Policy paper

Habitats regulations assessment: non-technical summary

Updated 18 April 2023

Applies to England

Introduction

This is the habitats regulations assessment (HRA) of the Severn river basin district (RBD) flood risk management plan (FRMP). The HRA has been undertaken in accordance with The Conservation of Habitats and Species Regulations (The Habitat Regulations) 2017 (as amended) and 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 FRMP, covering the years between 2021 and 2027, seeks to manage significant flood-related issues in the Severn RBD, including 5 specifically identified Flood Risk Areas. It covers an area of 21,000km2, spanning from uplands in Wales to lowland valleys and estuaries in England. It is to be noted that the FRMP only covers the English part of the RBD, except where hydrological linkages to nearby Welsh European sites may exist. Overall, the Severn FRMP seeks to reduce a range of flooding threats, including from:

• rivers
• the sea
• surface water
• groundwater
• sewers
• canals
• reservoirs

The need for protecting human receptors should be viewed in the context of the environmental challenges present in the Severn RBD. While the population in the RBD is largely concentrated in the major urban centres of Bristol, Gloucester, Shrewsbury, Worcester and Coventry, many European sites away from these conurbations are subject to high levels of anthropogenic pressures. Of primary importance to the RBD is the River Severn (the longest river in Great Britain) and its estuary, including its major tributaries (e.g. the Rivers Wye and Usk – noting that the R. Usk is not covered by this FRMP and only parts of the R. Wye). These and other European sites within the RBD are experiencing a range of negative impacts, including recreational pressure, reduced water flow / level, declining water quality, coastal squeeze and visual / noise disturbance.

The objective of this HRA is to assess the potential for the Severn FRMP to result in likely significant effects (LSEs) and, where applicable, adverse effects on the integrity of European sites (i.e. the ability of those sites to achieve their conservation objectives).

Methodology

The Habitats Regulations 2017 (as amended) set out the specific assessment steps required for the HRA process.

The first step in the sequence of tests, often referred to as HRA screening, establishes whether a more detailed analysis known as ‘appropriate assessment’ is required. The purpose of HRA screening is to determine, in view of the best available scientific knowledge, whether a plan or project, either alone or in-combination with other plans or projects, could result in LSEs on European sites in view of their conservation objectives. If the Competent Authority determines that no LSEs are present (both alone and in-combination), then no further assessment is necessary.

Test of likely significant effects

All measures included in the Severn RBD were assessed for LSEs on the European sites across and within 10km of the RBD. None of the measures were identified to result in LSEs on any European site for several reasons, including that they:

• too non-specific to assess meaningfully
• already being implemented - having undergone HRA previously
• being subjected to a separate consenting process - as applies to local flood risk management plans, shoreline management plans (SMPs) and coastal strategies
• desk-based and involving no physical activity on the ground
• remote from vulnerable sites
• worded such they are about ‘investigating’, ‘reviewing’ and ‘identifying opportunities’

One group of measures was found to commit to physical work on the ground by ‘delivering’ or ‘implementing’ flood management interventions, such as coastal defence structures or natural flood management approaches. The broad location of some measures, is known, enabling a broad assessment of their proximity to European sites and potential linking impact pathways. However, detailed HRA (including Appropriate Assessment) was deferred to either lower-tier plans or the planning application stage when details on the nature of proposals are available. This approach was adopted to account for the strategic (and thereby necessarily non-specific) nature of the FRMP, while also identifying the measures with the highest impact potential on European sites.

This HRA also identified that a range of measures in the Severn FRMP have the potential to improve the hydrological condition and water quality in European sites. For example, delivering natural flood management measures, undertaking tree planting and restoring floodplains are approaches that may contribute towards reinstating natural flow regimes and improving water quality (e.g. through reduced sedimentation). The FRMP represents the opportunity of building the ecological requirements of sensitive European sites into the initiative development process, with the ultimate aim of supporting site Conservation Objectives.

Other Plans and Projects

The potential for the FRMP to result in LSEs on European sites in-combination with (i.e. when considered alongside) other plans and projects was also assessed. Many such plans are proposed across the RBD, which are associated with their own impact potential. For example, local authorities are proposing a minimum of 392,711 new dwellings and 2,313.2ha of employment land within the timescales of their current Local Plans and Core Strategies.

The Welsh part of the Severn RBD will be covered by its own FRMP, associated with potential cumulative impacts particularly where European sites receive hydrological inputs from catchments in both England and Wales. There is also a potential for cumulative impacts with Drought Orders and Permits, the Environment Agency National Drought Plan and SMPs.

Potential in-combination LSEs with Local Plan development were excluded due to most measures not being negatively linked to European sites, the fact that some measures are only included for completeness being driven by entirely separate plan processes, and the strategic nature of the FRMP. Meaning that those measures with potential interactions with European sites depend upon considerable further development before the presence of any impact pathways can be clearly identified.