as clean and plentiful water, thriving plants and wildlife and reduction of and adaptation to climate change.

Environmental net gain: net gain is an approach to development that aims to leave the natural environment in a measurably better state than beforehand. The aim of environmental net gain is to reduce pressure on and achieve overall improvements in natural capital, ecosystem services and the benefits they deliver.

Environmental report: the document produced to describe the strategic environmental assessment process carried out for strategies. This report can be standalone or contained as an appendix to a strategy.

Flood defence: a structure (or system of structures) that reduce the risk of flooding from rivers or the sea.

Flood plan explorer: a new, online, map-based tool which displays all of the measures proposed as part of the second cycle of flood risk management plans in England.

Flood risk area: areas identified through the preliminary flood risk assessment process where the risk of flooding is significant nationally for people, the economy or the environment.

Flood risk management plan (FRMP): a statutory plan prepared by the Environment Agency and LLFAs under the Flood Risk Regulations 2009. The plans are reviewed and updated every 6 years.

Flood and coastal erosion risk management: managing the risks of flooding and coastal erosion to people, property and the natural environment through minimising predicting and managing the risk.

Green infrastructure: includes a range of environments such as parks, playing fields, woodland, street trees, rights of way, allotments, canal tow paths, green walls and roofs

Habitats Directive: EC Directive (92/43/EEC) on the conservation of natural habitats and of wild flora and fauna. Implemented (with the Birds Directive (79/409/EEC)) in the UK as the Conservation (Natural habitats and wild flora and fauna) Regulations (1994). This establishes a system of protection of certain flora, fauna and habitats considered to be of International or European conservation importance. Sites are designated as Special areas of conservation (SACs), Special protection areas (SPAs) and/or ramsar sites. Together these sites are referred to as the Natura 2000 network.

Habitats regulations assessment: any developments in or close to a special area of conservation or a special protection area are subject to the habitat regulations for approval of Natural England.

Historic England: officially known as the Historic Buildings and Monuments Commission for England. A public body that helps people care for, enjoy and celebrate England’s spectacular historic environment. They protect, champion and save the places that define who we are and where we’ve come from as a nation. Historic England are the government statutory advisor on the historic environment and are funded largely by the Department for Digital, Culture, Media and Sport.

Internal drainage boards: a public body that manage water levels in an area, known as an internal drainage district, where there is a special need for drainage.

Lead local flood authority: These are county, unitary or metropolitan boroughs that are responsible for managing flooding from surface water, smaller watercourses and groundwater.

Main river: a watercourse designated by Defra. The Environment Agency has permissive powers to carry out flood defence works, maintenance and operational activities on main rivers. Responsibility for maintenance rests on the riparian owner.

Mitigation measures: actions that are taken to minimise, prevent or compensate for adverse effects.

Natural England: Natural England is an executive non-departmental public body responsible to the Secretary of State for Environment, Food and Rural Affairs. Their purpose is to protect and improve England’s natural environment and encourage people to enjoy and get involved in their surroundings. Their aim is to create a better natural environment that covers all of our urban, country and coastal landscapes, along with all of the animals, plants and other organisms that live with us.

Natural flood management: implementation of natural measures which help to alleviate the risk of flooding. They can be used in conjunction with more traditional engineering techniques.

Nature based solutions: the sustainable management and use of natural features and processes to help address societal and environmental challenges.

Preparedness measure: a measure (action) which aims to prepare people for flooding. Examples include flood forecasting and warning, flood emergency response planning and improving public preparedness for flooding.

Prevention measure: a measure (action) which aims to avoid putting people or the environment at risk of flooding. Examples include watercourse regulation, flood risk modelling and mapping and development planning and control.

Property level resilience: actions to make people and their property less vulnerable to the physical and mental impacts of flooding, some which prevent water entering a house and others that minimise the impact should water enter the house, thus speeding up the recovery process

Protection measure: a measure (action) which aims to better protect people from the risk of flooding. Examples include building flood defences, nature based solutions and asset maintenance.

Recovery and review measure: a measure (action) which aims to use learning from flood incidents. Examples include reviewing lessons learnt from flood response, supporting communities, businesses and the environment to recover from flooding.

Risk management authority (RMA): the collective of organisations who are responsible for flood and coastal risk management in England, including the Environment Agency, lead local flood authorities, district councils and internal drainage boards.

River basin district (RBD): large river catchments in England. They cover an entire river system, including river, lake, groundwater, estuarine and coastal water bodies.

River basin management plan: statutory plans developed by the Environment Agency which set out how organisations, stakeholders and communities will work together to improve the water environment.

Scheduled monument: nationally important historic sites, buildings or monuments identified by Historic England and designated by the Secretary of State for Culture, Media and Sport. Any work affecting a scheduled monument must gain consent under the Ancient Monuments and Archaeological Areas Act (1979).

SEA Directive: European Directive 2001/42/EC ‘on the assessment of the effects of certain plans and programmes on the environment’

SEA regulations: The Environmental Assessment of Plans and Programmes Regulations (England) (SI 2004 1633) are the regulations transposing the SEA Directive into UK law.

Strategic environmental assessment (SEA): is a process designed to make sure that significant environmental effects arising from proposed plans and programmes are identified, assessed, subjected to public participation, taken into account by decision-makers, and monitored. SEA sets the framework for future assessment of development projects, some of which require environmental impact assessment (EIA). SEA is carried out according to the requirements of the SEA Regulations.

Sustainable development: a concept defined by the Brundtland Report (1987) as “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs”

Sustainable drainage systems (SuDs): approaches to manage surface water that take account of water quantity (flooding), water quality (pollution), biodiversity (wildlife and plants) and amenity are collectively referred to as sustainable drainage systems (SuDs). SuDs mimic nature and typically manage rainfall close to where it falls SuDs can be designed to transport (convey) surface water slow runoff down (attenuate) before it enters watercourses.

Water body: a unit of surface water being the whole (or part) of a stream river or canal lake or reservoir estuary or stretch of coastal water A groundwater water body is a defined area of an aquifer with geological and hydrological boundaries to ensure consistency and avoid fragmentation.

Water Framework Directive (WFD): EC Directive (2000/60/EC) on integrated river basin management. The WFD sets out environmental objectives for water status based on ecological and chemical parameters, common monitoring and assessment strategies, arrangements for river basin administration and planning and a programme of measures to meet the objectives. This is transposed into UK law through the Water Environment Regulations 2017.