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 Solway Tweed 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 Solway Tweed 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 Solway Tweed RBD FRMP as adopted
- how we will monitor the likely significant environmental effects of implementing the Solway Tweed RBD FRMP
1.2 Flood risk management plans (FRMPs)
The second cycle Solway Tweed 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 the potential for significant risk or impacts should major flooding occur. 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.
A copy of the final Solway Tweed RBD FRMP can be found at insert link for 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 Solway Tweed RBD 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 Solway Tweed 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 Solway Tweed RBD FRMP
- consultation
- Solway Tweed RBD FRMP SEA
- habitats regulations assessment (HRA)
2.2 Development of the Solway Tweed RBD FRMP
The environment and sustainability were considered throughout the preparation of the Solway Tweed 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 YEP 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 Solway Tweed 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
In total, 47 RBD-scale measures have been developed for the Solway Tweed RBD. 62% of these are in the preventing category. 30% are in the protecting category. 6% are categorised as recovery and review measures. 2% of measures are in the preparing category.
When creating measures, plan makers were asked to link individual measures to the objectives set out in Part A of the FRMP. In addition to the SEA, these raised the profile of certain environmental aspects in the plan development. Due to the changing nature of FRMP measures, funding constraints, evolving studies and ways of thinking, we currently believe that approximately:
- 72% of the measures have the potential to contribute to objective 6
- 89% of the measures have the potential to contribute to objective 8
- 87% of the measures have the potential to contribute to objective 9
- 79% of the measures have the potential to contribute to objective 10
RBD-scale measures in the Solway Tweed FRMP which have specific environmental aspects include:
- between 2021 and 2027, the Environment Agency and risk management authorities will work together to agree practices and principles for partnered schemes in northern England to contribute to achieving carbon reduction targets in the Solway Tweed river basin district
- by 2025, the Environment Agency and risk management authorities, wider communities and stakeholders will work together to deliver conventional, innovative and nature-based improvements to flood risk, water and habitat quality in northern England to reduce community flood risk and improve future collaborative working in the Solway Tweed river basin district
- by 2025, the Environment Agency and risk management authorities will identify and map opportunities to deliver nature-based solutions on risk management authority owned land in northern England to provide a shared resource that can be used to deliver schemes that reduce flood risk and benefit the natural environment in the Solway Tweed river basin district
- between 2021 and 2027, the relevant lead local flood authorities, and risk management authorities in the North West coastal group, will undertake prioritised estuary wide studies in northern England to establish intertidal linkages between flooding, erosion and habitat for identifying natural flood risk management and habitat gain opportunities in the Solway Tweed river basin district
- between 2021 and 2027, the relevant lead local flood authorities, and risk management authorities in the North West coastal group, will influence planning and policy in relation to coastal erosion and flood risk at landfill and contaminated sites in northern England to affect long term investment to reduce coastal pollution from waste sites in the Solway Tweed river basin district.
- by 2027, the Environment Agency and risk management authorities will collaborate with environmental partners and major landowners to significantly increase upland and lowland peat and wetland restoration in northern England to reduce flood risk, restore natural habitats and allow for carbon sequestration to counter the impacts of climate change in the Solway Tweed river basin district
- by 2026, the Environment Agency and risk management authorities will work in unison to map opportunity catchments for habitat creation and develop a programme for joint delivery in northern England to ensure integrated flood risk is tackled and investment is focussed where there will be greatest socio-environmental benefit in the Solway Tweed river basin district
- by 2024, the Environment Agency and risk management authorities will work together to align objectives for flood risk, river basin and drainage and wastewater management plans up to 2030 in northern England to establish agreed strategic measures (activities) in a collaborative programme of flood risk management works in the Solway Tweed river basin district
- between 2021 and 2027, the Environment Agency and risk management authorities will continue to monitor, advise on and work with natural flood processes as far as possible, within identified areas in northern England to ensure the actions are still proportionate to that area’s level of flood risk in the Solway Tweed river basin district
- by 2023, the Environment Agency will begin to implement long-term whole-life asset management plans in northern England to deliver improved work planning, stakeholder engagement, carbon reduction and future funding to enhance the strategic investment programme for reducing flood risk in the Solway Tweed river basin district
- between 2021 and 2027, the Environment Agency and risk management authorities, wider communities and stakeholders will exploit opportunities to store water or manage run-off in identified areas in northern England to provide overall flood risk reduction and environmental benefits in the Solway Tweed river basin district
- between 2021 and 2027, the Environment Agency and risk management authorities will work with local planning authorities, developers and other placemakers to ensure the wider use and adoption of sustainable drainage practices in northern England to reduce flood risk and benefit the environment in the Solway Tweed river basin district
- by 2025, the Environment Agency and risk management authorities will work with the regional flood and coastal committee, local planning authorities, developers and placemakers to promote adoption of best practices in northern England to maximise the benefit new development can bring to reducing flood risk and improving the environment in the Solway Tweed river basin district
- by 2024, United Utilities and risk management authorities will identify and assess opportunities to trial sites for surface water separation in northern England to assess the impacts and create a portfolio of examples that demonstrate the multiple benefits for flood risk reduction and environmental improvement. in the Solway Tweed river basin district
2.3 Consultation
In preparing the Solway Tweed 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 Solway Tweed RBD FRMP 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 to encourage responses. Relevant LLFAs worked collaboratively with the Environment Agency to plan and run consultation activities for shared local stakeholders. 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 13 specific to the Solway Tweed 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. As the Solway Tweed RBD crosses the border with Scotland, we also consulted with Scottish Environment Protection Agency (SEPA), NatureScot and the Scottish Government. 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 the 18th May 2022.
Sections 4 and 5 below outline how consultation responses were addressed and the changes made to the FRMP as a result of 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 Solway Tweed RBD FRMP SEA
We carried out a SEA of the Solway Tweed 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 Solway Tweed 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 Solway Tweed 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 and have consulted NatureScot in relation to any cross-boundary effects. 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. To view the full HRA please click here.
3. The findings of the SEA
Overall, the assessment identified significant positive effects on population and human health. This is due to the implementation of measures that will:
- prevent flooding
- protect against flooding
- prepare communities
- aid recovery
These measures will help to ease the anxiety and stress associated with being at risk of or facing flooding. As well as improving resilience and reducing the consequences of flooding.
The assessment of the FRMP has found that effects on the other environmental topics are likely to be positive or neutral. This is due to the majority of measures not delivering on the ground activities until implementation.
Table 1 provides an overview of the overall effects of the plan, which are discussed further below.
Table 1: overall effects of the plan
Topic | SEA question | Conclusion of assessment |
---|---|---|
Biodiversity, including flora and fauna | Does the plan protect and recover nature? | Overall positive increasing over time. Positive and negative. |
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 positive. Positive and negative. |
Climatic factors | Does the plan help to mitigate and adapt to climate change? | Overall neutral. Positive and negative. |
Material assets | Does the plan support communities and a prosperous economy? | Positive. |
Cultural heritage | Does the plan conserve and enhance the historic environment? | Overall neutral. Positive and negative. |
Landscape | Does the plan conserve and enhance landscape and seascape character? | Overall neutral. Positive and negative. |
Interrelationships | Does the plan have implications for the relationship between the environmental topics? | Yes |
Section 2.4 outlines how the SEA process in general has informed the preparation of the strategy from an early stage. For the Solway Tweed RBD virtual workshops were held to aid the development of measures. The workshops were attended by a range of stakeholders who fed into the development of measures. Environmental constraints and sustainability were considered as part of this process.
The measures of the FRMP for the Solway Tweed RBD aim to build on the first cycle FRMP in setting out the future flood risk management needs. They tend to set preliminary actions for the future investigation and development of business case appraisals and options. As such, further planning processes and supporting environmental assessments will focus on alternatives at these programme and project levels. Therefore, the focus of alternatives for this SEA is limited. It has concentrated on elements where the environmental assessment has identified that significant adverse environmental effects are likely from proposed flood risk management measures.
Below is a summary of the key findings of the SEA, as well as identified mitigation and enhancement opportunities. Full details are set out in the environmental report and non-technical summary. Where the conclusions identified a neutral effect, this often reflected a mix of positive and negative effects.
Biodiversity, including flora and fauna
The SEA found that the plan would have both negative and positive effects on biodiversity. These effects will not be significant at a RBD level.
Many of the measures will not result in direct effects on biodiversity. This is due to the measures not delivering on the ground activities. opportunities for working with nature to reduce flood risk whilst protecting and improving local habitats should be developed in any investigations or option appraisals.
Neutral effects are expected from measures in the preventing category, which include monitoring, data collection, training and guidance. Measures supporting increased awareness, engagement and collaborative working will have indirect positive effects.
Partnerships could drive better outcomes for biodiversity through knowledge sharing and coordinating activities. This could lead to the identification and implementation of more holistic, non-traditional solutions which will have positive outcomes for biodiversity.
Recovery and review measures which provide amenity value or maximise benefits will have positive effects if they create or enhance biodiversity.
The assessment identified uncertainties in assessing the protecting measures where detail on the solutions is currently unknown. There is the potential for the measures to deliver significant positive or negative impacts on biodiversity depending on the type of solution chosen.
Some solutions for reducing flood risk can conflict with statutory nature conservation obligations. Hard engineered solutions are likely to result in adverse effects locally. This could include the loss, damage or fragmentation of habitats through construction activities, impacting species abundance and diversity. The introduction of new infrastructure can also impact ecological connectivity.
Natural flood management (NFM), working with natural processes, measures which are required to achieve biodiversity net gain (BNG) and wider benefits can result in positive effects. Due to restoring and creating habitats and improving their connectivity. It is expected that this will benefit biodiversity, with the scale of positive impact increasing over time as these ways of working embed and the planning and delivery of flood and coastal risk management improves.
However, negative effects can occur even with the use of nature-based approaches due to the presence of sensitive habitats that could be vulnerable to change.
The use of sustainable drainage systems can benefit biodiversity by providing new and or improved green spaces. However, this will depend on what is created and the current biodiversity baseline.
Any identified negative effects on biodiversity at the local level will be addressed through mitigation actions. These will include environmental assessment and construction environmental management plans.
Population and human health
The SEA found measures will have a significant positive effect on wellbeing and human health. This is due to the reduction in flood risk to properties, infrastructure and services. As well as increasing the resilience of infrastructure and communities. Measures aim to improve preparedness, prevention, recovery and protection from flood and coastal erosion which will benefit the health and wellbeing of communities. The measures aim to:
- raise awareness of flood issues
- enable better preparation
- improve resilience
- reduce the consequences of flooding
Protecting measures will have positive effects on people, property and business due to reducing flood risk.
These measures will help to ease the anxiety and stress of experiencing or being at risk of flooding. The measures will reduce flood risk and enhance the communities’ ability to cope with flooding.
Indirect positive effects from wider benefits associated with improvements to the environment and increasing the amenity value of an area which can provide opportunities for extending or enhancing green networks as well as provide the benefit of greater contact with the natural environment.
Soil
The SEA concluded neutral effects on soils. Preventing, preparing and recovery and review measures that do not involve physical ‘on the ground’ activities are unlike to have direct effects.
Positive effects from measures implementing nature-based solutions are anticipated to help protect and conserve soils and improve resilience to degradation.
Measures that restore soil or reduce erosion (such as peatland restoration, and NFM) will have positive effects on soil but these are unlikely to be significant at a RBD level.
There will still be a need for new or improved infrastructure to manage flood risk and without mitigation these can result in the degradation of soils. Preferred options are not currently known thus, the assessment concludes uncertain effects.
Water
Measures have the potential to result in both positive and negative effects on water. The SEA concluded overall positive effect on the water environment which is unlikely to be significant at a RBD level.
Preventing, preparing and recovery and review measures that do not involve physical ‘on the ground’ activities are unlike to have direct effects.
Measures in the plan aim to reduce flood risk. Achieving this overall aim is likely to reduce the risk of run-off to rivers, reduce soil erosion and the transfer of sediment and pollutants into water resources.
The use of nature-based solutions to manage flood risk can help to reduce surface water run-off and soil erosion. This can benefit water quality by reducing diffuse pollution and the sedimentation of watercourses.
Measures have the potential to support the delivery of the water environment regulations objectives by reconnecting flood plains and re-naturalising watercourses and improving water quality. Some of these measures can also lead to habitat creation and water quality improvement which would benefit wetland and aquatic habitats. Measures such as peatland restoration will have positive effects on water quality. Measures also have the potential to conflict with the water environment regulations objectives. Without mitigation they can have negative effects on the status of a water body(s) for example, by altering the natural functioning of a watercourse and separating it from its flood plain.
The FRMP and the river basin management plans (RBMP) have been developed together. Therefore, the FRMP will be compliant with the objectives of the water environment regulations resulting in no significant negative effects.
Construction or maintenance works may cause temporary, short-term pollution however, this can be effectively mitigated.
Climatic factors
Neutral effects on climatic factors were concluded by the SEA. The management of water resources, investment and decision-making considering climate change will aid adaption to climate change and reduce the consequences of flooding.
Positive effects on climatic factors are likely by helping to provide climate resilient places and aiding preparation and adaption to flooding and coastal change.
Solutions involving new or improved infrastructure will potentially contribute to greenhouse gas emissions. The Environment Agency anticipates significant progress towards its net zero carbon 2030 target. The net zero target will reduce negative carbon effects resulting from the measures. Agreeing principles to contribute to carbon reduction targets on partnered schemes will also reduce negative carbon effects.
Other risk management solutions that work with natural processes are likely to have lower carbon footprints than traditional engineered solutions. Measures such as the use of NFM approaches and habitat creation can contribute to a reduction in greenhouse gases across the RBD. These measures offer benefits to climate factors as they increase climate resilience whilst offering opportunities for carbon sequestration. Peatland restoration will have positive effects on climate as peat acts as a carbon store, however unless large scale this is unlikely to be significant.
A healthy natural environment is an important element of climate resilience places. Measures which contribute to improving the environment will have positive effects on climate.
Achieving the overall aim of reducing flood risk is likely to have a beneficial effect on climatic factors. This is due to avoiding greenhouse gas emissions associated with the clean-up and the replacement of items damaged by flooding.
Material assets
The implementation of measures that provide a reduction in flood risk to properties, infrastructure and services and increase resilience will have positive effects on material assets. Measures will also have a positive effect on supporting sustainable communities and a prosperous economy.
Measures associated with awareness, preparing for and recovering from flooding will have positive effects. These measures will raise awareness and encourage action to be taken to reduce the consequences of flooding. This will enable people to return to their homes and businesses more quickly after a flooding event.
Measures which improve the understanding of the risks of flooding to critical infrastructure will enable resilience in the future. This may lead to long-term benefits as ways to protect the infrastructure are investigated, allowing continued operation or quick recovery following a flood event.
The assessment identified uncertainties in assessing the protecting measures where the solutions are currently unknown.
Cultural heritage
Measures have the potential to result in both positive and negative effects on cultural heritage, but overall, the assessment concluded neutral effects. Many of the measures will have neutral effects on cultural heritage. This is due to the measures not involving physical activity on the ground therefore not having a direct effect.
Many historic places are associated with the water environment. Some approaches to flood risk management, such as new or improved permanent infrastructure can have negative effects on historic places. This by association can have implications for the character of both urban and rural spaces and landscapes their character and setting above ground and harm below ground archaeology. This is particularly relevant for the 2 world heritage sites (WHSs).
Measures that reduce the risk of flooding to historic places can result in beneficial effects. Although upon implementation effects to heritage assets may occur. The significance of these effects may vary. The reduction of flooding will support the conservation of the historic environment, due to avoiding the harm caused by flooding.
The assessment of the protecting measures which will determine solutions has identified uncertainties, due to not having the detail on the solutions to be delivered and the heritage sensitivities of the local area likely to be affected.
Flood risk management interventions can also alter the water regime of places. This could negatively affect the archaeological interest, but also might positively enhance a landscape aesthetically designed to include water or where ‘wetting up’ a landscape improves the longer-term conservation of archaeological remains. Archaeological understanding can show how the water environment has changed over time. This understanding can inform risk management activities. This includes the design and implementation of measures.
An understanding of the character and significance of the historic environment can help to design schemes. This will reduce effects on the landscape. It may also offer enhancements to its character.
Landscape
The SEA found the overall effect on landscape is likely to be neutral. This is due to the measures not involving physical activity on the ground and therefore having no direct effects.
Measures have the potential to both negatively and positively affect landscape character. They can help to protect existing landscapes from the effects of flooding and coastal change. But infrastructure can also result in the loss of landscape features that contribute to the character of a place and its use by people. Such interventions can also provide opportunities to enhance the quality of landscapes at a greater scale, by improving or extending blue and green infrastructure networks or enhancing the public realm.
Measures that work with natural processes can enhance landscape character. Increasing amenity value can provide opportunities for extending or enhancing green networks. The use of sustainable drainage systems can also benefit landscape by enhancing the character of urban and rural landscapes. They can provide green space, as well as improving water quality and availability.
With mitigation, as informed by landscape character assessments, potential negative effects can be reduced at the local level. This will be particularly important in locations close to or within the landscape designations (national park, AONB and WHS).
Interrelationships and cumulative effects
Wider benefits of the measures will also have positive effects on other environmental and social topics. For example, improving amenity value and recreational networks can provide opportunities for extending or enhancing green networks. This would have positive effects on tourism and improve health and wellbeing.
There are interrelationships between the effects of the plan on different environmental topics. NFM, for example can provide positive interrelationships between topics including:
- biodiversity and water environment (supporting the water environment regulations objectives), soils (soil conservation)
- material assets (agricultural land)
- population and human health (tourism and improved health and wellbeing)
The use of sustainable drainage systems can contribute to enhancing the character of urban landscapes as well as improving water quality. These measures also link biodiversity and human health through interactions with the natural environment and green space.
There are also links between the topics of cultural heritage and landscape. For example, it’s likely that enhancement (or deterioration) of landscape character will be reflected in positive (or negative effects) on cultural heritage and vice versa. This is particularly relevant to the WHSs.
Measures that reduce the risk of flooding to historic places may contribute to enhancing the quality of landscapes in urban and rural places.
Measures that reduce the risk to cultural heritage could also have negative effects on the setting and the historic character of the landscape due to it being altered. Appropriate assessment to identify mitigation will be needed.
An assessment of the main potential cumulative effects of the interactions between the FRMP and other relevant policies, plans and programmes has been undertaken for the SEA. Strategic planning and partnership working, with environmental assessments undertaken where required for individual policies and scheme, would mitigate any significant cumulative effects.
SEPAs second cycle draft FRMP has been published for consultation. At a national level the Environment Agency are working collaboratively with SEPA via a cross border advisory group to ensure our plans for managing the risk of flooding and coastal change are mutually supportive.
In the Solway Tweed, NFM and nature-based solutions are common themes and approaches between England and Scotland.
Work to date suggests that at present there is low likelihood of flood risk management activities in these areas impacting the other side of the border.
National measures
On balance the national measures in the plan are assessed as having significant positive effects on population and human health, with effects on biodiversity assessed as potentially negative and all other environmental issues assessed as neutral.
The assessment recognises the potential for individual national measures to have positive and/or negative environmental effects as described. The actual environmental effects will depend on the nature and extent of the actions that arise from the national measures and local environmental conditions.
Given the widely acknowledged global climate and nature emergencies, environmental issues are increasingly important in a strategic context. It’s therefore important that national measures are actively implemented in a way that gives due consideration to their environmental consequences. The Environment Agency’s well-established approach to assessing and managing environmental risk and opportunity at a programme and project level will play an important role in minimising negative effects and maximising positive effects from these actions as they are implemented. It’s anticipated that lead local flood authorities (LLFAs) will have similar controls in place.
The balance of negative and positive effects associated with national measures is likely to skew more strongly towards positive over the duration of the plan as the Environment Agency and LLFAs make progress towards net zero carbon and environmental net gain targets and as nature first ways of working are embedded in standard practices.
Mitigation actions and enhancement opportunities
Measures that explore available options should follow place-based approaches to ensure that the most appropriate options are selected for the environmental baseline conditions. Studies should consider investing in a strategic landscape visioning exercise. This can form a valuable component of any land-based project study.
The ‘nature first’ approach should be followed. Priority habitats such as wetlands, lakes, ponds, wet grassland can act as good carbon stores in addition to peatlands, and woodland. These habitats should also be encouraged.
Flood risk management works will need to undertake an appropriate level of environmental assessment. This may include project level HRAs and water environment regulations assessments. The assessment process will identify negative impacts and avoid or reduce the effects. At the same time, it will allow for the inclusion of opportunities and enhancements. These assessments should focus on the sensitive receptors and guide the design of proposals to reduce negative effects. All plans should ensure that biodiversity net gain (BNG) is embedded into proposals.
Where planning permission is required, works will need to be supported by surveys or assessments to allow the planning authority to assess the local impacts and determine if site specific mitigation is suitable.
eMission 2030, is the Environment Agency’s sustainable business strategy. It makes commitments to deliver:
- environmental and 20% BNG across its operations
- achieve net zero carbon
- optimising our use of resources
- benefiting people and communities
These commitments should reduce negative effects of the measures being delivered by the Environment Agency.
Where onsite works are required, low carbon options for materials and low carbon construction operations should be explored. Measures should ensure that resources and flood assets will be sustainably managed (waste reduction and material recovery and reuse).
Partnership working and early engagement with stakeholders would reduce negative effects and maximise opportunities. Engagement could also increase wider benefits of the measures.
Prior to maintenance or construction works, an environmental management plan will be required. This will identify the environmental risks present on site and the measures needed to mitigate and manage them.
Implementing these mitigation and enhancement measures should minimise negative effects and ensure potential benefits are realised.
4. How opinions expressed in response to the consultation have been taken into account
4.1 Introduction
The consultation on the draft Solway Tweed 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 Solway Tweed RBD FRMP. 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?
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 Solway Tweed 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 Solway Tweed 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 is needed. 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, regarding 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 of these strategies and aims to work with natural processes in order 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 Solway Tweed RBD FRMP
The main themes from the Solway Tweed FRMP responses were partnerships engagement and readability.
The consultees who answered the SEA questions agreed totally or partially with the conclusions of the SEA.
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.
Approximately 70% of the respondents that answered were satisfied that negative and positive effects had been adequately addressed. Approximately 44% felt that there were other significant effects to consider. Approximately 63% felt that there were further opportunities to enhance positive effects and mitigate negative.
The main themes raise for the Solway Tweed RDB were similar to the national themes and included:
- biodiversity and designated sites
- agriculture and land management
- nature-based solutions
It is an ambition of the FRMP to continue to drive catchment-based delivery in the Solway Tweed RBD that offers multiple benefits to communities and the environment.
Comments have been considered in the revisions to Part B including recognising that agriculture and horticulture are economically significant land uses that are vulnerable to extreme weather and climate change. Part B also recognises the specific challenges in relation to flood risk management and the potential affect food production.
Specific to the Solway Tweed RBD was the theme of coastal issues not being sufficiently assessed through the SEA.
Shoreline management plans (SMP) provide the basis for policies for a length of coast and set the framework for managing risks along the coastline in the future. The objectives of an SMP should: set out the risks from flooding and erosion to people and the developed, historic and natural environment within the SMP area; identify opportunities to maintain and improve or increase coastal habitats by managing the risks from floods and coastal erosion; identify the preferred policies for managing risks from floods and erosion over the next century; identify the consequences of putting the preferred policies into practice; set out procedures for monitoring how effective these policies are; inform others so that future land use, planning and development of the shoreline takes account of the risks and the preferred policies; discourage inappropriate development in areas where the flood and erosion risks are high; and meet international and national nature conservation legislation and aim to achieve the biodiversity objectives.
There are 2 SMPs within the RBD. The Scottish Border to River Tyne SMP 2 (Northumberland and north Tyneside) covers the coastline from the north eastern extent of the RBD up to the Scottish border. The Great Orme’s Head to Scotland SMP 2 covers the western coastline to the Solway Firth.
The FRMP includes the following measure
- between 2021 and 2027, the relevant Lead local flood authorities and risk management authorities in the North West coastal group will implement the shoreline management plan action plan and co-ordinate wider activities along the coastline in line with the shoreline management plan in northern England to reduce the risk of flooding and manage coastal change in the Solway Tweed river basin district.
The SMPs have associated SEAs detailing the impacts and identifying potential mitigation on coastal habitats. The Environment Agency is working closely with the coastal groups to refresh all the SMPs covering the English coastline. This is to make sure they remain fit for purpose. This update will include revising the associated SEAs. The updated SMPs are due to be published in 2023.
The Solway Tweed coastline is covered by conservation designations including the Solway Firth SAC and Berwickshire and North Northumberland Coast SAC. We recognise the importance of rising sea levels on estuarine and intertidal habitats and the interactions of these habitats with new and existing defences.
Restoring meadow, marsh and reef (ReMeMaRe) is a habitat restoration initiative, which is aiming to restore at least 15% of three priority estuarine and coastal habitats along the English coast by 2043.
The FRMP aligns with the initiative, in particular, the following measure which looks to establish intertidal linkages between flooding, erosion and habitat:
- between 2021 and 2027, the relevant lead local flood authorities, and risk management authorities in the North West coastal group, will undertake prioritised estuary wide studies in northern England to establish intertidal linkages between flooding, erosion and habitat for identifying natural flood risk management and habitat gain opportunities in the Solway Tweed river basin district.
As noted in section 6.2 of the Solway Tweed RBD 2nd Cycle FRMP – SEA: environmental report, most of the measures will not result in direct effects, as measures will not deliver on the ground activities. The measures involve studies around options or investigating flood risk processes in more detail. The outcomes of these studies will inform future projects which are particularly difficult to assess at a strategic scale. Given the current lack of certainty on how these studies will evolve, future project appraisal and assessment processes will be better placed to determine the impacts on coastal habitats.
5. Reasons for adopting the Solway Tweed RBD FRMP
5.1 Introduction
This section provides an outline of the main factors taken into account in finalising the Solway Tweed 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 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 in 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.
Changes to Part B of the second cycle Solway Tweed RBD FRMP are summarised below. They largely relate to changes to the supporting text or narrative:
- minor alterations throughout the document to aid clarity and readability
- recognised the economically importance of agriculture and the impacts of flooding on agriculture and horticulture
- more information has been included around catchment-based delivery, offering multiple benefits to communities and the environment
- more information has been provided on partnership working and links with other plans - acknowledge that working in partnership is the most effective way to address the issues of flooding and climate change and to deliver multiple benefits
- updated information around flood risk and canals
- recognised that climate change predictions will evolve, replacing some of the presented river basin district level information and sign-posting up-to-date locational information
- acknowledging that measures are not intended to cover all detail and this will develop as projects progress and funding is secured
There has been one minor change to one measure which has no impact on the aims or outcomes of the measure.
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.
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 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 and NatureScot in preparing the final HRA.
The HRA has assessed the potential for the Solway Tweed FRMP to result in likely significant effects (LSEs) on European sites in view of their conservation objectives and, where applicable, adverse effects on the integrity of European sites.
LSEs of the FRMP on all European sites, both alone and in-combination, were excluded for all measures and an Appropriate Assessment was not required. This was based on various factors, including some measures being carried over from the cycle 1 FRMP (which would have been subject to the statutory consenting process, including HRA), already implemented, desk-based and involving no physical activity on the ground, not associated with impact pathways linking to European sites or too non-specific (either in terms of specific location, their nature or both) to allow for a detailed, meaningful assessment.
Notably, 10 measures were screened out at the strategic FRMP level but recommended for down-the-line HRA since 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. As the details of potential schemes are developed towards the planning application stage, the HRA process will ensure that adequate mitigation measures, where relevant, are incorporated and the integrity of European sites will be protected. It is to be noted that many of the flagged measures involve natural flood management approaches, which are likely to result in long-term benefits to hydrologically sensitive European sites. Notwithstanding this, potential negative impacts regarding hydrology, water quality, loss of functionally linked habitat and visual / noise disturbance should be adequately considered.
The Solway Tweed FRMP also contains a range of measures that could lead to a positive outcome for the conditions of European sites, if these are adequately planned in consideration of site conservation objectives. These measures, which include a range of proposals ranging from enhanced collaboration, further scientific studies to the delivery of natural flood management approaches, have the potential to help mitigate some of the impacts currently affecting European sites, such as inadequate water levels, insufficient hydrological flows and continuing coastal squeeze.
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. 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 be relevant also 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 YEP 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 Solway Tweed 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 |
---|---|
25 YEP | 25 year environment plan |
AONB | area of outstanding natural beauty |
BNG | biodiversity net gain |
DWMPs | drainage and wastewater management plans |
FCERM | flood and coastal; erosion risk management strategy |
FPE | flood plan explorer |
FRAs | flood risk areas |
FRMP | flood risk management plan |
HRA | habitats regulation assessment |
LFRMS | local flood risk management strategies |
LLFAs | lead local flood authorities |
LSEs | likely significant effects |
NFM | natural flood management |
OM4 | outcome measure 4 |
RBD | river basin district |
RBMPs | river basin management plans |
ReMeMaRe | restoring meadow, marsh and reef |
RMAs | risk management authorities |
SEA | strategic environmental assessment |
SMPs | shoreline management plans |
SOEP | statement of environmental particulars |
WFD | water framework directive |
WHS | world heritage site |
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: 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): is 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 net gain: 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: are 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 providing information and raising awareness about flooding.
Prevention measure: a measure (action) which aims to avoid putting people or the environment at risk of flooding. Examples include flood risk modelling and mapping and development planning and control.
Protection measure: a measure (action) which aims to better protect people from the risk of flooding. Examples include building flood defences and nature based solutions.
Recovery and review measure: a measure (action) which aims to use learning from flood incidents. Examples include 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.