Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy
Environmental Report
Client: Luton Borough Council Report No.: UE-0161 SEA- Luton LFRMS ER_3_150805 Version: 3 Status: Final Date: August 2015 Author: SP/NP Checked: SP Approved: NP
Cover image: Wardown Park, Luton (Source: Anemone Projects via Flickr)
SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
Contents
0 Non-Technical Summary i
0.1 About Strategic Environmental Assessment i
0.2 About the Luton Local Flood Risk Management Strategy i
0.3 Purpose and Content of the Environmental Report i
0.4 The SEA Scoping Stage ii
0.5 Assessment of Reasonable Alternatives iii
0.6 Detailed Assessment and Recommended Mitigation iv
0.7 Monitoring vi
0.8 Next Steps vi
1 Introduction 1
1.1 Purpose of this Report 1
1.2 The Luton Local Flood Risk Management Strategy 1
1.3 The Study Area 1
1.4 Sustainable Development 2
2 Methodology 5
2.1 Strategic Environmental Assessment 5
2.2 Assessment Stages 5
2.3 Approach to Assessing Significant Effects 6
2.4 Limitations to the Strategic Environmental Assessment 8
3 Scoping 9
3.1 Scoping Report 9
3.2 Scoping Consultation 9
3.3 Policy, Plan and Programme Review 9
3.4 Baseline Data and Key Environmental Issues 10
3.5 The SEA Framework 10
3.6 Assessing the LFRMS Objectives against the SEA Framework 10
4 Assessing Reasonable Alternatives 13
4.1 Responding to the Requirements of the SEA Directive 13
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4.2 High Level Assessment 14
4.3 Detailed Assessment 20
4.4 Cumulative Effects Assessment 30
5 Monitoring 31
5.1 Monitoring Framework 31
6 Summary and Consultation Arrangements 33
6.1 Summary and Next Steps 33
6.2 Consultation Arrangements 33
References and Bibliography 34
Appendix A: Annex 1 of the SEA Directive A
Appendix B: Consultation Analysis C
Appendix C: Policy, Plan & Programme Review E
Appendix D: Baseline Data & Key Issues G
Appendix E: SEA Framework I
Appendix F: High Level Assessment K
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List of Tables and Figures
Table 2.1: SEA stages and those addressed in this report 5
Table 3.1: Strategic Environmental Assessment Objectives 11
Table 3.2: Assessment of compatibility between LFRMS and SEA Objectives 11
Table 4.1: Cumulative, synergistic and indirect effects 30
Table 5.1: Proposed monitoring framework 31
Figure 1.1: Five guiding principles of the UK Sustainable Development Strategy, Securing the Future (2005) 4
Figure 4.1: Critical Drainage Areas and potential improvement/alleviation schemes 18
SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
Abbreviations
ALC Agricultural Land Classification
AONB Area of Outstanding Natural Beauty
BMV Best and Most Versatile
CDA Critical Drainage Area
CWS County Wildlife Site
DAM Detailed Assessment Matrix
DWS District Wildlife Site
FAS Flood Alleviation Scheme
HER Historic Environment Record
HLA High Level Assessment
LFRMS Local Flood Risk Management Strategy
LLFA Lead Local Flood Authority
LNR Local Nature Reserve
SAM Scheduled Ancient Monument
SEA Strategic Environmental Assessment
SSSI Site of Special Scientific Interest
SuDS Sustainable Drainage Systems
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0 Non-Technical Summary
0.1 About Strategic Environmental Assessment
0.1.1 A Strategic Environmental Assessment (SEA) is being carried out alongside the preparation of the Luton Local Flood Risk Management Strategy (LFRMS).
0.1.2 Plan-making bodies use SEA to assess strategy documents against a set of environmental objectives developed in consultation with local stakeholders and communities. This assessment helps the plan-makers to identify the relative environmental performance of proposed Objectives, Policies and Actions, and to evaluate which of these may be more sustainable.
0.1.3 SEA is a statutory process incorporating the requirements of the European Union Strategic Environmental Assessment Directive.
0.2 About the Luton Local Flood Risk Management Strategy
0.2.1 Luton Borough Council is a Lead Local Flood Authority and therefore has a duty to produce, maintain, implement and monitor a Local Flood Risk Management Strategy for its area. The Luton LFRMS will:
Ensure a clear understanding of the risks of flooding locally, so that investment in risk management can be prioritised more effectively;
Set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of the remaining risk;
Manage flood risks in an appropriate way, taking account of the needs of communities and the environment;
Ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond effectively to flood forecasts, warnings and advice; and
Help communities to recover more quickly and effectively after incidents.
0.3 Purpose and Content of the Environmental Report
0.3.1 The purpose of this Environmental Report is to:
Identify, describe and evaluate the likely significant effects of the LFRMS and its reasonable alternatives; and
Provide an early and effective opportunity for statutory consultees, interested parties and the public to offer views on any aspect of the SEA process which has been carried out to date.
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0.3.2 The Environmental Report contains:
An outline of the contents and main objectives of the LFRMS and its relationship with other plans, programmes and strategies;
Relevant aspects of the current state of the environment and key sustainability issues for the borough;
The SEA Framework of objectives and decision-making criteria against which the LFRMS has been assessed;
The appraisal of alternative options for the LFRMS;
The likely significant environmental effects of the LFRMS;
The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects which may arise as a result of the LFRMS;
A description of the measures envisaged concerning monitoring; and
The next steps for the SEA.
0.4 The SEA Scoping Stage
0.4.1 The Scoping Report was published for consultation between 26 November 2014 and 14 January 2015. It set out the intended scope and level of detail to be included in the SEA and included a plan, programme and strategy review, an evidence base for the assessment, key issues and environmental challenges to address, and an SEA Framework of objectives against which the LFRMS can be assessed.
0.4.2 The SEA Framework is comprised of six SEA Objectives, listed below, which were developed for use in the appraisal. # SEA Objective Relationship to SEA Directive 1 To conserve and enhance biodiversity Biodiversity, flora and fauna
2 To promote adaptation to climate change Climatic factors; Material assets; Population; Human health 3 To conserve and enhance the historic environment, heritage Landscape; Historic assets and their settings environment 4 To conserve and enhance the character of the landscape Landscape; Historic environment 5 To protect water resources and minimise water pollution Water
6 To conserve and manage natural resources (land, minerals, Material assets; Soil agricultural land, materials)
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0.4.3 Following consultation the information presented in the Scoping Report was updated to take account of the responses received. The revised scoping information is included in this Environmental Report.
0.5 Assessment of Reasonable Alternatives
0.5.1 The purpose and content of the LFRMS is clearly defined by law which means that there is limited scope for the consideration of markedly different alternatives. However, at points during the development of the LFRMS certain decisions were made for which alternatives were available.
0.5.2 Following the conclusion of the scoping stage, the SEA team contributed to the development of options work carried out for the LFRMS via the High Level Assessment. The purpose of this interaction between the SEA and the LFRMS was to inform and influence the strategy’s development and to provide an early and effective environmental input, and included suggestions for additional reasonable alternatives which could be considered alongside the Policies and Actions proposed for inclusion in the LFRMS. These can be summarised as:
Policy 1: Thresholds for flood investigations;
Alternative 1a: Set lower thresholds for initiating formal flood investigations (e.g. 5 or more adjacent dwellings and/or 1 or more business premises);
CDA 1a: High priority Critical Drainage Areas (CDA) are high risk and have synergy with other projects; medium priority are those with <£25,000 cost per property mitigated; all others are low;
CDA 1b: Alternative - Different approach to prioritisation of CDAs (e.g. medium priority are those with <£30,000 cost per property mitigated; all others are low);
Policy 2: Sand bags;
Alternative 2a: Supply sand bags to selected groups of residents in chosen locations;
Action 6.1: Water efficiency (retrofitting); and
Action 6.1a: Alternative - Water Efficiency (retrofitting) - higher target e.g. 60% of existing housing stock.
0.5.3 Overall the High Level Assessment found the Luton LFRMS to be a broadly sustainable strategy with a wide range of positive effects and few negative environmental effects. However, a number of Flood Alleviation Scheme (FAS) proposals for certain Critical Drainage Areas were flagged as leading to uncertain or mixed environmental effects the nature of which would largely depend on their means of implementation. Further discussion with the Council confirmed that a secondary level of options generation had taken place for reducing flood risk in CDAs. These options do not strictly form part of the LFRMS as they are subject to funding and final scheme design, however, it was decided that they would form the most appropriate basis for detailed assessment.
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0.6 Detailed Assessment and Recommended Mitigation
0.6.1 Four CDA proposals were assessed in greater detail. A summary of assessment findings and recommendations for each CDA is presented below.
Barton Road / Great Bramingham High Priority CDA Summary of predicted environmental effects: . Temporary loss of semi-natural habitats/species resulting from the route of the culvert and swales in Icknield Park. Minor temporary negative effects are predicted at a local scale over the short term. . Temporary or permanent loss of protected habitats would result in minor to major negative effects at a local to national scale, and could also lead to impacts on protected species, depending on the location of flood storage bunds near Turnpike Drive and Burford Close. . Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term, although creating swales in Icknield Park could adversely affect its use as a playing field, resulting in a functional loss of green infrastructure and minor indirect effects on human health. . Earthworks required for the construction of swales or installation of a larger culvert could result in the disturbance or destruction of archaeological remains, resulting in permanent minor to moderate impacts at a local to regional scale. . Loss of protected heritage features would result in major negative effects at a national scale depending on the location of flood storage bunds near Turnpike Drive and Burford Close. . New permanent flood storage areas could result in minor to moderate negative effects on a nationally important protected landscape over the long term. . Short term minor negative impacts to water quality during construction are predicted at a local scale due to introduction of sediments to the water course. . Permanent loss of agricultural land would result in minor to moderate negative effects at a local scale over the long term, depending on the location of flood storage bunds near Turnpike Drive and Burford Close. Summary of recommended mitigation: . Loss of protected habitats should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Functional loss of playing fields would need to be replaced on a like-for-like basis to ensure community accessibility to these facilities is maintained. . Loss of protected heritage features should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required. . It should be possible to reduce negative landscape effects via a high quality design which responds to landscape constraints and uses an appropriate selection of materials. . Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction.
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. Mitigation for the loss of agricultural land is not feasible, however, losses should be avoided or minimised through site selection, layout and design, while measures should be taken to ensure that good quality top soil is either re-used on site or put to productive use off site. Chapel Street / Arndale Centre High Priority CDA Summary of predicted environmental effects: . Temporary loss of semi-natural habitats/species resulting from the route of the new drainage pipe from George Street to Manor Road Park. Minor temporary negative effects are predicted at a local scale over the short term. . Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term, although the new pipe could also increase the extent and depth of flooding at Manor Road Park. . Engineering works could negatively affect the character of the Town Centre and Luton South Conservation Areas), resulting in temporary minor impacts at a local scale. . Short term minor negative impacts to water quality during construction are predicted at a local scale due to introduction of sediments to the water course. Summary of recommended mitigation: . Loss of protected habitats should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Loss of protected heritage features should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required. . Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction. Barnfield West Academy / Poynters Road High Priority CDA Summary of predicted environmental effects: . No strategically significant effects predicted. Summary of recommended mitigation: . No mitigation required at the strategic level, however, further investigations (e.g. ecological survey) may be necessary at the detailed project proposal stage. Vauxhall Way High Priority CDA Summary of predicted environmental effects: . Minor temporary negative effects are predicted at a local scale over the short term resulting from a temporary loss of semi-natural habitats/species, depending on the route of the proposed thrust pipe or open cut, and design and location of flood storage areas between Eaton Valley Road and Vauxhall Way and to the east of Parkway Road. . Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term. . Minor to moderate negative effects to a nationally important heritage feature are possible over the long term depending on the location, route and design of engineering works. . Short term minor negative impacts to water quality during construction are predicted at a local
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scale due to introduction of sediments to the water course. Summary of recommended mitigation: . Loss of protected habitats should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Loss of protected heritage features should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required. . Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction.
0.7 Monitoring
0.7.1 Chapter 5 of the Environmental Report contains proposals for a monitoring programme to measure the significant environmental effects of implementing the Luton LFRMS. Monitoring for the SEA will be aligned with or incorporated within monitoring that is scheduled for the LFRMS itself, both to avoid duplication and ensure that appropriate remedial action can be taken.
0.8 Next Steps
0.8.1 The LFRMS and its SEA will be published for a period of representations. Comments received on both documents will be considered by the Council prior to finalising and adopting the strategy. Any significant changes to the strategy which arise as a result of consultation will need to be assessed as part of the SEA process, which may lead to a further edition of, or addendum to the Environmental Report.
0.8.2 An Environmental Statement will be published with the adopted LFRMS. The purpose of the Environmental Statement is to outline how the SEA process has informed and influenced the planning process and demonstrate how consultation on the SEA was taken into account.
0.8.3 This Environmental Report is available online or in hard copy to view at the following addresses:
www.luton.gov.uk/floodriskmanagement Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ
0.8.4 The consultation period runs from 10 August to 7 September 2015. Responses should be submitted via the Luton Borough Council consultation portal or to the following addresses:
Email: [email protected] Flood Risk Management, Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ
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1 Introduction
1.1 Purpose of this Report
1.1.1 This Environmental Report has been prepared for Luton Borough Council as part of the Strategic Environmental Assessment (SEA) for the Luton Local Flood Risk Management Strategy (LFRMS).
1.1.2 The Environmental Report has been produced in compliance with the Environmental Assessment of Plans and Programmes Regulations 2004. It incorporates the information which is required in accordance with EU Directive 2001/42/EC on Environmental Assessment of Plans and Programmes (the SEA Directive). The report represents the latest stage in the SEA and forms part of the evidence base upon which the LFRMS is based.
1.2 The Luton Local Flood Risk Management Strategy
1.2.1 Luton Borough Council is a Lead Local Flood Authority (LLFA) under the Flood Risk Regulations (2009) and the Flood and Water Management Act (2010). The legislation created a duty for LLFAs to produce, maintain, implement and monitor Local Flood Risk Management Strategies for their area. The LFRMS must be consistent with the Environment Agency’s National Flood Risk Management Strategy.
1.2.2 The Luton LFRMS will:
Ensure a clear understanding of the risks of flooding locally, so that investment in risk management can be prioritised more effectively;
Set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of the remaining risk;
Manage flood risks in an appropriate way, taking account of the needs of communities and the environment;
Ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond effectively to flood forecasts, warnings and advice; and
Help communities to recover more quickly and effectively after incidents.
1.2.3 Box 1 sets out the key facts relating to the Luton Local Flood Risk Management Strategy.
1.3 The Study Area
1.3.1 Luton is a densely populated town with a rich cultural diversity. Surrounded by Green Belt and situated within the Chilterns Area of Outstanding Natural Beauty, the town benefits from easy access to high quality landscapes, wildlife areas, parks and other sub-regional leisure
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attractions, such as Luton Hoo, Dunstable Downs, and Woburn Abbey. At the same time the town benefits from good strategic north-south access to the midlands and to Greater London via the M1 and Midland Mainline Railway. It is also served by London Luton Airport which is growing and plays an important role in the economy of the town.
Box 1: Key facts about the Luton Local Flood Risk Management Strategy Name of Responsible Authority: Luton Borough Council. Title of plan: Luton Local Flood Risk Management Strategy.
What prompted the plan The Council has a statutory duty as Lead Local Flood Authority to (e.g. legislative, regulatory prepare an LFRMS under the Flood Risk Regulations (2009) and or administrative provision): the Flood and Water Management Act (2010).
Subject (e.g. transport): Flood risk management strategy.
Period covered: 2015 to 2018. Frequency of updates: Action Plan reviewed annually.
Area covered: The Borough of Luton.
Purpose and scope of the See paragraph 1.2.2. plan: Contact point: Flood Risk Management, Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ. Tel: 01582 547371; Email: [email protected]
1.3.2 Despite the underlying permeable geology, Luton has a history of surface water flooding. This is due to rapid development of the town without corresponding upgrade of the local surface water drains. Also, the River Lea and its tributaries in Luton, Houghton Brook, Lewsey Brook, Cat Brook and Riddy Brook, are partially fed by surface water drains and hence have developed flashy responses during heavy rainfall events. Infrastructure and properties within the River Lea corridor are also at risk from groundwater flooding, especially downstream of the town centre. A small area in the most north-eastern part of the borough is at risk of flooding in case of the Sundon reservoir failure.
1.3.3 Flood mitigation works have been carried out across many locations in the borough, including upgrades to and redevelopments of the highway drains, culvert repairs, improving conveyance of the natural channels and removal of silt. However, extensive infill development in the town centre and projected changes to rainfall could add to pressure on the sewer network and watercourses in the Luton catchment.
1.4 Sustainable Development
1.4.1 The UK’s sustainable development agenda is shaped by the Sustainable Development Strategy, Securing the Future (2005) and in planning terms by the National Planning Policy Framework (NPPF), which replaced previous national planning policy (Planning Policy Statements and Planning Policy Guidance notes) in March 2012. The NPPF includes a presumption in favour of sustainable development, which it goes on to interpret in a planning context with reference to the Sustainable Development Strategy.
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The UK Sustainable Development Strategy
1.4.2 Securing the Future (2005) suggests that for a policy to be sustainable, it must respect all five of the principles set out in Figure 1.1. The strategy also recognises that some policies, while underpinned by all five principles, will place more emphasis on certain principles than others. The strategy states that “we want to achieve our goals of living within environmental limits and a just society, and we will do it by means of a sustainable economy, good governance, and sound science” (Securing the Future, 2005).
1.4.3 The strategy states that the five guiding principles are promoted through four shared priorities:
“Sustainable Consumption and Production – Sustainable consumption and production is about achieving more with less. This means not only looking at how goods and services are produced, but also the impacts of products and materials across their whole lifecycle and building on people’s awareness of social and environmental concerns. This includes reducing the inefficient use of resources which are a drag on the economy, so helping boost business competitiveness and to break the link between economic growth and environmental degradation.
“Climate Change and Energy – The effects of a changing climate can already be seen. Temperatures and sea levels are rising, ice and snow cover are declining, and the consequences could be catastrophic for the natural world and society. Scientific evidence points to the release of greenhouse gases, such as carbon dioxide and methane, into the atmosphere by human activity as the primary cause of climatic change. We will seek to secure a profound change in the way we generate and use energy, and in other activities that release these gases. At the same time we must prepare for the climate change that cannot now be avoided. We must set a good example and will encourage others to follow it.
“Natural Resource Protection and Environmental Enhancement – Natural resources are vital to our existence and that of communities throughout the world. We need a better understanding of environmental limits, environmental enhancement and recovery where the environment is most degraded to ensure a decent environment for everyone, and a more integrated policy framework.
“Sustainable Communities – Our aim is to create sustainable communities that embody the principles of sustainable development at the local level. This will involve working to give communities more power in the decisions that affect them and working in partnership at the right level to get things done. The UK uses the same principles of engagement, partnership, and programmes of aid in order to tackle poverty and environmental degradation and to ensure good governance in overseas communities. These priorities for action within the UK will also help to shape the way the UK works internationally, in ensuring that our objectives and activities are aligned with international goals.”
1.4.4 The SEA for the LFRMS will incorporate these key principles at the heart of the assessment process.
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Figure 1.1: Five guiding principles of the UK Sustainable Development Strategy, Securing the Future (2005)
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2 Methodology
2.1 Strategic Environmental Assessment
2.1.1 Strategic Environmental Assessment is a systematic process for evaluating the environmental consequences of proposed plans or programmes to ensure environmental issues are fully integrated and addressed at the earliest appropriate stage of decision making. SEA was introduced to the UK through the EU Directive 2001/42/EC. In England this Directive has been transposed via the Environmental Assessment of Plans and Programmes Regulations 2004. The Luton LFRMS has been screened as a plan or programme which is likely to have significant environmental effects and which is being prepared for water management; it therefore requires an SEA under the Directive.
2.1.2 The SEA is based upon the following principles:
SEA Objectives are used for appraising the potential impacts of objectives, policies and actions proposed for inclusion in the LFRMS, on the various environmental receptors;
Baseline and spatial environmental information is collected and collated. Predicted effects of policies and proposals are evaluated against the baseline and likely evolution thereof in the absence of the strategy;
Alternative options and preferred options for the strategy are appraised using an SEA Framework , combined with careful consideration of baseline conditions; and
Decision-making criteria are devised for all SEA Objectives to assist in monitoring delivery of the plan and any significant effects thereof.
2.2 Assessment Stages
2.2.1 Table 2.1 provides a summary of the procedural steps for the assessment, based on both the National Planning Practice Guidance (DCLG, 2014) and A Practical Guide to the SEA Directive (ODPM, 2005a). The steps shaded in green are the stages addressed in this report. The second column indicates where information about each respective stage can be found (see also Appendix A).
Table 2.1: SEA stages and those addressed in this report
Stage A: Setting the context & objectives, establishing the baseline and Location in this deciding on the scope report 1. Identify other relevant policies, plans, programmes, & sustainability objectives Section 3.3 2. Collect baseline information Section 3.4 3. Identify environmental issues and challenges Section 3.4 4. Develop the Strategic Environmental Assessment Framework Section 3.5 5. Consult on the scope of the Environmental Report Section 3.2
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Stage B: Developing and refining alternatives and assessing effects 1. Test the Plan objectives against the SEA Framework Section 3.6 2. Develop the Plan options including reasonable alternatives Chapter 4 3. Evaluate the likely effects of the Plan and alternatives Chapter 4 4. Consider ways of mitigating adverse, and maximising beneficial effects Chapter 5 5. Propose measures to monitor the significant effects of implementing the Plan Chapter 5 Stage C: Prepare the Environmental Report Including all requirements of the SEA Directive Whole Document Stage D: Publish & consult on the Environmental Report & Plan 1. Consult the consultation bodies and public on the draft Plan and Chapter 6 Environmental Report 2. Appraise significant changes resulting from representations, and amend the n/a Plan Stage E: Post-adoption reporting and monitoring 1. Prepare and publish the post-adoption Environmental Statement n/a 2. Monitor SEA indicators during Plan implementation n/a 3. Respond to adverse effects n/a
2.3 Approach to Assessing Significant Effects
2.3.1 The proposed Objectives, Policies and Actions to be considered for inclusion in the LFRMS are assessed against the baseline and SEA Framework using a three-stage process. An important aspect of this process is selecting the preferred options from a range of reasonable alternatives, and justifying these decisions in light of assessment conclusions.
High level assessments
2.3.2 The appraisal of options engages a strategic High Level Assessment (HLA) technique which uses the SEA Framework to evaluate the likely environmental performance of each option. The SEA Framework was developed through the scoping process (see Chapter 3) and consists of six SEA Objectives with corresponding ‘decision-making criteria’, which are derived from the review of plans, programmes and policies and baseline data.
2.3.3 For each option, with reference to onsite or nearby environmental constraints where relevant, the impact of the proposal on the SEA Objectives is assessed (from Strong Positive, Positive or Neutral, to Negative, Strong Negative or Mixed/Uncertain). The main function of the high level assessment is to identify whether or not the proposals are likely to bring positive, negative or uncertain effects in relation to the SEA Objectives. A benefit of this approach is that a range of options may be assessed, which can then be scrutinised in further detail if a significant number of uncertainties or potential negative effects arise.
2.3.4 Within this SEA, options which are taken forward for detailed assessment are those which are appraised as having greater negative than positive effects overall, or those with one or more
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strong negative impacts on at least one SEA Objective, or those which are likely to significantly affect sites designated pursuant to the Habitats1 or Birds Directives2 (i.e. European sites).
Detailed assessments
2.3.5 Where potential negative effects or uncertainties are identified through the high level assessment in association with a particular option, a secondary level of assessment takes place to examine the proposal in more detail. At the scoping stage it was envisaged that this stage would use Detailed Assessment Matrices to address the range of criteria identified in Annex II of the SEA Directive for determining the likely (positive or negative) significance of effects (Box 2). However, where physical changes are discussed within the LFRMS their precise location and extent is not certain, their delivery is subject to further design and funding, and often several options for implementation still remain.
2.3.6 As a result it was decided that the methodology should be adjusted to suit the level of detail available for assessment. The detailed assessments presented in Chapter 3 instead focus on known environmental constraints within and close to the areas proposed for flood mitigation work, before presenting an assessment against these constraints in the context of the SEA Framework. Where significant effects are predicted or uncertain, a range of mitigation measures is recommended.
Box 2: Criteria for the assessment of significant effects Criteria for determining the likely significance of effects referred to in Article 3(5) of the SEA Directive The characteristics of plans and programmes, having regard, in particular, to a. the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources; b. the degree to which the plan or programme influences other plans and programmes including those in a hierarchy; c. the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development; d. environmental problems relevant to the plan or programme; e. the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste management or water protection).
Characteristics of the effects and of the area likely to be affected, having regard, in particular, to a. the probability, duration, frequency and reversibility of the effects; b. the cumulative nature of the effects; c. the trans boundary nature of the effects; d. the risks to human health or the environment (e.g. due to accidents); e. the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected); f. the value and vulnerability of the area likely to be affected due to: special natural characteristics or cultural heritage;
1 European Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora 2 European Council Directive 2009/147/EC on the conservation of wild birds
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exceeded environmental quality standards or limit values; intensive land-use; the effects on areas or landscapes which have a recognised national, Community or international protection status.
Cumulative effects assessment
2.3.7 As required by the SEA Regulations, cumulative, synergistic and indirect effects are identified and evaluated during the assessment. An explanation of these is as follows:
Indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway;
Cumulative effects arise where several developments each have insignificant effects but together have a significant effect, or where several individual effects of the plan have a combined effect;
Synergistic effects interact to produce a total effect greater than the sum of the individual effects.
2.4 Limitations to the Strategic Environmental Assessment
2.4.1 It is acknowledged that there are a number of limitations and difficulties surrounding the SEA process which stem largely from the nature of strategic assessment at the plan level, using secondary data. In many cases assessment has been undertaken for proposals which do not lead to physical changes on the ground (e.g. engineering works or flood risk mitigation) or without data on environmental limits. Where physical changes are discussed within the LFRMS their precise location and extent is not certain, and their delivery is subject to further design and funding. In these circumstances the appraisals have erred on the side of caution. To address these issues, monitoring proposals should seek to monitor the effects of the plan as it is implemented as well as addressing data gaps.
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3 Scoping
3.1 Scoping Report
3.1.1 The first phase of the SEA was the scoping stage. Scoping is the process of deciding the scope and level of detail of an SEA, including the environmental effects to be considered, the assessment methods to be used, and the structure and contents of the SEA Report. The purpose of the Scoping Report (UEEC, 2014) is to set the criteria for assessment (including the SEA objectives), and establish the baseline data and other information, including a review of relevant policies, programmes and plans.
3.1.2 The Scoping Report presents information in relation to the following tasks:
Identifying other relevant policies, plans and programmes, and sustainability objectives;
Collecting baseline information;
Identifying sustainability opportunities and challenges; and
Developing the SEA Framework.
3.2 Scoping Consultation
3.2.1 The Scoping Report was published for consultation between 26 November 2014 and 14 January 2015.
3.2.2 Responses were received from the three Consultation Bodies (English Heritage, Environment Agency and Natural England) and LBC Officers. Appendix B contains an analysis of scoping consultation responses including a description of how the comments have been taken into account. Following receipt of responses, the SEA information, including the baseline and policy and plan review, was updated. The updated SEA information is included in this Environmental Report.
3.3 Policy, Plan and Programme Review
3.3.1 The LFRMS may be influenced in various ways by other policies, plans or programmes (PPPs), or by external environmental objectives such as those put forward in other strategies or initiatives. The SEA process takes advantage of potential synergies between these PPPs and addresses any inconsistencies or constraints.
3.3.2 The Scoping Report presented an evaluation of the key PPPs that are likely to be relevant to the SEA process and LFRMS. Each PPP is discussed on the basis of how its objectives and environmental requirements affect, or are affected by, the LFRMS. The list was updated following scoping consultation and the revised PPP review can be viewed at Appendix C.
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3.4 Baseline Data and Key Environmental Issues
3.4.1 A key part of the scoping process is the collection of baseline data. The purpose of the exercise is to help identify key opportunities and challenges facing the area which might influence the LFRMS, and to provide an evidence base from which to make the assessment. The baseline sections in the Scoping Report review the social, economic and environmental conditions affecting the borough. One of the purposes of consultation on the Scoping Report was to seek views on whether the data selected was appropriate. Comments were received from a range of stakeholders and in some cases new sources of baseline information were provided or suggested.
3.4.2 The revised baseline data and its likely evolution in the absence of the LFRMS can be viewed at Appendix D, together with a summary of the key environmental issues facing the strategy.
3.5 The SEA Framework
3.5.1 The purpose of the SEA Framework is to provide a means of ensuring that the LFRMS considers the environmental effects of selecting and implementing strategic options. It enables the significant effects of the strategy to be consistently described, analysed and compared.
3.5.2 The SEA Framework consists of objectives which, where practicable, can be expressed in the form of targets, the achievement of which is measurable using indicators. There is no statutory basis for setting objectives but they are a recognised way of considering the environmental effects of a plan and comparing alternatives, and as such provide the basis from which effects of the plan can be tested. The SEA Objectives were derived through consideration of the PPP review, the baseline data collection, and the key sustainability issues identified for the borough. They seek to reflect each of these influences to ensure the assessment process is robust, balanced and comprehensive.
3.5.3 Annex I(f) of the SEA Directive (see Appendix A) contains a list of environmental receptors which require consideration, including biodiversity, flora and fauna, population, human health, soil, water, air, climatic factors, material assets, cultural heritage (including architectural and archaeological heritage), landscape and the inter-relationship between these factors. However, not all of these receptors are likely to be significantly affected by the LFRMS, and some were thus scoped out of the SEA at the scoping stage (see Chapter 3 of the Scoping Report).
3.5.4 Following the receipt of consultation responses on the Scoping Report, the SEA Framework was updated to address the comments received. The updated SEA Framework is presented at Appendix E while Table 3.1 lists the SEA Objectives and their relationship to the SEA Directive requirements.
3.6 Assessing the LFRMS Objectives against the SEA Framework
3.6.1 Table 3.2 presents a compatibility appraisal of the LFRMS objectives against the SEA objectives. The assessment shows that the strategy objectives broadly support the full range of SEA objectives and that there is a good degree of compatibility (or neutrality) between the two sets
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of objectives. Some potential for conflict exists between the strategy objective for Flood Risk Mitigation, and SEA objectives which seek protection for Biodiversity, Landscape and Cultural Heritage, but these largely depend on the how the objective would be implemented by Policies and Actions within the LFRMS.
Table 3.1: Strategic Environmental Assessment Objectives
# SEA Objective Relationship to SEA Directive 1 To conserve and enhance biodiversity Biodiversity, flora and fauna
2 To promote adaptation to climate change Climatic factors; Material assets; Population; Human health 3 To conserve and enhance the historic environment, heritage Landscape; Historic assets and their settings environment 4 To conserve and enhance the character of the landscape Landscape; Historic environment 5 To protect water resources and minimise water pollution Water
6 To conserve and manage natural resources (land, minerals, Material assets; Soil agricultural land, materials)
Table 3.2: Assessment of compatibility between LFRMS and SEA Objectives
Luton Local Flood Risk Management Plan SEA Objectives
Objectives Compatibility Assessment SEA1 SEA2 SEA3 SEA4 SEA5 SEA6 No LFRMS Objective
1 Improve the Understanding of Flood Risk in Luton 0 P 0 0 0 0
2 Flood Risk in Planning and Development Control P P P P P P
3 Emergency Planning, Response and Resilience 0 P 0 0 0 0
4 Flood Risk Mitigation ? P ? ? P P
5 Partnership Working 0 P 0 0 0 0
6 Wider Environmental Benefits P 0 0 P P 0
7 Economics 0 P 0 0 0 0 SEA1 SEA2 SEA3 SEA4 SEA5 SEA6 Key to the Compatibility Assessment Matrix P Compatible ? Potentially incompatible O Incompatible 0 No link
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4 Assessing Reasonable Alternatives
4.1 Responding to the Requirements of the SEA Directive
4.1.1 The SEA Directive requires that the Environmental Report should consider:
‘Reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme’ and give ‘an outline of the reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex I (h)).
4.1.2 The purpose and content of the LFRMS is clearly defined by the 2009 Regulations and 2010 Act which means that there is limited scope for the consideration of markedly different alternatives. However, at points during the development of the LFRMS certain decisions were made for which alternatives were available.
4.1.3 Following the conclusion of the scoping stage, the SEA team contributed to the development of options work carried out for the LFRMS via the High Level Assessment. The purpose of this interaction between the SEA and the LFRMS was to inform and influence the strategy’s development and to provide an early and effective environmental input, and included suggestions for additional reasonable alternatives which could be considered alongside the Policies and Actions proposed for inclusion in the LFRMS. These can be summarised as:
Policy 1: Thresholds for flood investigations;
Alternative 1a: Set lower thresholds for initiating formal flood investigations (e.g. 5 or more adjacent dwellings and/or 1 or more business premises);
CDA 1a: High priority Critical Drainage Areas (CDA) are high risk and have synergy with other projects; medium priority are those with <£25,000 cost per property mitigated; all others are low;
CDA 1b: Alternative - Different approach to prioritisation of CDAs (e.g. medium priority are those with <£30,000 cost per property mitigated; all others are low);
Policy 2: Sand bags;
Alternative 2a: Supply sand bags to selected groups of residents in chosen locations;
Action 6.1: Water efficiency (retrofitting); and
Action 6.1a: Alternative - Water Efficiency (retrofitting) - higher target e.g. 60% of existing housing stock.
4.1.4 Checks were made during the High Level Assessment to ensure that the preferred alternative does not lead to significant negative effects on the SEA objectives. The findings of the High Level Assessment, which are described in detail in section 4.2 below, concluded that none of the proposed Objectives, Policies or Actions were predicted to result in (a) greater negative than positive effects overall, (b) one or more strong negative impacts on at least one SEA
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Objective, or (c) likely significantly effects on European sites. As result, none required detailed further assessment.
4.1.5 However, a number of Flood Alleviation Scheme (FAS) proposals for certain Critical Drainage Areas were flagged as leading to uncertain or mixed environmental effects the nature of which would largely depend on their means of implementation. Further discussion with the Council confirmed that a secondary level of options generation had taken place for reducing flood risk in CDAs. These options do not strictly form part of the LFRMS as they are subject to funding and final scheme design, however, it was decided that they would form the most appropriate basis for detailed assessment at the current stage.
4.2 High Level Assessment
4.2.1 The findings of the HLA are summarised in matrix format which illustrates the impact of each proposal on each of the SEA Objectives and can be viewed at Appendix F. This is accompanied below by a commentary discussing and comparing the options’ environmental performance in relation to the SEA Objectives. The commentary is structured according to each of the LFRMS Objectives under which Policies and Actions are proposed.
LFRMS Objective 1: Improve the Understanding of Flood Risk in Luton
4.2.2 This objective has few direct links with the SEA Objectives, as illustrated at Table 3.2. However, it is compatible with SEA Objective 2 (To promote adaptation to climate change).
4.2.3 One Policy is proposed under the objective, which sets thresholds for the circumstances under which a formal investigation of a flooding incident would be initiated by the Council as LLFA. The thresholds are based on flood characteristics and significance criteria which strike an appropriate balance between recording and investigating the causes and consequences of flooding, and the cost and resources required to undertake an investigation. The thresholds address human health, economic activity and environment (although there is no direct reference to biodiversity) and so are predicted to positively affect SEA Objectives 2 to 6, as is its corresponding Action in the Action Plan.
4.2.4 Two alternatives to this proposed Policy were considered: to set higher thresholds which would result in fewer formal investigations, or to set lower thresholds which would result in a greater quantity of information being collected on the causes and consequences of flooding. Setting higher thresholds was rejected as not being a reasonable alternative because the preferred thresholds are already higher than national thresholds. The preferred thresholds are considered by the Council to be justified because of the densely populated nature of Luton which means that a given flooding event typically results in a greater number of properties being affected than would be the case in a less densely populated area experiencing the same volume of rainfall.
4.2.5 Setting lower thresholds is predicted to lead to greater positive effects on SEA Objectives 2 to 6 than the Policy as proposed, because formal investigations would be initiated more frequently. However, the cost of undertaking formal investigations is not insignificant and may not be the best use of limited resources. The Council may still investigate flooding below the
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preferred thresholds, but would do so at the Council’s discretion, not necessarily following the prescribed process under the legislation.
4.2.6 Although not specifically encapsulated in its Policy or Action Plan, this section of the LFRMS also considers how to prioritise implementation of flood risk solutions in Critical Drainage Areas (CDA). High priority CDAs are based on overall verified risk and potential synergy with other projects, using sound engineering judgement, as recommended by the Surface Water Management Plan3. Medium priority CDAs are those with a cost per property mitigated of less than £25,000, with all other CDAs being low priority. This is considered to be a reasonable approach to prioritisation based on risk and evidence which seeks to achieve an acceptable balance between costs and benefits, and predicted to positively affect all six of the SEA Objectives.
4.2.7 However, it was also considered reasonable to exame an alternative approach to prioritisation whereby medium priority CDAs would be all those with a cost per property mitigated of less than £30,000. This would have the effect of promoting the three CDAs which are currently proposed to be low priority to medium priority and result in flood risk solutions being developed to protect a further 50 dwellings at risk from a 0.5m flood depth under the 1in100yr rainfall event. This is predicted to have greater positive effects on SEA Objectives 1 to 6 in comparison to the currently proposed approach to prioritisation, however, there would clearly be a significant cost in selecting this as the preferred approach.
4.2.8 Fourteen Actions are proposed under LFRMS Objective 1 within the Action Plan, all of which are predicted to positively affect SEA Objective 2 (climate change adaptation). The majority of Actions are predicted to be neutral with regard to the other SEA Objectives. However, to “Produce riparian advice/guidance” is predicted to positively affect SEA1 (biodiversity), SEA3 (heritage), SEA5 (water quality) and SEA6 (natural resources). Similarly “Groundwater study/investigation” is predicted to positively affect SEA3, SEA5 and SEA6.
LFRMS Objective 2: Flood Risk in Planning and Development Control
4.2.9 This objective is assessed as broadly compatible with all the SEA Objectives. Similarly, each of its nine Actions is predicted to result in positive or neutral effects on the SEA Objectives. “Floodplain protection” is predicted to positively affect SEA1 (biodiversity), SEA3 (heritage), SEA4 (landscape), SEA5 (water quality) and SEA6 (land and natural resources) by promoting the restoration of natural river forms and floodplains as areas of biodiversity and improved amenity value. “Development and flood risk” is assessed in a similar light because it seeks to prevent development in areas of high flood risk, recreate river corridors in urban areas and provide space for water, wildlife and recreation.
4.2.10 “Assessment of Sustainable Drainage Systems (SuDS) applications” and “SuDS retrofitting for reducing runoff” are expected to result in positive effects for biodiversity (SEA3) and landscape because they often include areas of wetland habitat and semi-natural vegetation with amenity
3 Capita Symonds (2012): Luton Surface Water Management Plan – Final Draft [Updated September 2013]. Accessed online at [October 2014]: http://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Luton%20SWMP%20-%20Final%20Draft%20- %20V1%207.pdf
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value (SEA4), and can improve water quality (SEA5) by removing pollutants. All of the Actions under this objective are predicted have positive or strong positive effects on SEA2 (climate change adaptation).
4.2.11 The safeguarding of land from development in the Upper Lea Catchment near Lewsey Farm, Houghton Brook and Limbury is considered to have strong positive effects because of the presence of environmental assets in these areas, including River Lea County Wildlife Site (CWS), Leagrave Common CWS, River Lea District Wildlife Site (DWS), Lewsey Park DWS, Waulud’s Bank Scheduled Ancient Monument (SAM) and archaeological areas on the Historic Environment Record (HER15812, HER820 and HER115).
LFRMS Objective 3: Emergency Planning, Response and Resilience
4.2.12 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The two Actions proposed under this objective are assessed in a similar way because they focus on procedure and planning rather than on-the-ground activities.
4.2.13 One policy is proposed under this objective, which makes it clear that the Council does not provide sand bags to the general public for use during flood events, instead using its limited supply to protect highways and public buildings. The policy is broadly neutral with respect to the SEA Objectives, with minor positive effects on SEA3 (heritage) because some public buildings are listed. An alternative approach could be to reverse this policy so that the Council does provide sand bags, or provides sand bags to selected groups of residents in chosen locations. This would lead to minor positive effects on SEA2 (climate change adaptation) but may not be an efficient use of resources and does not address the stated limitations of sand bags as a flood protection measure.
LFRMS Objective 4: Flood Risk Mitigation
4.2.14 This objective is compatible with SEA2 (climate change adaptation), SEA5 (water quality) and SEA6 (land and natural resources) but potentially incompatible with SEA1 (biodiversity), SEA3 (heritage) and SEA4 (landscape) depending on where and how mitigation is implemented.
4.2.15 In total, 40 Actions are proposed under this objective, the majority of which involve studies, consultation and data gathering to investigate which solutions may be effective and acceptable, or inspection, maintenance and use of powers. Furthermore, while most of the Actions target flood risk mitigation in a broad area, they are not sufficiently spatially specific to enable assessment of potential environmental effects other than in the broadest terms. All of these Actions (Act4.7 to Act4.40 in Appendix F) are predicted to lead to at least minor positive effects on SEA2 (climate change adaptation), and a handful may also have beneficial effects on water quality (SEA5).
4.2.16 However, two Flood Alleviation Schemes (FAS) and projects proposed under the four high priority CDAs are further developed and can be assessed to a slightly finer level of detail at this stage. Each of these is predicted to have strong beneficial effects for climate change adaptation (SEA2) but mixed or uncertain effects on at least one other SEA Objective.
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4.2.17 The Houghton Regis FAS (Act4.1 in Appendix F) aims to reduce flood risk in the Upper Lea around Houghton Brook, Lewsey Brook and Limbury, and could involve construction of a flood storage area on the Houghton Brook between the M1 and Houghton Regis (see Figure 4.1, map reference 01). This is a greenfield site just outside of the borough boundary and currently in arable use (Agricultural Land Classification (ALC) Grade 2). The proposal could negatively affect an Iron Age or Roman settlement (HER15812) which underlies the western part of the site, depending on the final layout and design. It would also result in a loss of best and most versatile (BMV) agricultural land and could negatively affect landscape character, however, it is expected to deliver significant flood risk benefits to properties in parts of the Lewsey Farm, Parkside up to Marsh Farm and Limbury areas. No further details were available for appraisal and it is recommended that the scope for significant environmental effects is assessed at the project proposal stage.
4.2.18 The Icknield Way FAS (Act4.2, map reference 02) aims to utilise SuDS (e.g. swale and sewer upgrades) to alleviate surface water system surcharges at Icknield Way. The site is within the urban area but could negatively affect Limbury/Biscot Roman settlement (HER115), an extensive area of Roman occupation indicative of a large village, which underlies the southern part of the site, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals). No further details were available for appraisal and it is recommended that the scope for significant environmental effects is assessed at the project proposal stage.
4.2.19 Potential capital solutions in the Barton Road / Great Bramingham CDA (Act4.3) include flood storage areas to the north. Environmental constraints in the vicinity include Dray's Ditches SAM, the line of a route-way known as the Theedway (HER 10843) which may have prehistoric origins, the Chilterns Area of Outstanding Natural Beauty (AONB), Galley & Warden Hills Local Nature Reserve (LNR), and Grade 2 agricultural land. Consequently, the proposal could negatively affect biodiversity, heritage features, landscape character and BMV agricultural land, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals).
4.2.20 Potential capital solutions in the Chapel Street / Arndale Centre CDA (Act4.4) include installation of a new culvert from the corner of Chapel Street and George Street to Manor Road Park. Environmental constraints in the vicinity include Luton medieval town (HER16993), the Town Centre Conservation Area, and a number of listed buildings. Consequently, the proposal could negatively affect heritage features, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals).
4.2.21 Potential capital solutions in the Barnfield West Academy / Poynters Road CDA (Act4.5) include removal of silt from Lewsey Brook to restore flow capacity and provide in-bank flood storage. This could result in negative effects on the River Lea CWS, River Lea DWS, Lewsey Park DWS depending on the final extent and methods proposed; it could also result in long-term benefits to biodiversity and water quality if a sensitive river restoration design is adopted. Positive effects would be expected for climate change adaptation.
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Figure 4.1: Critical Drainage Areas and potential improvement/alleviation schemes
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4.2.22 Potential capital solutions in the Vauxhall Way CDA (Act4.6) include: flood storage areas along Vauxhall Way; increased conveyance from Airport Way underpass; and creation of a storage area or wetland in the vacant lot adjacent to Parkway Road and associated pipe work to route excess flow under Parkway Road and the A505 into the River Lea. Environmental constraints in the vicinity include The Chase CWS, Luton Hoo Park CWS, River Lea CWS, and Luton Parkway Verges DWS. Depending on the layout and final design proposals, the works could negatively affect any of these assets with consequent impacts on ecological receptors. However, certain parts of the proposal could result in long-term positive effects, including water quality improvements in the River Lea and creation of new wetland habitats. Positive effects would be expected for climate change adaptation.
LFRMS Objective 5: Partnership Working
4.2.23 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The three Actions proposed under this objective are assessed in a similar way because they focus on stakeholder engagement, cooperation, data sharing and partnership working, rather than on-the-ground activities which could result in environmental effects.
LFRMS Objective 6: Wider Environmental Benefits
4.2.24 This is the only objective that is not directly related to SEA2 (climate change adaptation), although it is compatible with SEA1 (biodiversity), SEA4 (landscape) and SEA5 (water quality). However, the Actions proposed under this objective are predicted to positively affect SEA2 (climate change adaptation) and SEA5 (water quality) because they promote water efficiency and SuDS retrofitting. Act6.3 has additional positive effects on biodiversity (SEA1), landscape (SEA4) and the sustainable use of land (SEA6) because it promotes the creation and enhancement of wetland habitats and green infrastructure.
4.2.25 One reasonable alternative was considered in relation to Act6.1 Water Efficiency (retrofitting) whereby a higher target could be set for the installation of easy-fit water saving devices, aiming for 60% of the existing housing stock instead of 20%. This is predicted to have greater positive effects on SEA2 and SEA5 by comparison but would also require a higher level of investment. Furthermore, as the Action Plan is to be reviewed on a regular basis there is nothing to prevent this target being aspired to over the longer term as the LFRMS is implemented.
LFRMS Objective 7: Economics
4.2.26 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The six Actions proposed under this objective are assessed in a similar way because they focus on funding opportunities, partnership schemes and insurance, rather than on-the-ground activities which could result in environmental effects.
Conclusions
4.2.27 Overall the High Level Assessment has found the Luton LFRMS to be a broadly sustainable strategy with a wide range of positive effects and few negative environmental effects. Using the summary matrix from the HLA of the proposed Policies and Actions, the options with the most
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adverse impact(s) on the SEA Objectives can be identified. These options are summarised below:
Action 4.1: Capital Improvement Project – Houghton Regis Flood Alleviation Scheme
Action 4.2: Capital Improvement Project – Icknield Way Flood Alleviation Scheme
Action 4.3: Capital Improvement Project – Barton Road / Great Bramingham High Priority CDA (BRGB) Flood Alleviation Scheme
Action 4.4: Capital Improvement Project – Chapel Street / Arndale Centre High Priority CDA (CHAST) Flood Alleviation Scheme
Action 4.5: Capital Improvement Project – Barnfield West Academy / Poynters Road High Priority CDA (BWPR) Flood Alleviation Scheme
Action 4.6: Capital Improvement Project – Vauxhall Way High Priority CDA (VAUX) Flood Alleviation Scheme
4.2.28 Whilst none of these Capital Improvement Projects meet the criteria for further assessment set out in paragraph 2.3.4, a further stage of options generation has taken place for Actions 4.3 to 4.6 and these are taken forward for detailed assessment.
4.3 Detailed Assessment
4.3.1 The following sections present a detailed assessment of the likely significant effects of currently preferred options for the four Capital Improvement Projects (BRGB, CHAST, BWPR, VAUX).
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Action 4.3: Capital Improvement Project – Barton Road / Great Bramingham High Priority CDA (BRGB) Flood Alleviation Scheme
Environmental Constraints Data Environmental constraints within the area: . 13 national priority habitats which include deciduous woodland, lowland calcareous grassland and lowland fens. . Two archaeological sites: Dray's Ditches SAM, the line of a route-way known as the Theedway (HER 10843) which may have prehistoric origins. . Little Bramingham Farmhouse is a listed building. . There are 29 greenspace areas which include 26 amenity greenspaces and three natural and semi-natural greenspace. . Four areas marked as fluvial flood zone 3. . One CWS; Bramingham Woods. . Two DWS; Turnpike Drive and Whitehorse Vale. Environmental constraints within 250m: . 44 national priority habitats which include deciduous woodland, lowland calcareous grassland, lowland fens and lowland meadow. . Source protection zones 2 and 3. . Agricultural land: Grade 2, Grade 3, Grade 4. . 5 archaeological sites, which include ‘Dray’s Ditches’ prehistoric boundary at Luton/Streatley and Roman settlement at Limbury/Biscot, Luton. . The one listed building is Little Bramingham Farmhouse. . One ancient monument, which has been amended to include the eastern extent of Dray’s Ditches. . There are 51 greenspace sites all of which are amenity greenspace, allotment and leisure gardens or natural and semi-natural greenspaces. . Chilterns ANOB. . Greenbelt. . 22 areas marked as fluvial flood zone 2, and 9 areas marked as fluvial flood zone 3. . One Site of Special Scientific Interest (SSSI) at Galley and Warden Hills. . One LNR at the Galley and Warden Hills SSSI. . There are 11 CWS. . Four DWS which are Great Bramingham Park, the River Lea, Turnpike Drive and Whitehorse Vale.
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Preferred Options . Increasing conveyance capacity by enlarging the pipe diameter of the culvert buried beneath Icknield Park playing field . Constructing swales within Icknield Park playing field to create a preferential overland flow route connecting Catsbrook with the River Lea . Creating above-ground flood storage areas by constructing bunds to create detention basins near Turnpike Drive, Burford Close and further upstream in the rural area . Increasing community resilience by installing temporary or permanent flood gates to protect properties affected by flood depths up to 600mm . Installing permeable paving, water butts and other SuDS measures to improve source control and attenuation Likely Significant Effects on SEA Objectives 1 The route of the culvert and swales in Icknield Park would pass through and into the River Lea CWS and DWS and installation would result in at least a temporary loss of semi-natural habitats resulting in impacts on protected species which may be present, including for example badger, bats (if tree roosts are affected), nesting birds, great crested newt, reptiles and water vole (otter is not thought to be present on the River Lea 4). Minor temporary negative effects are predicted at a local scale over the short term. In the long term swales could increase biodiversity within Icknield Park by creating additional wetland habitats, resulting in minor permanent positive effects at the local scale. Although the location of flood storage bunds near Turnpike Drive and Burford Close is not specified the scope for negative effects is significant. This area of north Luton features the Galley & Warden Hills SSSI/LNR/CWS, Sunshine Riding Stables CWS, Great Bramingham Park DWS and Turnpike Drive DWS, together with 11 areas mapped nationally as priority habitat (deciduous woodland and lowland calcareous grassland). Temporary or permanent loss of these features would result in minor to major negative effects at a local to national scale, and could also lead to impacts on protected species. 2 Overall minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term. However, some measures (e.g. flood gates) could result in a minor increase in flood risk to properties in adjacent areas downstream. Creating swales in Icknield Park could adversely affect its use as a playing field, resulting in a functional loss of green infrastructure and minor indirect effects on human health. 3 Icknield Park lies within Limbury/Biscot Roman settlement (HER115: Extensive area of Roman occupation: indicative of large village). Earthworks required for the construction of swales or installation of a larger culvert could result in the disturbance or destruction of archaeological remains, resulting in permanent minor to moderate impacts at a local to regional scale. Although the location of flood storage bunds near Turnpike Drive and Burford Close is not specified the scope for negative effects is significant. This area of north Luton features Dray’s Ditches SAM (HER113/HER10843: Triple-ditched boundary: Bronze Age in origin: enlarged and strengthened in the Iron Age. Crosses Icknield Way). Temporary or permanent loss of these features would result in major negative effects at a national scale, while the setting of these
4 BedsLife (2009): Bedfordshire & Luton Species Action Plan: European Otter. Last updated September 2009. Accessed online [May 2015]: http://www.bedscape.org.uk/BRMC/newsite/docs/bedslife/bap%20plans/SAP%202007%20otter.pdf
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features is also at risk over the long term.
4 Although the location of flood storage bunds near Turnpike Drive and Burford Close is not specified, the area is within the Green Belt and within or adjacent to the Chilterns AONB. New permanent flood storage areas could result in minor to moderate negative effects on a nationally important feature over the long term. 5 Short term minor negative impacts to water quality during construction of the culvert and swales in Icknield Park are predicted at a local scale due to introduction of sediments to the water course. 6 Although the location of flood storage bunds near Turnpike Drive and Burford Close is not specified, the area features extensive tracts of BMV (Grade 2) agricultural. New permanent flood storage areas could result in minor to moderate negative effects at a local scale over the long term. Recommended Mitigation . Temporary or permanent loss of features within designated sites (including SSSI/LNR/CWS/DWS) should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated via habitat restoration, creation or compensation, and species translocation. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Functional loss of playing fields would need to be replaced on a like-for-like basis to ensure community accessibility to these facilities is maintained. . Temporary or permanent loss of features associated with Dray Ditches SAM and/or Limbury/Biscot Roman settlement should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery and interpretation of remains). . It should be possible to reduce negative landscape effects via a high quality design which responds to landscape constraints and uses an appropriate selection of materials. Development should be supported by an LVIA. The existing structural framework of hedgerow/mature trees should be adequately conserved, with gapping-up of hedgerows where appropriate. . Standard site procedures as recommended by the Environment Agency (such as Pollution Prevention Guidelines 5 – Works and Maintenance in or Near Water) will be required to ensure that no contaminants or effluent (e.g. oil, fuel or chemical spills) are released into aquatic environments during construction. Construction methodologies should contain specific measures to protect the water courses from changes in morphology, turbidity or flow regime. . Mitigation for the loss of agricultural land is not feasible, however, losses should be avoided or minimised through site selection, layout and design, while measures should be taken to ensure that good quality top soil is either re-used on site or put to productive use off site.
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Action 4.4: Capital Improvement Project – Chapel Street / Arndale Centre High Priority CDA (CHAST) Flood Alleviation Scheme
Environmental Constraints Data Environmental constraints within the area: . There are five national priority habitats, all of which are deciduous woodland. . Two archaeological sites, both of which are Luton medieval town. . Four conservation areas: Plaiters Lea, Rothesay, Town Centre and Luton South. . There are 54 listed buildings. . There are five green spaces, four are amenity greenspaces and the other is a churchyard and cemetery. . Four areas marked as fluvial flood zone 2 and four areas marked as fluvial flood zone 3. . One public water supply borehole. Environmental constraints within 250m: . There are 21 national priority habitats, including deciduous woodland and lowland calcareous grassland. . Source protection zones 1, 2 and 3. . Three archaeological areas have been highlighted near this CDA, all are Luton medieval town. . There are five conservation areas; Rothesay, Town Centre, High Town, Plaiters Lea and Luton South. . 58 listed buildings. . 16 greenspaces have been highlighted; seven amenity greenspace, three churchyards and cemeteries, two allotment and leisure gardens, two urban parks and gardens, one major sports and leisure site and one natural and semi-natural greenspace. . 11 areas marked as flood zone 2, 8 areas marked as flood zone 3. . There are three CWS at church cemetery, Luton, Dallow Down and the River Lea. . Two DWS, one is the River Lea and the other at Stockwood Park. . Two public water supply boreholes. Preferred Options . Increasing conveyance capacity along London Rd/Castle St & Chapel Street to reduce flooding around the Arndale Shopping Centre . Increasing community resilience by installing temporary or permanent flood gates to protect properties affected by flood depths up to 600mm . Installing a new 1.5m diameter pipe from George Street to Manor Road Park to create a preferential flow route connecting to the River Lea
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. Installing additional gullies along London Rd/Castle St & Chapel Street to increase conveyance Likely Significant Effects on SEA Objectives 1 The route of the new 1.5m diameter pipe from George Street to Manor Road Park would pass close to and/or into the River Lea CWS and DWS and installation would result in at least a temporary loss of semi-natural habitats resulting in impacts on protected species which may be present in Manor Road Park, including for example badger, bats (if tree roosts are affected), nesting birds, great crested newt, reptiles and water vole. Minor temporary negative effects are predicted at a local scale over the short term. 2 Overall minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term. However, some measures (e.g. flood gates) could result in a minor increase in flood risk to properties in adjacent areas downstream. Installing a new 1.5m diameter pipe from George Street to Manor Road Park could also increase the extent and depth of flooding at Manor Road Park. 3 Increasing conveyance capacity along London Rd/Castle St & Chapel Street could negatively affect the character and setting of the Town Centre and Luton South Conservation Areas and their various listed buildings/structures, as well as Luton medieval town (HER16993), resulting in temporary minor impacts at a local scale. Installing a new 1.5m diameter pipe from George Street to Manor Road Park could negatively affect the character and setting of the Town Centre Conservation Area and its various listed buildings/structures, as well as Luton medieval town (HER16993), resulting in temporary minor impacts at a local scale. 4 No strategically significant effects predicted.
5 Short term minor negative impacts to water quality during construction of the new 1.5m diameter pipe from George Street to Manor Road Park are predicted at a local scale due to introduction of sediments to the water course. 6 No strategically significant effects predicted. Recommended Mitigation . Temporary or permanent loss of features within designated sites (including CWS/DWS) should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated via habitat restoration, creation or compensation, and species translocation. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Temporary or permanent loss of features associated with the Town Centre and Luton South Conservation Areas, their various listed buildings/structures, and Luton medieval town should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery and interpretation of remains).
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. Standard site procedures as recommended by the Environment Agency (such as Pollution Prevention Guidelines 5 – Works and Maintenance in or Near Water) will be required to ensure that no contaminants or effluent (e.g. oil, fuel or chemical spills) are released into aquatic environments during construction. Construction methodologies should contain specific measures to protect the water courses from changes in morphology, turbidity or flow regime.
Action 4.5: Capital Improvement Project – Barnfield West Academy / Poynters Road High Priority CDA (BWPR) Flood Alleviation Scheme
Environmental Constraints Data Environmental constraints within the area: . Four amenity green spaces at Browning Road, Byron Road, Poets Green and Poynters Road. Environmental constraints within 250m: . Source protection zones 2 and 3. . Agricultural land: Grade 2. . There are seven greenspaces, six being amenity greenspace and one an urban park and garden. . Four areas marked as flood zone 2. . Two CWS, one at Dunstable to Luton disused railway, and the other is the River Lea. . One DWS, River Lea. Preferred Options . Increasing conveyance capacity by increasing pipe sizes along Ridge Way Avenue, Goldstone Crescent & Jillifer Road . Creating below-ground flood storage in the back gardens of properties near the east side of Poynters Road to reduce ponding and attenuate runoff into the Lewsey Farm area . Installing SuDS measures in private properties to improve source control and attenuation . Installing additional gullies to increase conveyance and entry capacity in the local road network to pick up overland flows Likely Significant Effects on SEA Objectives 1 No strategically significant effects predicted. 2 No strategically significant effects predicted. 3 No strategically significant effects predicted. 4 No strategically significant effects predicted.
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5 No strategically significant effects predicted. 6 No strategically significant effects predicted. Recommended Mitigation . No mitigation required at the strategic level, however, further investigations (e.g. ecological survey) may be necessary at the detailed project proposal stage.
Action 4.6: Capital Improvement Project – Vauxhall Way High Priority CDA (VAUX) Flood Alleviation Scheme
Environmental Constraints Data Environmental constraints within the area: . There are two national priority habitats, both are lowland calcareous grassland. . One listed building on the south side of Kimpton Road Office Block, Vauxhall Motors. . Eight amenity green spaces. . The Chase CWS, and Mixes Hill DWS and Dairyborn Scarp DWS. Environmental constraints within 250m: . 21 national priority habitats including deciduous woodland and lowland calcareous grassland. . Source protection zones 1, 2 and 3. . Agricultural land: Grade 3. . There are three archaeological sites; Stopsley medieval settlement, Luton; Round Green medieval settlement, Luton; Crawley Green medieval settlement, Luton. . Two listed buildings; one building on the south side of Kimpton Road Office Block, Vauxhall Motors, the other is Stockingstone Road Round Green St Cristopher’s Church. . There are 25 green spaces: 20 amenity greenspaces, four natural and semi-natural greenspaces and one churchyard and cemetery. . Green belt. . Three areas marked as flood zone 2, three areas marked as flood zone 3. . Five CWS’s have been identified; church cemetery, Luton; Honeygate and Crick Hills; Luton Hoo Park; River Lea and The Chase. . There are three DWS’s; Dairyborn Scarp; Luton Parkway Verges and Mixes Hill.
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Preferred Options . Increasing conveyance capacity near the Kimpton Road / Airport Way roundabout - either via a thrust pipe under Airport Way to the south, or via open cut towards Vauxhall Road (then piped under Parkway Road to an overland flow route towards the River Lea . Creating a series of above-ground flood storage areas to the east of Parkway Road and in the open space area between Eaton Valley Road and Vauxhall Way . Increasing community resilience by installing temporary or permanent flood gates for the industrial yard near Vauxhall Way to protect properties affected by flood depths up to 600mm . Installing permeable paving and other SuDS measures to improve source control and attenuation . Installing additional gullies at 25m intervals to increase conveyance and entry capacity in the local road network to pick up overland flows Likely Significant Effects on SEA Objectives 1 The route of the thrust pipe or open cut is not final but together with flood storage areas to the east of Parkway Road could take land from within or close to the River Lea CWS, Dairyborn Scarp DWS and Luton Parkway Verges DWS, while there are many areas mapped nationally as priority habitats (primarily deciduous woodland and lowland calcareous grassland). Installation would result in at least a temporary loss of semi-natural habitats resulting in impacts on protected species which may be present, including for example badger, bats (if tree roosts are affected), nesting birds, great crested newt, reptiles and water vole. Minor temporary negative effects are predicted at a local scale over the short term. In the long term an open cut could increase biodiversity by creating additional wetland habitats, resulting in minor permanent positive effects at the local scale. There are no ecological designations or nationally mapped priority habitats in the open space between Eaton Valley Road and Vauxhall Way, but the area features a number of mature trees and grassland. Creation of flood storage areas here would result in at least a temporary loss of semi-natural habitats resulting in impacts on protected species which may be present, including for example badger, bats (if tree roosts are affected), nesting birds and reptiles. Minor temporary negative effects are predicted at a local scale over the short term. In the long term an above-ground flood storage area could increase biodiversity by creating additional wetland habitats, resulting in minor permanent positive effects at the local scale. 2 Overall minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term. However, some measures (e.g. flood gates) could result in a minor increase in flood risk to properties in adjacent areas or downstream. 3 Although the location/route of the thrust pipe / open cut and flood storage areas to the east of Parkway Road are not final they could alter the setting of Kimpton Road Office Block Listed Building and/or Someries Castle Scheduled Monument, resulting in minor to moderate negative effects to a nationally important feature over the long term. There are no known heritage features in the open space between Eaton Valley Road and Vauxhall Way. 4 Although the route of the thrust pipe or open cut could run through Green Belt, the proposal would not be likely to detract from its primary purpose and no strategically significant effects are predicted.
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There are no designated landscape features in the open space between Eaton Valley Road and Vauxhall Way.
5 Short term minor negative impacts to water quality during construction of the thrust pipe / open cut and flood storage areas are predicted at a local scale due to introduction of sediments to the water course. 6 Although the route of the thrust pipe or open cut could run through BMV (Grade 3) agricultural land, any losses are likely to small scale and no strategically significant effects are predicted. Recommended Mitigation . Temporary or permanent loss of features within designated sites (including CWS/DWS) should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated via habitat restoration, creation or compensation, and species translocation. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible. . Temporary or permanent loss of features associated with Kimpton Road Office Block Listed Building and/or Someries Castle should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery and interpretation of remains). . Standard site procedures as recommended by the Environment Agency (such as Pollution Prevention Guidelines 5 – Works and Maintenance in or Near Water) will be required to ensure that no contaminants or effluent (e.g. oil, fuel or chemical spills) are released into aquatic environments during construction. Construction methodologies should contain specific measures to protect the water courses from changes in morphology, turbidity or flow regime.
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4.4 Cumulative Effects Assessment
4.4.1 This section considers the cumulative, synergistic and secondary effects of the LFRMS taken as whole. The results of the cumulative effects assessment are presented in Table 4.1.
Table 4.1: Cumulative, synergistic and indirect effects
SEA Objective Cumulative effects assessment To conserve and The majority of Objectives, Policies and Actions proposed within the LFRMS enhance biodiversity will have positive or neutral effects on this objective. However, Actions 4.3, 4.4 and 4.6 are predicted to lead to direct or secondary negative effects, which may act cumulatively and synergistically resulting in a magnified overall effect in combination unless recommended mitigation measures are applied. To promote adaptation The majority of Objectives, Policies and Actions proposed within the LFRMS to climate change will have positive or neutral effects on this objective. Actions 4.3, 4.4 and 4.6 are predicted to lead to direct or secondary negative effects, which may act cumulatively and synergistically, however, these are generally outweighed by the overall positive effects. To conserve and The majority of Objectives, Policies and Actions proposed within the LFRMS enhance the historic will have positive or neutral effects on this objective. environment, heritage However, Actions 4.3, 4.4 and 4.6 are predicted to lead to direct or assets and their settings secondary negative effects, which may act cumulatively and synergistically resulting in a magnified overall effect in combination unless recommended mitigation measures are applied. To conserve and The majority of Objectives, Policies and Actions proposed within the LFRMS enhance the character will have positive or neutral effects on this objective. of the landscape Negative effects are only predicted as a result of Action 4.3, and are not expected to act cumulatively or synergistically. To protect water The majority of Objectives, Policies and Actions proposed within the LFRMS resources and minimise will have positive or neutral effects on this objective. water pollution However, Actions 4.3, 4.4 and 4.6 are predicted to lead to direct or secondary negative effects, which may act cumulatively and synergistically resulting in a magnified overall effect in combination unless recommended mitigation measures are applied. To conserve and The majority of Objectives, Policies and Actions proposed within the LFRMS manage natural will have positive or neutral effects on this objective. resources (land, Negative effects are only predicted as a result of Action 4.3, and are not minerals, agricultural expected to act cumulatively or synergistically. land, materials)
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5 Monitoring
5.1 Monitoring Framework
5.1.1 Table 5.1 provides proposals for a programme of monitoring to measure the strategy’s performance in relation to the SEA Objectives against which significant effects were identified. The monitoring programme may still be adjusted in response to representations on the LFRMS and its SEA. The final monitoring programme will be included in the Post Adoption Statement. Consultees are invited to suggest any further indicators that they feel are necessary or suitable for inclusion in the monitoring programme.
Table 5.1: Proposed monitoring framework
Receptor Monitoring data Biodiversity . Land (ha) take for Luton flood risk management measures within designated sites (including outside of the borough boundary) . Re-instatement of habitats which are temporarily affected and successful implementation of mitigation strategies Climate change . Increased risk of flooding in areas downstream of flood risk management measures . Loss (ha) of public open space for Luton flood risk management measures within designated sites (including outside of the borough boundary) Heritage . Number of heritage assets at risk of flooding . Proportion of conservation area ground at risk from flooding . Number of flood risk management measures implemented that conserve and enhance heritage assets . Number of designated and non-designated heritage assets harmed by flood risk management measures, including impacts on their settings Landscape . Land take (ha) for Luton flood risk management measures within Chilterns AONB (including outside of the borough boundary) Waterbodies . Reported pollution incidents in waterbodies resulting from Luton flood risk management measures (including outside of the borough boundary) Natural resources . Loss (ha) of BMV agricultural land for Luton flood risk management measures within Chilterns AONB (including outside of the borough boundary)
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6 Summary and Consultation Arrangements
6.1 Summary and Next Steps
6.1.1 The Environmental Report presents the findings of a Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy.
6.1.2 The report forms part of the evidence base upon which the strategy is based. It includes an assessment of the reasonable alternatives which were considered during preparation of the strategy, including alternative options for future flood risk management solutions, and makes a series of recommendations for mitigating and monitoring the strategy’s significant effects.
6.1.3 The LFRMS and its SEA will be published for a period of representations. Comments received on both documents will be considered by the Council prior to finalising and adopting the strategy. Any significant changes to the strategy which arise as a result of consultation will need to be assessed as part of the SEA process, which may lead to a further edition of, or addendum to the Environmental Report.
6.1.4 SEA Regulations 16.3c)(iii) and 16.4 require that a ‘statement’ be made available to accompany the strategy as soon as possible after its adoption. The purpose of the Environmental Statement is to outline how the SEA process has informed and influenced the planning process and demonstrate how consultation on the SEA was taken into account. The statement will contain the following information:
The reasons for choosing the strategy as adopted in the light of other reasonable alternatives dealt with;
How environmental considerations were integrated into the strategy;
How consultation responses were taken into account; and
Measures that are to be taken to monitor the significant effects of the strategy.
6.2 Consultation Arrangements
6.2.1 This Environmental Report is available online or in hard copy to view at the following addresses:
www.luton.gov.uk/floodriskmanagement Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ
6.2.2 The consultation period runs from 10 August to 7 September 2015. Responses should be submitted via the Luton Borough Council consultation portal or to the following addresses:
Email: [email protected] Flood Risk Management, Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ
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References and Bibliography
Department for Communities and Local Government (DCLG; 2014): Planning Practice Guidance. Available online at: http://planningguidance.planningportal.gov.uk/
Department for Environment, Food and Rural Affairs (Defra; 2011): Soil Strategy for England.
Environment Agency (2007), Pollution Prevention Guidelines 5 – Works and Maintenance in or Near Water. Available online at: http://publications.environment-agency.gov.uk/PDF/PMHO1107BNKG-E- E.pdf
Luton Borough Council (LBC; 2010): Luton Climate Change Adaptation Action Plan.
Office of the Deputy Prime Minister (ODPM; 2005a): A Practical Guide to the SEA Directive.
ODPM (2005b): Government Circular: Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System.
Urban Edge Environmental Consulting (UEEC; 2014): Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy: Scoping Report.
UEEC (2015): Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy: Options Assessment Report.
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Appendix A: Annex 1 of the SEA Directive
Directive 2001/42/EC of the European Parliament and of the Council on the Assessment of the Effects of Certain Plans and Programmes on the Environment
Annex 1: Information for Environmental Reports (referred to in Article 5(1))
Requirement Location in this SEA a. An outline of the contents and main objectives of the plan or programme, Sections 1.2, 3.6, 3.3 and of its relationship with other relevant plans and programmes. and Appendix C b. The relevant aspects of the current state of the environment and the likely Section 3.4 and evolution thereof without implementation of the plan or programme. Appendix D c. The environmental characteristics of areas likely to be significantly affected. Section 3.4 and Appendix D d. Any existing environmental problems which are relevant to the plan or Section 3.4 and programme including, in particular, those relating to any areas of a particular Appendix D environmental importance, such as areas designated pursuant to Council Directive 79/409/EEC on the conservation of wild birds and the Council Directive 92/43/EEC on the conservation of habitats and species. e. The environmental protection objectives, established at international, Section 3.3 and Community or Member State level, which are relevant to the plan or Appendix C programme and the way those objectives and any environmental considerations have been taken into account during its preparation. f. The likely significant effects on the environment, including short, medium Chapter 4 and and long-term effects, permanent and temporary effects, positive and Appendix F negative effects, and secondary, cumulative and synergistic effects, on issues such as biodiversity, population, human health, flora, fauna, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the inter-relationship between these factors. g. The measures envisaged to prevent, reduce and as fully as possible offset Chapter 5 any significant adverse effects on the environment of implementing the plan or programme. h. An outline of the reasons for selecting the alternatives dealt with, and a Chapter 4 and Section description of how the assessment was undertaken including any difficulties 2.4 (such as technical deficiencies or lack of know-how) encountered in compiling the required information. i. A description of the measures envisaged concerning monitoring in Chapter 5 accordance with Article 10 (regulation 17). j. A non-technical summary of the information provided under paragraphs a Non Technical to i. Summary
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Appendix B: Consultation Analysis
Please see insert.
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D Analysis of Consultation Responses Strategic Environmental Assessment of the Luton Local Flood Risk Management Strategy Organisation Date Comment ID Para Comments Document Summary of reaction, if any needed
Natural England 07/01/2015 1 4.1 and 12.1 We welcome consideration of nationally designated nature conservation sites, i.e. nearby SSSIs, and the inclusion of Scoping Report Noted. protecting biodiversity within the SEA objectives. 2 4.1.1 The document identifies that there are no internationally designated sites within Luton Borough. Natural England Scoping Report Amendments made to baseline; Scoping Report would recommend that it also clarifies whether there are internationally designated sites further afield that could be not re-issued. affected by the strategy. This would be particularly useful if your authority decides to screen out the need for a Habitats Regulations Assessment of the strategy as the SEA screening report allows you to present the information to underpin your decision on the test of likely significant effects to European Sites. 3 7.1 and 12.1 We welcome consideration of designated landscapes, i.e. The Chilterns Area of Outstanding Natural Beauty, and the Scoping Report Noted. inclusion of landscape character within the SEA objectives. 4 10.1 and 12.1 We welcome consideration of Best and Most Versatile agricultural Land and the inclusion of agricultural land within the Scoping Report Noted. SEA objectives.
Environment Agency 15/01/2015 5 4.5.1 Welcome the reference in the SEA, 4.5.1, acknowledging the River Lee is one of the borough’s most extensive wildlife Scoping Report Noted. sites, and that measures to alleviate flood risk (whether promoted by the LFRMS or other flood risk management plan) should seek to avoid significant ecological impacts, recognising that the impact of specific proposals would need to be considered on a site by site basis and as part of the next stage of the SEA. 6 11.2.2 Paragraph 11.2.2 states that “The chemical status of the three surface water bodies in Luton does not require Scoping Report Amendments made to baseline; Scoping Report assessment” - this is incorrect. not re-issued. For Cycle 2, from 2013, the chemical status has been assessed and the result is that the water body/bodies FAIL. This and associated information can be found in the open access Catchment Data Explorer at: http://environment.data.gov.uk/catchment-planning/WaterBody/GB106038033391
English Heritage 14/01/2015 7 - English Heritage recommends that our updated guidance (2013) on Strategic Environmental Assessment (SEA) / Scoping Report Noted. Sustainability Appraisal (SA) and the Historic Environment is used to inform the environmental assessment. 8 - English Heritage welcomes the opportunity to engage in the assessment and Scoping Report Noted. preparation of the strategy for the following reasons: • The vulnerability of most heritage assets (designated and non-designated) to flooding, including occasional flooding, and the potential harm to or loss of their significance. • The potential impact of flood risk management measures on heritage assets and their settings, including impacts on water-related or water-dependent heritage assets. • The potential impact of changes in groundwater flows and chemistry on preserved organic and paleo-environmental remains. Where groundwater levels are lowered as a result of measures to reduce flood risk, this may result in the possible degradation of remains through de-watering, whilst increasing groundwater levels and the effects of re- wetting could also be harmful. 8 - • The potential impact on heritage assets of hydromorphological adaptations. This can include the Scoping Report Noted. modification/removal of historic in-channel structures, such as weirs, as well as physical changes to rivers with the potential to impact on archaeological and paleo-environmental remains. • The potential implications of flood risk on securing a sustainable use for heritage assets, including their repair and maintenance. • The opportunities for conserving and enhancing heritage assets as part of an integrated approach to flood risk management and catchment based initiatives, this including sustaining and enhancing the local character and distinctiveness of historic townscapes and landscapes. • The opportunity for increasing public awareness and understanding of appropriate responses for heritage assets in dealing with the effects of flooding as well as the design of measures for managing flood risk and improving resilience. • The opportunities for improving access, understanding or enjoyment of the historic environment and heritage assets as part of the design and implementation of flood risk management measures.
UE-0161 Consultation Analysis_2_150720 Appendix B 1 / 4 Analysis of Consultation Responses Strategic Environmental Assessment of the Luton Local Flood Risk Management Strategy Organisation Date Comment ID Para Comments Document Summary of reaction, if any needed 9 - English Heritage advises that the relevant local authorities’ conservation and archaeological officers are involved Scoping Report Noted. throughout the preparation, assessment and implementation of the strategy, as they are often best placed to advise on: • baseline information on the historic environment and heritage assets through the county-based Historic Environment Record (HER); • the significance of designated and non-designated heritage assets; • local historic environment issues and priorities, as for example heritage assets vulnerable to the effects flooding and or those that have been harmed by previous flooding events; • how flood risk management measures can be tailored to avoid or minimise potential adverse impacts on the historic environment; • the nature and design of any required mitigation measures; and • opportunities for securing wider benefits for the future conservation, management and enjoyment of heritage assets, whether through the design and implementation of individual measures and schemes and wider catchment management proposals. 10 PPP Review English Heritage acknowledges that the current review will concentrate on those policies, plans, programmes that are Scoping Report PPP updated where necessary. most relevant to the flood risk management and to the implementation of the strategy. Relevant historic environment Plaiter's Lea is the only Conservation Area considerations, however, should still be fully taken into account in the review as for example: affected by fluvial flood risk, which is limited to a At national level: short, narrow stretch of the Lea between John - The NPPF; Flood Risk Regulations 2009; Flood and Water Management Act 2010; National Flood and Coastal Erosion Street and Guildford Street. A Conservation Area Risk Management Strategy. Appraisal is not available. At local level: - Conservation area appraisals and accompanying management plans, particularly for conservation areas identified as at risk of flooding. 11 Baseline In accordance with our guidance on SEA/SA English Heritage recommends that a broad definition of the historic Scoping Report Noted. environment is used to establish the baseline. This will include areas, buildings, features and landscapes with statutory protection (designated heritage assets), together with those parts of the historic environment which are locally valued and important (non-designated heritage assets) and also the historic character of the landscape, townscape and seascape. The cultural heritage overview of Luton in Section 6 of the report is useful, including reference to Heritage at Risk. 12 Baseline Together with our general advice on baseline information and the historic environment, the following data sources can Scoping Report Historic environment records and related be particularly useful in providing locally specific information, as for example: information were used at the options assessment • Historic Environment Records: These can be interrogated in various ways, as for example, heritage assets located in stage. identified Flood Risk Areas or river catchments, and or heritage assets associated with rivers and other water- dependent habitats or water-level management regimes (e.g. historic bridges, weirs, mills). • Preliminary Flood Risk Assessments: These assessments may identify heritage assets as a key site at risk of flooding. • The character of the historic landscape and townscape and other valued historic landscapes: Historic characterisation studies such as county based historic landscape characterisations can help to identify surviving water meadows or areas where such historic land management could be reinstated as part of wider catchment management proposals. Urban historic characterisation studies may be useful in providing up-to-date, mapped data on present day land uses and the character of places as well as their historical development, including the historical extent of river floodplains and associated land uses. Such information may be of help informing the location and sensitive design of Sustainable Drainage Systems within the existing urban fabric.
13 Baseline English Heritage also recommends that the baseline takes account of areas of archaeological importance and the Scoping Report Historic environment records and related potential for unrecorded archaeology: This may include buried, waterlogged archaeological and paleo-environmental information were used at the options assessment remains of significant interest and fragility that can be associated river valleys, floodplains and stage. wetland areas. 14 Baseline English Heritage recommends that, wherever possible, data sets are mapped. This will aid the assessment process by Scoping Report Noted. helping to identify those heritage assets or groups of assets that may be at most risk from flooding and or potentially impacted by proposed measures to help manage flood risk or improve resilience.
UE-0161 Consultation Analysis_2_150720 Appendix B 2 / 4 Analysis of Consultation Responses Strategic Environmental Assessment of the Luton Local Flood Risk Management Strategy Organisation Date Comment ID Para Comments Document Summary of reaction, if any needed 15 Baseline For both designated and non-designated heritage assets, an important consideration is the contribution of their setting Scoping Report Noted. to their heritage interest or significance. The significance of a heritage asset can be harmed or lost by development within its setting. New development within the setting of a heritage asset may also offer opportunities for enhancing or better revealing its significance, for example, removing a culvert may serve to improve the character and experience of a historic townscape or landscape (relevant to the River Lea through Luton town centre).
16 Baseline With regard to heritage assets identified as at risk in the National Heritage at Risk Register or local registers, Scoping Report Historic environment records and related consideration could be given to screening the records to identify if the at risk status is associated in some way with information were used at the options assessment flood risk and or whether flood risk might exacerbate the problem. For example, this might include whether a stage. conservation area at risk is within a high flood risk area, or whether the sustainable use of a listed building at risk might be hampered by its location in a flood risk area as a result of limitations put on its use or the design solution for its repair and reuse. Up-to-date information on the National Heritage at Risk Register is available via: http://www.english- heritage.org.uk/caring/heritage-at-risk/ 17 Key Issues Environmental problems, issues and opportunities affecting the historic environment in the context of the strategy Scoping Report Key issues updated. could include the following depending on the local baseline and the nature and prevalence of flood risk: • Most heritage assets are vulnerable to flooding and a range of heritage assets are likely to be at risk of flooding, which may result in harm to or loss of their significance. This may be as a result of direct flood damage as well as inappropriate remedial works. • Proposed flood risk management measures and measures to improve resilience have the potential to impact on the significance of heritage assets, including the contribution made by their setting. • Securing the sustainable use of heritage assets, including those identified as at risk, may be hindered by their location in high flood risk areas. • Accommodating measures such as Sustainable Drainage Systems, whilst sustaining and enhancing the character of historic townscapes and landscapes and the significance of areas of archaeological interest and or potential interest.
18 SEA English Heritage recommends the SEA assessment framework includes a specific headline objective for the SEA topic Scoping Report SEA Framework updated. Framework on Archaeology and Cultural Heritage, for example: ‘Conserve and enhance the historic environment, heritage assets and their settings’ The current draft SEA objective on page 53 of your report could be amended as above. 19 SEA In addition to the head-line objective, it can also be beneficial for the SEA framework to include relevant sub-objectives Scoping Report Noted. Framework (decision-making criteria) to help ensure that all the key heritage issues are considered and potential effects (direct and indirect) appropriately assessed. We note the decision making criteria in Appendix IV which we welcome. Examples of other decision-making criteria that may be relevant for the strategy include: • Will the measures reduce the number of heritage assets at risk of flooding? • Will the measures harm the significance of designated and non-designated heritage assets, including their setting? • Will the measures help secure the sustainable use of a heritage asset and or improve its maintenance? • Will the measures lead to changes in groundwater levels or chemistry that could alter the hydrological setting of water-dependent heritage assets, including paleo-environmental deposits? • Will the measures involve hydromorphological adaptations comprising the modification/removal of weirs or other in- channel structures and physical changes to rivers including de-canalisation or re-cutting old meanders? • Will the measures conserve and enhance the local character and distinctiveness of historic townscapes and landscapes? • Will the measures increase public awareness and understanding of appropriate responses for heritage assets affected by flooding and the design and implementation of other measures aimed at risk management or improving resilience? • Will the measures provide opportunities for improved access, understanding and enjoyment of the historic environment?
UE-0161 Consultation Analysis_2_150720 Appendix B 3 / 4 Analysis of Consultation Responses Strategic Environmental Assessment of the Luton Local Flood Risk Management Strategy Organisation Date Comment ID Para Comments Document Summary of reaction, if any needed 20 Monitoring The English Heritage guidance on SEA/SA recognises that a combination of different types of indicators is likely to be Scoping Report Noted. necessary as part of the assessment process. However, the priority should be the inclusion of indicators which clearly demonstrate the significant impact(s) of the plan/strategy on the historic environment, whether positive or negative. For example, recording numbers of assets may be appropriate as part of the baseline, but are not normally recommended for monitoring impacts. Appendix 4 of our SEA/SA guidance provides examples of indicators for the historic environment that can be tailored to local circumstances and suggests ways in which they can be framed to: • describe the baseline or state of the historic environment; • monitor the type of impact or outcome; and • track wider policy responses or actions taken to conserve and improve the historic environment, and mitigate any degradation (including avoiding or rectifying adverse impacts). 21 Monitoring With respect to specific indicators for the strategy additional, topic specific indicators might include: Scoping Report Consider for inclusion in Environmental Report • Number of heritage assets at risk of flooding and/or Environmental Statement. • Proportion of conservation area ground at risk from flooding • Number of flood risk management measures implemented that conserve and enhance heritage assets • Number of designated and non-designated heritage assets harmed by flood risk management measures, including impacts on their settings
LBC Ecology Officer 15/01/2015 22 Chapter 4 Oaket Wood and Winch Hill wood are partly in Luton & partly in Herts, and part of Oosey Hill CWS is in CBeds. A Scoping Report Amendments made to baseline; Scoping Report further DWS was added in Nov 2013 – Whitehorse Vale DWS, which is the parcel of land in Luton, N of Bramingham not re-issued. Wood. 23 Chapter 4 NB three sites are currently being considered by Natural England as SSSIs – Dallow Downs CWS, Cowslip Meadow Scoping Report Amendments made to baseline; Scoping Report CWS and Bradger’s Hill CWS, the latter may include parts of Stopsley Common DWS too. A decision on all three is not re-issued. likely later this year.
LBC Transportation 02/12/2014 24 General On list of figures/tables at front (and also on the relevant pages of those), need consistent approach to name of Capita Scoping Report Amended. Strategy & Regulation Symonds work. In some places it is in full, but others say “Cap Symonds” Manager 25 General To be consistent with the actual LFRMS, the name of main river should be “Lea” & not “Lee”. Scoping Report Amended. 26 Chapter 4 May be worth checking the list of CWS’s on page 11 with that in the latest version of emerging Local Plan, because it Scoping Report See comments 22 and 23 above. looks to me as though there are a couple missing 27 Chapter 4 In relation to Para 4.5.1 on page 13, surely the presence or not of flooding in a particular area of biodiversity interest Scoping Report Amended. could have an impact on survival of certain species. This doesn’t seem to be mentioned. 28 Chapter 6 In relation to cultural heritage sites close to Luton, surprised that Sundon Historic Park + Garden doesn't get a mention Scoping Report Amended. in Para 6.1.2. 29 General In Table 8.1 (and also on list of figures/tables page at front) note incorrect spelling of “Barnfield”. Scoping Report Amended.
UE-0161 Consultation Analysis_2_150720 Appendix B 4 / 4 SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
Appendix C: Policy, Plan & Programme Review
Please see insert.
E SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
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F Review of Policies, Plans and Programmes
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy
Biodiversity
UN Convention on Biological Diversity (1992) The aims of the Convention include the conservation of biological diversity The LFRMS should include provision which enhances biological (including a commitment to significantly reduce the current rate of diversity (e.g. provision of woodland and greenspace) where biodiversity loss), the sustainable use of its components and the fair and possible in order to meet the requirements of the UN Convention, equitable sharing of the benefits arising out of the utilization of genetic whilst at the same time avoiding biodiversity loss through careful resources. choice of flood risk management actions. Bern Convention on the Conservation of European The Convention seeks to conserve wild flora and fauna and their natural Protected species are present throughout the borough, so the Wildlife and Natural Habitats (1979) habitats, and to monitor and control endangered and vulnerable species. LFRMS should ensure that where flood risk management actions are necessary in areas containing these species, adequate mitigation is carried out before development commences. Monitoring of such species will also be necessary. DEFRA Wildlife and Countryside Act (1981, as The principle mechanism for the legislative protection of wildlife in Great Protected species are present throughout the borough, so the amended) Britain. LFRMS should ensure that where flood risk management actions are necessary in areas containing these species, adequate mitigation is carried out before development commences. Monitoring of such species will also be necessary. Natural Environment and Rural Communities Act 2006 A wide ranging act, parts of which re-organised the Government’s arms- Section 41 of the Act lists habitats and species of principal length bodies for countryside management. The most important part of importance in England. The biodiversity duty requires all public the Act in relation to biodiversity is the section 40 duty on all public bodies bodies to take biodiversity into account when undertaking their to have regard to the conservation of biodiversity in England, when normal functions, including flood defence. carrying out their normal functions. Conservation of Habitats and Species Regulations The UK transposition of EC Directive 92/43/EC on the conservation of There are no European sites in the borough, but there is a 2010 (as amended) natural habitats and of wild fauna and flora. possibility that European protected species could be affected The Regulations provide for the designation and protection of 'European directly or indirectly by development within the borough. The sites', the protection of 'European protected species', and the adaptation LFRMS should explore opportunities to promote their conservation. of planning and other controls for the protection of European Sites. The Regulations make it an offence (subject to exceptions) to deliberately capture, kill, disturb, or trade in the animals listed in Schedule 2, or pick, collect, cut, uproot, destroy, or trade in the plants listed in Schedule 4. Making Space for Nature: a review of England’s The Making Space for Nature report, which investigated the resilience of The LFRMS should aim to promote flood risk management actions wildlife sites and ecological network (2010) England’s ecological network to multiple pressures, concluded that which support the resilience of and improves sub regional England’s wildlife sites do not comprise of a coherent and resilient ecological networks. This includes through facilitating the provision ecological network. The report advocates the need for a step change in of a high quality green infrastructure network, enhancements to conservation of England’s wildlife sites to ensure they are able to adapt habitats, promoting connections between biodiversity sites and and become part of a strong and resilient network. The report summarises facilitating the right conditions for native species. what needs to be done to improve England’s wildlife sites to enhance the resilience and coherence of England’s ecological network in four words; more, bigger, better, and joined. There are five key approaches which Policy Plan and Programme Review: Appendix C; page 1
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy encompass these, which also take into account of the land around the ecological network: (i) Improve the quality of current sites by better habitat management. (ii) Increase the size of current wildlife sites. (iii) Enhance connections between, or join up, sites, either through physical corridors, or through ‘stepping stones’. (iv) Create new sites. (v) Reduce the pressures on wildlife by improving the wider environment, including through buffering wildlife sites. To establish a coherent ecological network 24 wide ranging recommendations have been made which are united under five key themes: (i) There is a need to continue the recent progress in improving the management and condition of wildlife sites, particularly our SSSIs. We also make recommendations for how these should be designated and managed in ways that enhance their resilience to climate change. (ii) There is a need to properly plan ecological networks, including restoration areas. Restoration needs to take place throughout England. However, in some areas, both the scale of what can be delivered to enhance the network, and the ensuing benefits for wildlife and people, will be very high. These large areas should be formally recognised as Ecological Restoration Zones. (iii) There are a large number of surviving patches of important wildlife habitat scattered across England outside of SSSIs, for example in Local Wildlife Sites. We need to take steps to improve the protection and management of these remaining wildlife habitats. ‘Protection’ will usually be best achieved through incentive-based mechanisms, but at times may require designation. (iv) There is a need to become better at deriving multiple benefits from the ways we use and interact with our environment. (v) It will not be possible to achieve a step-change in nature conservation in England without society accepting it to be necessary, desirable, and achievable. The Natural Choice: Securing the Value of Nature. Published in June 2011, the Natural Environment White paper sets out the The LFRMS should seek to help deliver the aspirations of the White The Natural Environment White Paper. HM Government’s plans to ensure the natural environment is protected and Paper. The LFRMS should seek to support natural systems in the Government 2011. fully integrated into society and economic growth. The White Paper sets area and consider facilitating people and communities to access out four key aims: and enjoy the natural environment. (i) Protecting and improving our natural environment There is a need to improve the quality of our natural environment across England, moving to a net gain in the value of nature. It aims to arrest the decline in habitats and species and the degradation of landscapes. It will protect priority habitats and safeguard vulnerable non-renewable Policy Plan and Programme Review: Appendix C; page 2
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy resources for future generations. It will support natural systems to function more effectively in town, in the country and at sea. It will achieve this through joined-up action at local and national levels to create an ecological network which is resilient to changing pressures. (ii) Growing a green economy The ambition is for a green and growing economy which not only uses natural capital in a responsible and fair way but contributes to improving it. It will properly value the stocks and flows of natural capital. Growth will be green because it is intrinsically linked to the health of the country’s natural resources. The economy will capture the value of nature. It will encourage businesses to use natural capital sustainably, protecting and improving it through their day-to-day operations and the management of their supply chains. (iii) Reconnecting people and nature The ambition is to strengthen the connections between people and nature. It wants more people to enjoy the benefits of nature by giving them freedom to connect with it. Everyone should have fair access to a good- quality natural environment. It wants to see every child in England given the opportunity to experience and learn about the natural environment. It wants to help people take more responsibility for their environment, putting local communities in control and making it easier for people to take positive action. (iv) International and EU leadership The global ambitions are: • internationally, to achieve environmentally and socially sustainable economic growth, together with food, water, climate and energy security; and • to put the EU on a path towards environmentally sustainable, low-carbon and resource-efficient growth, which is resilient to climate change, provides jobs and supports the wellbeing of citizens. UK National Ecosystem Assessment (2011) The UK National Ecosystem Assessment is the first analysis of the UK’s The LFRMS should seek to reflect the emerging importance of the natural environment and the benefits it provides to society and economic ecosystem service concept. It should be aware of the impacts that prosperity. The assessment leads on from the Millennium Ecosystem flood risk management actions can have on these services and Assessment (2005) and analyses services provided by ecosystem set against recognise the services that have the potential to be performed by eight broad habitat types. The ecosystem services provided by these the natural environment in the LFRMS area. habitat types have been assessed to find their overall condition. The assessment sought to answer ten key questions: 1) What are the status and trends of the UK’s ecosystems and the services they provide to society? 2) What are the drivers causing changes in the UK’s ecosystems and their services? 3) How do ecosystem services affect human well-being, who and Policy Plan and Programme Review: Appendix C; page 3
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy where are the beneficiaries, and how does this affect how they are valued and managed? 4) Which vital UK provisioning services are not provided by UK ecosystems? 5) What is the current public understanding of ecosystem services and the benefits they provide? 6) Why should we incorporate the economic values of ecosystem services into decision making? 7) How might ecosystems and their services change in the UK under plausible future scenarios? 8) What are the economic implications of different plausible futures? 9) How can we secure and improve the continued delivery of ecosystem services? 10) How have we advanced our understanding of the influence of ecosystem services on human well-being and what are the knowledge constraints on more informed decision making? Biodiversity 2020: a Strategy for England’s Wildlife A new England Biodiversity Strategy, which introduces a package of The LFRMS should seek to address the objectives of the biodiversity and Ecosystem Services (2011) measures to halt the decline of our wildlife and its habitats. The Strategy strategy by fully addressing biodiversity considerations through the includes the following priorities: LFRMS development process. - Creating 200,000 hectares of new wildlife habitats by 2020 – this is In particular the LFRMS should support flood risk management equivalent to an area the size of Warwickshire actions which avoid sensitive areas and seek to support sub regional - Securing 50% of SSSIs in favourable condition, while maintaining biodiversity networks. at least 95% in favourable or recovering condition - Trialling new approaches to setting fishing quotas to reduce discards - Encouraging more people to get involved in conservation by supporting wildlife gardening and outdoor learning programmes - Introducing a new designation for local green spaces to enable communities to protect places that are important to them The Strategy will help to deliver the Natural Environment White Paper. National Planning Policy Framework (2012)) Replacing PPS9 (Biodiversity and Geological Conservation), the policy sets The LFRMS should aim to promote flood risk management action out the Government’s planning policies for England and is a framework for which protects and supports the resilience of and improves sub local policies and how they should be applied. In response to the UN regional ecological networks. This includes through facilitating the resolution 24/187, the framework performs a sustainable development role provision of a high quality green infrastructure network, (economic, social and environmental) in the planning system, outlining 12 enhancements to habitats, promoting connections between core planning principles for plan and decision making, including - biodiversity sites and facilitating the right conditions for native Conserving and enhancing the natural environment; species. Local geodiversity assets should also be recognised by the The planning system should contribute and enhance the natural and local LFRMS. environment by; Protecting and enhancing valued landscapes, geological conservation interests and soils; Policy Plan and Programme Review: Appendix C; page 4
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy Recognising the wider benefits of ecosystem services; Minimising impacts on biodiversity and providing net gains in biodiversity where possible, including by establishing coherent ecological networks that are more resilient to current and future pressures; Preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. Plans and decisions should encourage effective use of brownfield sites and take into account the economic benefits of agricultural land when assessing development, seeking to utilise areas of poorer quality land. Local planning strategic approach should plan positively for creation, protection, enhancement and management of networks of biodiversity and green infrastructure. Maintain character and scenic beauty of undeveloped coast and landscapes, especially; Heritage coast, National Parks, the Broads and Areas of Outstanding Natural Beauty. Planning and decision making should occur at a landscape scale across local authority boundaries and assess noise, air and light pollution, considering cumulative impacts. The framework offers guidance to protect and enhance biodiversity specifically regarding priority species/habitats, protected sites and potential/proposed/possible protected sites. Bedfordshire and Luton Wildlife Working Group Since 2001 the Bedfordshire and Luton Wildlife Working Group has been The LFRMS should aim to promote flood risk management action (2001): Bedfordshire and Luton Biodiversity Action developing and maintaining the individual plans for species and habitats as which protects and supports local biodiversity, including the Plan part of the county's Biodiversity Action Plan, which is comprised of: habitats and species for which action plans have been prepared. Seven species action plans; and Thirteen habitat action plans.
Climate Change
UN Framework Convention on Climate Change (1992) Sets an overall framework for intergovernmental efforts to tackle the Background document. challenge posed by climate change. IPCC Kyoto Protocol to the United Nations Commits member nations to reduce their emissions of carbon dioxide and Background document. Framework Convention on Climate Change (1997) other greenhouse gases, or engage in emissions trading if they maintain or increase emissions of these gases. UK Climate Change Act 2008 (2008) The 2008 Climate Change Act seeks to manage and respond to climate The LFRMS will be a key document in seeking to increase the change in the UK, by: resilience of the borough to the effects of climate change.
Policy Plan and Programme Review: Appendix C; page 5
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy Setting ambitious, legally binding targets; Taking powers to help meet those targets; Strengthening the institutional framework; Enhancing the UK’s ability to adapt to the impact of climate change; and Establishing clear and regular accountability to the UK Parliament and to the devolved legislatures. Significantly, the Act sets a legally binding target of at least an 80 percent cut in greenhouse gas emissions by 2050 and at least a 34 percent cut by 2020. These targets are against a 1990 baseline. National Planning Policy Framework (2012) Replacing ‘Planning and Climate Change: Supplement to PPS1’, the policy The LFRMS will be a key document in seeking to ensure sets out the Government’s planning policies for England and is a development does not take place in flood risk areas, and does not framework for local policies and how they should be applied. In response increases flood risk in existing or potential (due to climate change) to the UN resolution 24/187, the framework performs a sustainable flood risk areas. development role (economic, social and environmental) in the planning system, outlining 12 core planning principles for plan and decision making, including - Meeting the challenge of climate change, flooding and coastal change; Adoption of proactive strategies to mitigate and adapt to climate change in line with the objectives and provisions of the Climate Change Act 2008, taking full consideration of flood risk, coastal change and water supply and demand. Support low carbon future by helping to increase the use of renewable and low carbon sources in line with the National Policy Statement for Renewable Energy Infrastructure. Seeks to ensure that all types of flood risk is taken into account ,over the long term, at the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas of highest risk Under the principle of ‘promoting healthy communities’ local and neighbourhood plans should identify community green spaces of particular importance to them, ensuring any development of these areas is ruled out in a majority of circumstances. National Policy Statements (NPS): Renewable Energy It sets out the Government’s policy (England and Wales) for delivery of Background document. Infrastructure NPS (July 2011) major energy infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance on generic impacts and mitigation may be helpful to local planning authorities (LPAs) in preparing their local impact reports. Luton Climate Change Adaptation Action Plan (Luton The Luton Climate Change Adaptation Action Plan sets out an extensive The LFRMS will be a key document in seeking to ensure Borough Council, 2010) series of key actions to promote adaptation, organised under the following development does not take place in flood risk areas, and does not
Policy Plan and Programme Review: Appendix C; page 6
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy themes: increases flood risk in existing or potential (due to climate change) Adapting Luton’s built environment to a changing climate; flood risk areas. Minimising flood risk in Luton; Managing and enhancing Luton’s green infrastructure to improve resilience to a changing climate; Increasing the resilience of the Council’s services delivery; Increasing workforce capability to adapt to climate change; Raising awareness and communicating climate change risks; and To provide leadership across the borough in increasing resilience and adapting to climate change.
Health
EC Together for Health: A Strategic Approach for the Building on current work, this Strategy aims to provide an overarching Background document. EU 2008-2013 (2007) strategic framework spanning core issues in health as well as health in all policies and global health issues. National Planning Policy Framework (2012) Replacing PPG17 (Planning for Open Space, Sport and Recreation), the The LFRMS should support the provision and protection of new policy sets out the Government’s planning policies for England and is a sporting, leisure, recreational facilities, public rights of way and framework for local policies and how they should be applied. In response National trails in the borough and help facilitate enhancements to to the UN resolution 24/187, the framework performs a sustainable sub regional multifunctional green infrastructure networks (Local development role (economic, social and environmental) in the planning Green Spaces). system, outlining 12 core planning principles for plan and decision making, including – Promoting healthy communities; The framework sets out open space, sport and recreation considerations for neighbourhood planning bodies These include an assessment of needs and opportunities; setting local standards; maintaining an adequate supply of open space and sports and recreational facilities; planning for new open space and sports and recreational facilities; and planning obligations. Local and neighbourhood plans should identify community green spaces of particular importance (including recreational and tranquillity) to them, ensuring any development of these areas is ruled out in a majority of circumstances.
Historic Environment
UNESCO World Heritage Convention (1972) Aims of the Convention are: defining cultural and natural heritage; The protection and enhancement of cultural heritage assets and recognising the protection and conservation; understanding the value; and their settings should be a key consideration for the LFRMS. establishing 'the World Heritage fund'. Council of Europe: Convention on the Protection of Aims for signatories to protect their architectural heritage by means of The protection and enhancement of cultural heritage assets and the Architectural Heritage of Europe (1985) identifying monuments, buildings and sites to be protected; preventing the their settings should be a key consideration for the LFRMS. disfigurement, dilapidation or demolition of protected properties; providing financial support by the public authorities for maintaining and
Policy Plan and Programme Review: Appendix C; page 7
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy restoring the architectural heritage on its territory; and supporting scientific research for identifying and analysing the harmful effects of pollution and for defining ways and means to reduce or eradicate these effects. Council of Europe: The Convention on the Protection The convention defines archaeological heritage and identifies measures for Archaeological assets, both potential and realised should be of Archaeological Heritage (Revised) (Valetta its protection. Aims include integrated conservation of the archaeological provided with full consideration through the development of the Convention) (1992) heritage, and financing of archaeological research and conservation. LFRMS. Council of Europe: European Landscape Convention Aims to promote the protection, management and planning (including The LFRMS should support flood risk management action which (2006) active design and creation of Europe's landscapes, both rural and urban, protects, and where possible improves the landscape character of and to foster European co-operation on landscape issues. the area. DCMS Ancient Monuments and Archaeological Areas An act to consolidate and amend the law retain to ancient monuments, to Flood risk management actions affecting areas of archaeological Act (1979) make provision of matters of archaeological or historic interest, and to resource will need to have due regard to this Act. provide grants by secretary of state to the Architectural Heritage fund. National Planning Policy Framework (2012) Replacing PPS (Planning for the Historic Environment), the policy sets out The protection and enhancement of cultural heritage assets and the Government’s planning policies for England and is a framework for their settings should be a key consideration for the LFRMS. local policies and how they should be applied. In response to the UN resolution 24/187, the framework performs a sustainable development role Archaeological assets, both potential and realised should be (economic, social and environmental) in the planning system, outlining 12 provided with consideration by the LFRMS, proportionate to their core planning principles for plan and decision making, including – significance. Conserving and enhancing the historic environment;
Local planning authorities should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. If any heritage asset is affected by a proposed development, planning applicants must supply relevant historical records and consult using appropriate expertise. The significance of any impact to heritage asset should be taken into account by the local authority. Deliberate neglect or damage to the asset should not be taken into account when assessing the impact of the development to the asset. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional. Non-designated heritage assets of archaeological interest that are demonstrably of equivalent significance to scheduled monuments, should be considered subject to the policies for designated heritage assets. Where a proposed development will lead to substantial harm to a designated heritage asset, local authorities should refuse consent unless the development meets one of the exception criteria outlined in the framework. To enhance or better reveal their significance, Local planning authorities Policy Plan and Programme Review: Appendix C; page 8
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy should look for opportunities within Conservation Areas, World Heritage Sites and within the setting of heritage assets. Proposals that preserve the setting, reveal the significance of the asset or make a positive contribution should be treated favourably. Planning (Listed Buildings and Conservation Areas) An act to consolidate certain enactments relating to special controls in Flood risk management actions affecting listed buildings and Act (1990) respect of buildings and areas of special architectural or historic interest conservation areas will need to have due regard to this Act. with amendments to give effect to recommendations to give effect to recommendations of the Law Commissions.
Landscape
Council of Europe: European Landscape Convention Aims to promote the protection, management and planning (including Background document. (2006) active design and creation of Europe's landscapes, both rural and urban, and to foster European co-operation on landscape issues. The Chilterns Conservation Board: The Chilterns The Management Plan for the AONB for 2014-2019 contains a number of The LFRMS should seek to reflect the ambitions of the Management AONB Management Plan 2009-14 broad aims for the management of the Chilterns AONB. The more detailed Plan and support the integrity of the AONB. policies and actions in the Plan outline how these aims will be achieved by the Board and all other parties with an interest in the AONB.
Material Assets
EC Sixth Environmental Action Programme 2002-2012 Natural resources and waste (in particular recycling) has been identified as Background document. (2002) one of four priority areas for Europe. The EAP requires member states to achieve 22% of electricity production from renewable energies by 2010; to significantly reduce the volumes of waste generated and the quantity going to disposal; and to give preference to waste recovery and recycling. EC Directive on Electricity Production from Seeking to promote renewable energy use in electricity production, the Background document. Renewable Energy Sources (2001) directive, which took effect in October 2001, sets national indicative targets for renewable energy production from individual member states. Whilst the overall target for the 15 original member states is for 22% of electricity to be produced from renewable sources, the target for the UK is 10%. EC Waste Framework Directive (1975, updated 2006) Objective is the protection of human health and the environment against Background document. harmful effects caused by the collection, transport, treatment, storage and tipping of waste. Particular focus is placed on the re-use of recovered materials as raw materials; restricting the production of waste; promoting clean technologies; and the drawing up of waste management plans. EC Landfill Directive (1999) Aims to prevent or reduce as far as possible negative effects on the Background document. environment, in particular the pollution of surface water, groundwater, soil and air, and on the global environment, including the greenhouse effect, as well as any resulting risk to human health, from the landfilling of waste, during the whole lifecycle of the landfill. National Planning Policy Framework (2012) Replacing MPS1 (Planning and Minerals), the policy sets out the The LFRMS should, if relevant recognise the potential of former
Policy Plan and Programme Review: Appendix C; page 9
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy Government’s planning policies for England and is a framework for local minerals sites for landscape and biodiversity/geodiversity-led policies and how they should be applied. In response to the UN resolution restoration. It should also, where appropriate, aim to safeguard 24/187, the framework performs a sustainable development role against the sterilisation of certain minerals resources and related (economic, social and environmental) in the planning system, outlining 12 infrastructure. core planning principles for plan and decision making, including – Facilitating the sustainable use of minerals; The framework sets out guidance for local mineral plans including: Identifying policies for existing and new sites of national importance, definition of Mineral Safeguarding Areas so that locations of mineral sources are not sterilised by other developments, safeguarding of existing and planned mineral infrastructure (rail links, wharfage, storage, processing etc), environmental criteria to ensure there is not an unacceptable environmental impact and policies for reclaiming land and site aftercare. The framework sets out the principles and the key planning policy objectives against which plans for minerals and decisions on individual applications should be made. These cover the areas of exploration, survey, safeguarding, protection of heritage and countryside, supply, bulk transportation, environmental protection, efficient use, and restoration. Mineral planning authorities should plan for steady and adequate supply of aggregates by; preparing a Local Aggregate Assessment, participating in an Aggregate Working Party, making provision for land-won in mineral plans, take account of National and sub national guidelines, using landbanks as an indicator of supply, maintaining separate landbanks for specific qualities and making adequate provisions. Mineral planning authorities should also: clearly distinguish between the three phases of development when planning on-shore oil and gas development, encourage underground gas and carbon storage, indicate areas of acceptable coal extraction and spoil sites and encourage capture and use of methane from coal mines. National Planning Policy Framework (2012) Replacing PPS22 (Renewable Energy), the policy sets out the Government’s Background document. planning policies for England and is a framework for local policies and how they should be applied. In response to the UN resolution 24/187, the framework performs a sustainable development role (economic, social and environmental) in the planning system, outlining 12 core planning principles for plan and decision making, including - Meeting the challenge of climate change, flooding and coastal change; Support low carbon future by helping to increase the use of renewable and low carbon sources in line with the National Policy Statement for Renewable Energy Infrastructure. National Policy Statements : Overarching National This Overarching National (England and Wales) Policy Statement for Background document. Policy Statement (NPS) for Energy (July 2011) Energy (EN-1) is part of a suite of NPSs issued by the Secretary of State for Energy and Climate Change. It sets out the Government’s policy for delivery of major energy infrastructure, enabling the planning system to be
Policy Plan and Programme Review: Appendix C; page 10
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy rapid, predicable and accountable. A further five technology-specific NPSs for the energy sector cover different types of energy infrastructure (see below NPSs). These are used in conjunction with this NPS where relevant to an application. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Fossil Fuel Electricity It sets out the Government’s (England and Wales) policy for delivery of Background document. Generating Infrastructure NPS (July 2011) major energy Infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Renewable Energy It sets out the Government’s (England and Wales) policy for delivery of Background document. Infrastructure NPS (July 2011) major energy Infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Gas Supply Infrastructure It sets out the Government’s (England and Wales) policy for delivery of Background document. & Gas and Oil Pipelines NPS (July 2011) major energy Infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Electricity Networks It sets out the Government’s (England and Wales) policy for delivery of Background document. Infrastructure NPS (July 2011) major energy Infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Nuclear Power It sets out the Government’s (England and Wales) policy for delivery of Background document. Generation NPS (July 2011) major energy Infrastructure, enabling the planning system to be rapid, predicable and accountable. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Hazardous Waste This NPS (England only), and in particular the policy and guidance section Background document. on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. The NPS
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Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy covers; Construction of facilities in England where the main purpose of the facility is expected to be the final disposal or recovery of hazardous waste and the capacity is expected to be: o in the case of the disposal of hazardous waste by landfill or in a deep storage facility1, more than 100,000 tonnes per year; o in any other case, more than 30,000 tonnes per year. The alteration of a hazardous waste facility in England where the main purpose of the facility is the final disposal or recovery of hazardous waste and the alteration is expected to have the following effect: o in the case of the disposal of hazardous waste by landfill or in a deep storage facility, to increase by more than 100,000 tonnes per year the capacity of the facility; o in any other case, to increase by more than 30,000 tonnes per year the capacity of the facility. Bedfordshire and Luton Minerals and Waste Local This plan sets out strategic policies on which future waste management Background document. Plan Strategic Sites and Policies Plan 2014 and mineral extraction will be assessed. It identifies strategic sites for mineral extraction, non-hazardous waste landfill and other waste management activities. Waste recycling and recovery, including generating energy where appropriate, is an important part of the plan. The plan safeguards the existing rail served aggregates depots at Leagrave Road and Crescent Road, as well as the asphalt-making plants and concrete batching plants that provide essential materials for road construction and maintenance.
Population
UN The Aarhus Convention (1998) Links environmental rights and human rights. It establishes that sustainable Background document. development can be achieved only through the involvement of all stakeholders and links government accountability and environmental protection. Securing the Future: Delivering the Sustainable Aims to enable people to satisfy their basic needs and enjoy a better Background document. Development Strategy, 2005 quality of life without compromising the quality of life of future generations. Equality Act 2010* The Equality Act 2010 is the law which bans unfair treatment and helps Background document. achieve equal opportunities in the workplace and in wider society. The act replaced previous anti-discrimination laws with a single act to make the law simpler and to remove inconsistencies. The act protects everyone against unfair treatment, on the basis of protected characteristics: age, disability, gender reassignment, marriage
Policy Plan and Programme Review: Appendix C; page 12
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. National Planning Policy Framework (2012) Replacing PPS12 (Local Spatial Planning) and PPG17 (Planning for Open The LFRMS should have due regard to the NPPF ‘promoting healthy Space, Sport and Recreation), the policy sets out the Government’s community’ and ‘Supporting high quality communications planning policies for England and is a framework for local policies and how infrastructure’ principles. they should be applied. In response to the UN resolution 24/187, the framework performs a sustainable development role (economic, social and environmental) in the planning system, outlining 12 core planning principles for plan and decision making, including - Promoting healthy communities, and Supporting high quality communications infrastructure; The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see. Local policies and decisions should therefore promote: Safe and accessible environments and developments. Opportunities for members of the community to mix and meet. Plan for development and use of high quality shared public space. Guard against loss of facilities. Ensure established shops can develop in a sustainable way Ensure integrated approach to housing and community facilities and services. Local and neighbourhood plans should identify community green spaces of particular importance (including recreational and tranquillity) to them, ensuring any development of these areas is ruled out in a majority of circumstances. The framework sets out open space, sport and recreation considerations for neighbourhood planning bodies These include an assessment of needs and opportunities; setting local standards; maintaining an adequate supply of open space and sports and recreational facilities; planning for new open space and sports and recreational facilities; and planning obligations. Advanced, high quality communications infrastructure is essential for sustainable economic growth. The development of high speed broadband technology and other communications networks also plays a vital role in enhancing the provision of local community facilities and services. The NPPF states on page 17 that ‘to deliver the social, recreational and cultural facilities and services that the community needs, planning policies and decisions should plan for the use of shared space and guard against unnecessary loss of valued facilities. Also to ensure that established facilities and services are retained and able to develop for the benefit of the community.’
Policy Plan and Programme Review: Appendix C; page 13
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy English Nature: Accessible Natural Green Space Aims to help Local Authorities develop policies which acknowledge, The LFRMS should seek to support the expansion of Accessible Standards in Towns and Cities: A Review and Toolkit protect and enhance the contribution natural spaces make to local Natural Green Space and improve the quality of existing areas. for their Implementation (2003) sustainability. Three aspects of natural space in cities and towns are discussed: their biodiversity; their ability to cope with urban pollution; ensuring natural spaces are accessible to everyone. The report aims to show how size and distance criteria can be used to identify the natural spaces which contribute most to local sustainability. The Greensand Trust: Luton Green Space Strategy This Strategy reviews and updates the earlier Draft Green Space Strategy The LFRMS should seek to support the expansion of Green Space Review (2014) for Luton and South Bedfordshire, which was consulted upon but never and improve the quality of existing areas. updated and adopted. The elements making up the Review therefore include: Assessment of consultation responses to the Draft Strategy; Assessing the draft typology and proposed standards (distance thresholds, quantitative and qualitative standards); Assessing other existing qualitative data (e.g. site surveys); Recommendations for green space standards within the Luton Local Plan 2011-31; Considering the impact upon green space provision of an additional 50,000 residents by 2031; and Considering how green space in adjoining areas contributes to meeting local needs.
Soil
DEFRA: Safeguarding our Soils: A Strategy for The Soil Strategy for England outlines the Government’s approach to The LFRMS should seek to limit the loss of the highest quality England (2009) safeguarding soils for the long term. It provides a vision to guide future agricultural land, support a reduction of soil loss and erosion, policy development across a range of areas and sets out the practical steps promote an improvement of soil quality, including a reduction of that are needed to take to prevent further degradation of our soils, land contamination, and promote soil protection during the enhance, restore and ensure their resilience, and improve understanding of construction activities linked with flood risk management actions. the threats to soil and best practice in responding to them. Key objectives of the strategy include: Better protection for agricultural soils; Protecting and enhancing stores of soil carbon; Building the resilience of soils to a changing climate; Preventing soil pollution; Effective soil protection during construction and development; and Dealing with the legacy of contaminated land National Planning Policy Framework (2012) Replacing PPS7 (Sustainable development in rural areas), the policy sets The LFRMS should seek to limit the loss of higher quality out the Government’s planning policies for England and is a framework for agricultural land and valued geology. local policies and how they should be applied. In response to the UN Policy Plan and Programme Review: Appendix C; page 14
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy resolution 24/187, the framework performs a sustainable development role (economic, social and environmental) in the planning system, outlining 12 core planning principles for plan and decision making, including conserving and enhancing the natural environment; The planning system should contribute and enhance the natural and local environment by; Protecting and enhancing valued landscapes, geological conservation interests and soils; Recognising the wider benefits of ecosystem services; Preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. Planning policies and decisions should also ensure that: The site is suitable for its new use taking account of ground conditions and land instability, including from natural hazards or former activities such as mining, pollution arising from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation; after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990; and adequate site investigation information, prepared by a competent person, is presented. Plans and decisions should encourage effective use of brownfield sites and take into account the economic benefits of agricultural land when assessing development. The presence of best and most versatile agricultural land (defined as land in grades 1, 2 and 3a of the Agricultural Land Classification), should be taken into account alongside other sustainability considerations. Where significant development of agricultural land is unavoidable, local planning authorities should seek to use areas of poorer quality land (grades 3b, 4 and 5) in preference to that of a higher quality, except where this would be inconsistent with other sustainability considerations. Soils Lead Coordination Network: Soils and the This document sets out the Soils Lead Coordination Network’s vision for The LFRMS should seek to reflect the vision presented in the Natural Heritage: a Vision by the Soils LCN for the soil conservation. document by seeking to support a reduction of soil loss and Protection of the UK Soil Resource and Sustainable The “desired outcomes” of the vision are as follows: erosion, promote an improvement of soil quality, including a Use of Soils (2007) reduction of land contamination, and promote soil protection (i) Maintaining the diversity and biodiversity of UK soils; during development. (ii) Controlling and when appropriate reversing loss of soil carbon and water-holding capacity; Policy Plan and Programme Review: Appendix C; page 15
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy (iii) Reducing accelerated soil erosion and sediment transport into watercourses; and (iv) Ensuring appropriate status of soils in mitigation and remediation scenarios to control the impact of climate change. Water
EC Water Framework Directive 2000/60/EC This provides an overarching strategy, including a requirement for EU The LFRMS should seek to ensure that water quality is not Member States to ensure that they achieve 'good ecological status' by negatively affected by planned flood risk management actions, 2015. River Basin Management Plans were defined as the key means of including regarding surface run-off during and after construction achieving this. which could lead to a deterioration in quality of local watercourses. EC Floods Directive 2007/60/EC Requires Member States to assess if all water courses and coast lines are at The LFRMS will be a key document in seeking to ensure risk from flooding, to map the flood extent and assets and humans at risk, development does not take place in flood risk areas, and does not and to take measures to reduce this flood risk. Also reinforces the rights of increases flood risk in existing or potential (due to climate change) the public to access this information. flood risk areas. The Water Environment (Water Framework Directive) Requires all inland and coastal waters to reach “good status” by 2015. This The LFRMS should support development which reduces the (England and Wales) Regulations (2003) is being done by establishing a river basin structure within which frequency and severity of pollution events, limits the risk of flooding, demanding environmental objectives are being set, including ecological improves water quality and facilitates water conservation and reuse. targets for surface waters. National Planning Policy Framework (2012) Replacing PPS23 (Planning and Pollution Control), the policy sets out the The LFRMS should treat potential pollution from flood risk Government’s planning policies for England and is a framework for local management actions as a material consideration, help realise policies and how they should be applied. In response to the UN resolution opportunities for the remediation of contaminated 24/187, the framework performs a sustainable development role (economic, social and environmental) in the planning system, outlining 12 The LFRMS will be a key document in seeking to ensure core planning principles for plan and decision making, including - development does not take place in flood risk areas, and does not Conserving and enhancing the natural environment, and Meeting the increases flood risk in existing or potential (due to climate change) challenge of climate change, flooding and coastal change; flood risk areas. The planning system should contribute to and enhance the natural and local environment by: preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability. In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk, coastal change and water supply and demand considerations. Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk Policy Plan and Programme Review: Appendix C; page 16
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards. Local Plans should apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change, by: applying the Sequential Test; if necessary, applying the Exception Test; safeguarding land from development that is required for current and future flood management; using opportunities offered by new development to reduce the causes and impacts of flooding; and where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long- term, seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations. The Water Supply (Water Quality) Regulations, 2010 / These legislative and regulatory instruments set out objectives and provide The LFRMS will be a key document in seeking to ensure Water Act, 2003 / Water Resources Act, 1991 / Water direction for the protection, improvement, sustainable management and development does not take place in flood risk areas, and helping to Industry Act, 1991,1999 / Groundwater Regulations, use of the water environment (surface, ground, estuarine and coastal alleviate flood risks and hazards where they occur. 1998 / Bathing Waters Regulations, 2008 / Urban waters) in terms of quantity and quality, for the benefit of the human and Wastewater Treatment Regulations, 1994 / Land natural environment. Drainage Act, 1991, 1994 / Drainage EIA Regulations, 1999 / Flood Risk Regulations, 2009 Flood and Water Management Act, 2010 The Flood and Water Management Act (2010) states that a LFRMS must The LFRMS will be the primary means of meeting these address: requirements in Luton.
authorities in relation to the area;
ose objectives;
& how they are to be paid for;
is to be reviewed, and how the strategy contributes to the achievement of wider environmental objectives. Environment Agency: Water Resources for the Future: Looks at the steps needed to manage water resources to the 2020s and The LFRMS will be a key document in seeking to ensure A Strategy for England and Wales (2001, reviewed beyond, with the overall aim of improving the environment while allowing development does not take place in flood risk areas, and helping to 2005) enough water for human uses. alleviate flood risks and hazards where they occur.
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Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy Environment Agency: Groundwater Protection: Policy The Environment Agency is the statutory body responsible for the The LFRMS should seek to protect the quality and quantity of and Practice (2007) protection and management of groundwater resources in England & groundwater in the wider area through promoting development Wales. The Environment Agency have set out a framework for the which reduces the frequency and severity of pollution events, limits regulation and the risk of flooding, improves water quality and facilitates water management of groundwater in a set of documents, collectively known as conservation and reuse. The presence of the Source Protection Groundwater Protection: Policy and Practice (GP3). Zones in the borough will require close management of surface In these documents the Environment Agency describe their aims and water runoff to protect groundwater. objectives for groundwater, their technical approach to its management and protection, the tools to be used and the policies and approach to the application of legislation. The documents also provide a route map to other policies, strategies, procedures and technical resources related to groundwater. National Policy Statements : Water Supply NPS It sets out the Government’s policy for delivery of major infrastructure, Background document. relating to the mitigation of, and adaptation to, climate change. This NPS, and in particular the policy and guidance section on generic environmental impacts and mitigation, may be helpful to local planning authorities (LPAs) in preparing their local impact reports. National Policy Statements : Waste Water NPS It sets out the Government’s (England only, including national project in Background document. England) policy for the provision of major waste water infrastructure, enabling the planning system to be rapid, predicable and accountable. Major waste water infrastructure is defined as;
• construction of waste water treatment plants which are expected to have a capacity exceeding a population equivalent4 of 500,000 when constructed; or • alterations to waste water treatment plants where the effect of the alteration is expected to increase by more than a population equivalent of 500,000 the capacity of the plant. Waste water (generally a mixture of domestic waste water from baths, sinks, washing machines and toilets, and waste water from industry. It will often also contain rainwater run-off from roofs and other impermeable surfaces). This NPS, includes a policy and guidance section on generic environmental impacts and mitigation.
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Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy National Flood and Coastal Erosion Risk Management The strategy encourages more effective risk management by enabling The Strategy defines how responsibility for flood and coastal Strategy, 2011 people, communities, business, infrastructure operators and the public erosion risk management issues are shared between public bodies, sector to work together to: establishes duties to be met by each body, and sets priorities for • ensure a clear understanding of the risks of flooding and coastal strategy, funding and reporting. erosion, nationally and locally, so that investment in risk management can be prioritised more effectively; • set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of the remaining risk; • manage flood and coastal erosion risks in an appropriate way, taking account of the needs of communities and the environment; • ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond effectively to flood forecasts, warnings and advice; • help communities to recover more quickly and effectively after incidents. Environment Agency, River Basin Management Plan: The River Basin Management plan focuses on the protection, improvement The LFRMS should seek to support improvements to the area’s River Thames Basin District (2009); and sustainable use of the water environment. This plan has been prepared water environment. In this context it should support flood risk And: under the Water Framework Directive, which requires all countries management actions which reduce the frequency and severity of throughout the European Union to manage the water environment to pollution events, improve water quality and facilitate water Environment Agency (October 2014): Water for life consistent standards. The plan describes the river basin district, and the conservation and reuse. and livelihoods: A consultation on the draft update to pressures that the water environment faces. It highlights what this means the river basin management plan for the Thames River for the current state of the water environment, and what actions will be Basin District. taken to address the pressures. It sets out what improvements are possible by 2015 and how the actions will make a difference to the local environment – the catchments, estuaries, the coast and groundwater. Environment Agency: Thames Catchment Flood The CFMP gives an overview of the flood risk in the Thames catchment The LFRMS will be a key document in seeking to ensure Management Plan (2009); area and sets out the preferred plan for sustainable flood risk management development does not take place in flood risk areas, and helping to And: over the next 50 to 100yrs. alleviate flood risks and hazards where they occur. Environment Agency (October 2014): Thames River Basin District: Consultation on the Draft Flood Risk Management Plan.
Policy Plan and Programme Review: Appendix C; page 19
Title of PPP Main objectives and environmental / socio-economic How it affects, or is affected by the Luton Local Flood requirements of PPP Risk Management Strategy Environment Agency: Upper Lee Abstraction This Licensing Strategy sets out how water resources are managed in the The LFRMS should seek to support sustainable water management Licensing Strategy (2013) Upper Lee CAMS area. It provides information about where water is and promote the sustainable use of water resources. available for further abstraction and an indication of how reliable a new abstraction licence may be. The strategy was produced in February 2013 using evidence and information gathered during the Catchment Abstraction Management Strategy (CAMS) process which it supersedes. Through this process the Environment Agency considers the impact of abstraction at all flows. This helps to manage future abstraction more sustainably. The document provides information on the geology and hydrology within the Upper Lee CAMS area and resource availability in terms of surface and groundwater and reliability of abstraction within the CAMS area. It also details how abstractions are managed within the CAMS area, including the principles that guide licence application assessment; the abstraction licence application process; opportunities for license trading; new authorisations and restoring sustainable abstractions. Capita Symonds (February 2013): Luton Strategic A Level 1 SFRA presents sufficient information to enable the LPA to apply The LFRMS will be a key document in seeking to ensure Flood Risk Assessment Level 1 (Update) the Sequential Test to potential development sites and assists in development does not take place in flood risk areas, and helping to identifying if application of the Exception Test will be necessary. The Level alleviate flood risks and hazards where they occur. 1 SFRA also provides background information, a review of local policies, and guidance for site specific flood risk assessment and the potential for application of Sustainable Drainage Systems (SuDS). The review of policies is allied to guidance on the requirements for site- specific Flood Risk Assessments (FRAs) throughout the study area. The outcomes from the Level 1 SFRA should be used by the LPA to identify the most suitable locations for development in line with NPPF and other planning drivers. Where sites cannot be located in line with the principles of NPPF further investigation may be required through a Level 2 SFRA. Capita Symonds (2012): Luton Surface Water The draft SWMP defines 17 Critical Drainage Areas (CDA) which are The LFRMS will be a key document in seeking to ensure Management Plan – Final Draft [Updated September “discrete geographic areas (usually a hydrological catchment) where development does not take place in flood risk areas, and helping to 2013]. multiple and interlinked sources of flood risk (surface water, groundwater, alleviate flood risks and hazards where they occur. sewer and/or river) often cause flooding during severe weather thereby affecting people, property or local infrastructure”. It goes on to identify options for reducing flood risks and hazards, prioritisation thereof, a proposed surface water drainage policy, and an action plan.
Policy Plan and Programme Review: Appendix C; page 20
SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
Appendix D: Baseline Data & Key Issues
Please see insert.
G SEA for the Luton Local Flood Risk Management Strategy: Environmental Report August 2015 UE-0161 SEA- Luton LFRMS ER_3_150805
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H SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
Contents
1 Biodiversity, Flora and Fauna 1
1.1 Designated Sites 1
1.2 Priority Habitats 4
1.3 Bedfordshire and Luton Biodiversity Action Plan 4
1.4 Key Issues for Biodiversity 5
1.5 Likely Evolution of the Baseline in the Absence of the LFRMS 5
2 Climatic Factors 7
2.1 Effects of Climate Change 7
2.2 Climate Change Adaptation 9
2.3 Key Issues for Climate Change 10
2.4 Likely Evolution of the Baseline in the Absence of the LFRMS 10
3 Cultural Heritage 11
3.1 Designated Sites 11
3.2 Key Issues for Cultural Heritage 13
3.3 Likely Evolution of the Baseline in the Absence of the LFRMS 13
4 Landscape 14
4.1 Designated Sites 14
4.2 Key Issues for Landscape 16
4.3 Likely Evolution of the Baseline in the Absence of the LFRMS 16
5 Material Assets 17
5.1 Properties and Infrastructure at Risk of Flooding 17
5.2 Key Issues for Materials Assets 27
5.3 Likely Evolution of the Baseline in the Absence of the LFRMS 28
6 Population and Human Health 29
6.1 Demographics 29
6.2 Key Issues for Population and Human Health 31
6.3 Likely Evolution of the Baseline in the Absence of the LFRMS 31
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7 Soil 32
7.1 Agricultural Land 32
7.2 Minerals and Waste Sites 32
7.3 Previously Developed and/or Derelict Land 35
7.4 Key Issues for Soil 35
7.5 Likely Evolution of the Baseline in the Absence of the LFRMS 36
8 Water 37
8.1 Water Resources 37
8.2 Water Quality 39
8.3 Flood Risk 40
8.4 Key Issues for Water 44
8.5 Likely Evolution of the Baseline in the Absence of the LFRMS 44
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List of Tables and Figures
Table 1.1: County and District Wildlife Sites 3
Table 1.2: Type and extent of priority habitats in Luton 4
Table 1.3: Bedfordshire & Luton Species and Habitat Action Plans 4
Table 4.1: Luton Green Belt 14
Table 5.1: Barnfield College / Barnfield Avenue CDA (Adapted from Capita Symonds, 2013) 17
Table 5.2: Barton Road / Great Bramingham CDA (Adapted from Capita Symonds, 2013) 19
Table 5.3: Barnfield West Academy/Poynters Road CDA (Adapted from Capita Symonds, 2013) 19
Table 5.4: Beechwood Primary School / Railway Line CDA (Adapted from Capita Symonds, 2013) 20
Table 5.5: Chapel Street, Stuart Street CDA (Adapted from Capita Symonds, 2013) 20
Table 5.6: Dalroad Enterprise Estate CDA (Adapted from Capita Symonds, 2013) 21
Table 5.7: Dunstable Road / Luton Town FC Ground CDA (Adapted from Capita Symonds, 2013) 21
Table 5.8: Farley Hill CDA (Adapted from Capita Symonds, 2013) 22
Table 5.9: Junction 11 M1 CDA (Adapted from Capita Symonds, 2013) 22
Table 5.10: Luton Sixth Form College CDA (Adapted from Capita Symonds, 2013) 23
Table 5.11: Luton High Town CDA (Adapted from Capita Symonds, 2013) 23
Table 5.12: Sundon Park / Railway Line CDA (Adapted from Capita Symonds, 2013) 24
Table 5.13: Vauxhall Road CDA (Adapted from Capita Symonds, 2013) 25
Table 5.14: Wigmore Lane / Eaton Green Road CDA (Adapted from Capita Symonds, 2013) 25
Table 5.15: Summary of Risk Outside CDAs (Adapted from Capita Symonds, 2013) 26
Table 5.16: Summary of Risks in CDAs Outside the Borough Boundary * (Adapted from Capita Symonds, 2013) 27
Table 8.1: Luton waterbodies, status and objectives 2014/2015 40
Figure 1.1: Designated nature conservation sites in and around the borough 2
Figure 1.2: Priority habitats in and around the borough 6
Figure 2.1: Extent and possible impacts of changes in summer temperature and precipitation in the East of England (Source: LBC, 2010) 8
Figure 2.2: Extent and possible impacts of changes in winter precipitation in the East of England (Source: LBC, 2010) 9
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Figure 3.1: Designated heritage sites in and around the borough 12
Figure 4.1: Designated landscapes in and around the borough 15
Figure 5.1: Luton Critical Drainage Areas (Source: Capita Symonds, September 2013) 18
Figure 6.1: Age profile of Luton (June 2012), with regional and England comparators 29
Figure 6.2: Population projections, 2012, 2027, 2037 30
Figure 6.3: Health profile (March 2011) 31
Figure 7.1: Agricultural Land Classification in and around the borough 33
Figure 7.2: Policies Inset Map 9 (Source: Bedfordshire and Luton Minerals and Waste Local Plan) 34
Figure 8.1: Upper Lee abstraction licensing area (Source: Upper Lee ALS 2013) 37
Figure 8.2: Source Protection Zones in Luton 39
Figure 8.3: Fluvial flood risk in Luton 41
Figure 8.4: River catchments and watercourses (Source: Capita Symonds, 2012) 42
Figure 8.5: Susceptibility to groundwater flooding (Source: Capita Symonds, 2012) 42
Figure 8.6: Sewer flooding probability areas (Source: Capita Symonds, 2012) 45
Figure 8.7: Surface water depths during a 100yr rainfall event (Source: Capita Symonds, 2012) 45
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1 Biodiversity, Flora and Fauna
1.1 Designated Sites
1.1.1 There are no internationally important nature conservation sites within or adjacent to the Luton borough boundary, such as Special Areas of Conservation (SAC), Special Protection Areas (SPA) or Ramsar sites. The closest such site to the borough is Chilterns Beechwoods SAC, approximately 8.8km to the south-west and designated for Asperulo-Fagetum beech forests, semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia) and stag beetle Lucanus cervus. Although water levels are likely to play an important role in the ecological status of these features they are unlikely to be affected by the LFRMS. There are no other European sites within 20km of the borough.
1.1.2 The only other European sites which could theoretically be affected by the LFRMS are the Lea Valley SPA/Ramsar which are hydrologically connected to the borough via the River Lea. However, these are located c.25km south-east of the borough boundary at their nearest extent and would be unlikely to be affected except under an extreme pollution incident. Assessment of the LFRMS policies and actions will need to take account of the risk of such an event.
1.1.3 There are no nationally designated sites for nature conservation within Luton, however, the following are adjacent to the borough’s northern boundary:
Galley and Warden Hills Site of Special Scientific Interest (SSSI); and
Galley and Warden Hills Local Nature Reserve (LNR).
1.1.4 Located on the northern edge of Luton, and situated on the Middle Chalk with an overlying cap of clay-with-flints, Galley and Warden Hills SSSI supports areas of unimproved neutral and calcareous grassland with structural variety provided by scattered and dense scrub. It supports a characteristic downland flora, including many locally uncommon species and nationally rare plants. First notified in 1951, and covering an area of 47.5ha, 76.7% of the site is in “unfavourable, recovering” condition, with the remaining 23.3% in “favourable” condition. The site was further declared an LNR in 1993.
1.1.5 There are 27 County Wildlife Sites (CWS) and 16 District Wildlife Sites (DWS) within or adjacent to the borough boundary, see Table 1.1 and Figure 1.1. County Wildlife Sites are recognised as important for wildlife when assessed against a set of criteria including: Size, Diversity, Rarity, Fragility, Typicality and Recorded History. Bradgers Hill CWS, Dallow Downs CWS and part of Hay Wood and Stopsley Common DWS are being considered for designation as SSSI but no decisions have yet been and the precise extent of the land to be designated is not known.
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Figure 1.1: Designated nature conservation sites in and around the borough
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1.1.6 District Wildlife Sites are recognised as having value for wildlife when assessed against a set of criteria, and are one tier below CWS status, i.e. their biodiversity interest is not great enough for recognition as CWS but is still worthy of recognition and protection if possible. With appropriate management a DWS may attain CWS quality and status. District Wildlife Sites are a new category of site, initiated in 2012 and currently only being recognised within the area of Luton Borough Council1.
Table 1.1: County and District Wildlife Sites
County and District Wildlife Sites
County Wildlife Sites
Within Luton Leagrave Common CWS Biscot Churchyard CWS Oaket Wood CWS (partly in Hertfordshire) Bradger's Hill CWS (currently being Oosey Hill CWS (partly in Central considered for SSSI designation) Bedfordshire) Bramingham Wood CWS People's Park CWS Castle Croft and Bluebell Wood CWS River Lea CWS Church Cemetery, Luton CWS Riverside Walk CWS Cowslip Meadow CWS (currently being Slaughter's Wood and Green Lane CWS considered for SSSI designation) Stockwood Park CWS Croda Colloids CWS Sunshine Riding Stables CWS Dallow Downs CWS (currently being The Chase CWS considered for SSSI designation) Wandon End Park CWS Fallowfield CWS Wigmore Park CWS Honeygate and Crick Hills CWS Winch Hill Wood CWS (partly in Icknield School CWS Hertfordshire) Adjacent to Luton Galley and Warden Hills CWS Dunstable to Luton disused railway CWS Kidney and Bull Woods CWS
District Wildlife Sites
Within Luton Dairyborn Scarp DWS Hitchin Road Spinney DWS Dallow Lane DWS Lewsey Park DWS Foxdell DWS Luton Parkway Verges DWS Great Bramingham Park DWS Mixes Hill DWS Great Hayes Wood DWS River Lea DWS Hatters Way DWS Stockingstone Hill DWS Hay Wood and Stopsley Common DWS (part Stockwood Park DWS of which is currently being considered for Turnpike Lane DWS SSSI designation) Whitehorse Vale DWS
1 Bedfordshire and Luton Biodiversity Recording and Monitoring Centre accessed online at [October 2014]: http://www.bedscape.org.uk/BRMC/newsite/index.php?c=sites_dws
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1.2 Priority Habitats
1.2.1 Luton is a heavily urbanised borough but nonetheless supports over 225ha of priority habitats according to nationally mapped datasets2. These are depicted on Figure 1.2 with a summary of the extent of each priority habitat type given in Table 1.2.
Table 1.2: Type and extent of priority habitats in Luton
Priority Habitat Type Area (ha)
Deciduous woodland 81.74
Good quality semi-improved grassland 1.03
Lowland calcareous grassland 17.02
Lowland fen 0.02
Lowland meadow 16.49
1.3 Bedfordshire and Luton Biodiversity Action Plan
1.3.1 Since 2001 the Bedfordshire and Luton Wildlife Working Group has been developing and maintaining the plans for species and habitats as part of the county's Biodiversity Action Plan; see Table 1.3.
Table 1.3: Bedfordshire & Luton Species and Habitat Action Plans
Habitat Action Plans Species Action Plans
Arable field margins Adder
Floodplain grazing marsh Arable plants
Hedgerows Depressed river mussel
Lowland grasslands (dry acid & calcareous) Otter
Lowland heathland Great crested newt
Lowland meadows Hazel dormouse
Ponds Water vole
Reedbed -
Traditional orchards -
Wet woodland -
Wood-pasture and parkland -
Woodland -
2 Natural England Priory Habitats Layer (June 2013), accessed online at [February 2014]: http://www.geostore.com/environment- agency/WebStore?xml=environment-agency/xml/ogcDataDownload.xml
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1.4 Key Issues for Biodiversity
1.4.1 Luton is a heavily urbanised borough with comparatively little remaining in the way of semi- natural habitats. It has a growing population and a high level of new housing needs over the next 20 years or so, which will place additional pressures on the remaining biodiversity resources in the borough. The LFRMS should, wherever possible, seek to promote and facilitate the conservation and enhancement of semi-natural habitats, both in their own right and for flora and fauna they support. This could be achieved, for example, by promoting multifunctional (i.e. biodiverse) flood storage areas, removal of watercourse culverts, and ensuring that flood defences and their management do not significantly affect biodiversity.
1.5 Likely Evolution of the Baseline in the Absence of the LFRMS
1.5.1 Baseline conditions for biodiversity, flora and fauna are unlikely to significantly alter in the absence of an LFRMS, except perhaps to the extent that they could be negatively affected by other flood risk management strategies and defences. However, as the River Lea is both a key source of flood risk in Luton and one of the borough’s most extensive wildlife sites, measures to alleviate flood risk (whether promoted by the LFRMS or other flood risk management plan) should seek to avoid significant ecological impacts. Flooding incidents may result in impacts to remaining areas of semi-natural and/or priority habitats and the species they support, but equally are likely to play a role in the dynamic conditions of riparian ecosystems. Flood defences could negatively affect populations of riparian species such as water vole or kingfisher by changing the extent or structure of riparian habitat.
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Figure 1.2: Priority habitats in and around the borough 6 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
2 Climatic Factors
2.1 Effects of Climate Change
2.1.1 The outcome of research on the probable effects of climate change in the UK has been released by the UK Climate Projections (UKCP09) team. UKCP09 gives climate information for the UK up to the end of this century and projections of future changes to the climate are provided, based on simulations from climate models. Projections are broken down to a regional level across the UK and are shown in probabilistic form, which illustrate the potential range of changes over three time periods (2020s, 2050s and 2080s) and the level of confidence in each prediction. The effects of climate change for the East of England climate in the 2050s for a medium emissions scenario are likely to be as follows3:
The central estimate of increase in winter mean temperature is 2.2ºC; it is very unlikely to be less than 1.1ºC and is very unlikely to be more than 3.4ºC. A wider range of uncertainty is from 0.9ºC to 3.8ºC.
The central estimate of increase in summer mean temperature is 2.5ºC; it is very unlikely to be less than 1.2ºC and is very unlikely to be more than 4.3ºC. A wider range of uncertainty is from 1ºC to 4.8ºC.
The central estimate of increase in summer mean daily maximum temperature is 3.4ºC; it is very unlikely to be less than 1.3ºC and is very unlikely to be more than 6ºC. A wider range of uncertainty is from 1.1ºC to 6.8ºC.
The central estimate of increase in summer mean daily minimum temperature is 2.7ºC; it is very unlikely to be less than 1.2ºC and is very unlikely to be more than 4.7ºC. A wider range of uncertainty is from 1.1ºC to 5.3ºC.
The central estimate of change in annual mean precipitation is 0%; it is very unlikely to be less than –5% and is very unlikely to be more than 5%. A wider range of uncertainty is from –5% to 6%.
The central estimate of change in winter mean precipitation is 14%; it is very unlikely to be less than 3% and is very unlikely to be more than 31%. A wider range of uncertainty is from 1% to 35%.
The central estimate of change in summer mean precipitation is –17%; it is very unlikely to be less than –38% and is very unlikely to be more than 6%. A wider range of uncertainty is from –40% to 14%.
2.1.2 Figure 2.1 and Figure 2.2 illustrate the extent and possible impacts of changes in summer temperature, and summer and winter precipitation in the East of England over three time periods (2020, 2040 and 2080).
3 UK Climate Projections, UKCP09 Key Findings, accessed online at [October 2014]: http://ukclimateprojections.metoffice.gov.uk/22146
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Figure 2.1: Extent and possible impacts of changes in summer temperature and precipitation in the East of England (Source: LBC, 2010)
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Figure 2.2: Extent and possible impacts of changes in winter precipitation in the East of England (Source: LBC, 2010)
2.2 Climate Change Adaptation
2.2.1 The Luton Climate Change Adaptation Action Plan (LBC, 2010) sets out an extensive series of key actions to promote adaptation, organised under the following themes:
Adapting Luton’s built environment to a changing climate;
Minimising flood risk in Luton;
Managing and enhancing Luton’s green infrastructure to improve resilience to a changing climate;
Increasing the resilience of the Council’s services delivery;
Increasing workforce capability to adapt to climate change;
Raising awareness and communicating climate change risks; and
To provide leadership across the borough in increasing resilience and adapting to climate change.
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2.3 Key Issues for Climate Change
2.3.1 Large areas of Luton are already subject to flood risks resulting from a combination of topography, geology and inadequate infrastructure (including the constrained capacity in drainage and culverted watercourses). Although levels of summer precipitation may decline in future, climate change is likely to exacerbate this situation through greater volumes of rainfall during the winter, and increased storminess and intensity of rain showers.
2.4 Likely Evolution of the Baseline in the Absence of the LFRMS
2.4.1 The effects of climate change in Luton are likely to continue with accelerating pace in future, with or without an LFRMS, due to past and present carbon emissions. The borough already benefits from an extensive Climate Change Adaptation Strategy, however, the LFRMS and related documents (e.g. the Surface Water Management Plan) will form an important part of the policy response to managing these impacts. Without an LFRMS, adaptation to climate change is unlikely to be as successful, meaning that its impacts would be greater.
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3 Cultural Heritage
3.1 Designated Sites
3.1.1 There are no World Heritage Sites, Registered Battlefields or Protected Wrecks in Luton, but there are four Scheduled Monuments within or adjacent to the borough; see Figure 3.1:
Neolithic enclosure known as Waulud’s Bank in the north-west of the borough;
Dray’s Ditches, an Iron Age linear earthwork overlaying Bronze Age occupation at the northern borough boundary;
Two bowl barrows on Galley Hill, just north of Dray’s Ditches; and
The upstanding and buried remains of the late medieval magnate's residence known as Someries Castle and the adjacent garden earthworks, just outside the borough boundary south of London Luton Airpoort.
3.1.2 A fifth Scheduled Monument, the site of a Medieval village near Zouches Farm, is outside of the borough around 700m south-west.
3.1.3 Additionally there are three Registered Parks and Gardens in the borough, Wardown Park (in the centre of the borough), Putteridge Bury (on its north-eastern flank) and Luton Hoo (to the south). A further (unregistered) historic park and garden can be found south of Manor Farm, Lower Sundon just outside of the borough to the north. This area, commonly known as Sundon Park, formed part of the home park of the manor of Sundon during the medieval (when it was joined to a much larger deer park) and post-medieval periods, before the house was demolished in the early 19th century. On demolition of the house, the landscape garden reverted back to farmland.
3.1.4 Furthermore there is one Grade I (Parish Church of St Mary) and 81 Grade II nationally Listed Buildings4, and five locally designated Conservation Areas in the borough including:
High Town Conservation Area, noted by English Heritage as in ‘very bad’ condition and listed on the Heritage at Risk Register 20145;
Luton South Conservation Area;
Plaiters Lea Conservation Area, noted by English Heritage as in ‘very bad’ condition and listed on the Heritage at Risk Register 2014;
Rothesay Conservation Area; and
Town Centre Conservation Area.
4 English Heritage National Monuments Record (Feb/Mar 2014), accessed online at [March 2014]: http://services.english- heritage.org.uk/NMRDataDownload/ 5 English Heritage, Heritage at Risk Register 2014, accessed online at [October 2014]: http://risk.english- heritage.org.uk/register.aspx?rs=1&rt=0&pn=1&st=a&ua=Luton+%28UA%29&ctype=all&crit=
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Figure 3.1: Designated heritage sites in and around the borough
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3.1.5 There is also undesignated archaeology, including some that may be of national importance, which is recorded on the Historic Environment Record (HER); buried archaeology can be affected by changes in hydrology, e.g. de‐watering.
3.2 Key Issues for Cultural Heritage
3.2.1 The majority of the borough’s historic assets are at risk of flooding, whether from fluvial, ground water or surface water sources, which may result in harm to or loss of their significance as a result of direct flood damage and/or inappropriate remedial works. This is especially so in the town centre which is noted as having a high risk of fluvial and pluvial flooding and ‘very high’ susceptibility to groundwater flooding (see also Chapter 8). The following key issues are relevant:
Proposed flood risk management measures and measures to improve resilience have the potential to impact on the significance of heritage assets, including the contribution made by their setting.
Securing the sustainable use of heritage assets, including those identified as at risk, may be hindered by their location in high flood risk areas.
Measures such as Sustainable Drainage Systems should be promoted whilst sustaining and enhancing the character of historic townscapes and landscapes and the significance of areas of archaeological interest and/or potential interest.
3.3 Likely Evolution of the Baseline in the Absence of the LFRMS
3.3.1 The borough’s historic environment is unlikely to change dramatically with or without an LFRMS, however, the number of heritage features at risk of flooding is likely to progressively increase with climate change unless suitable adaptation and flood protection measures are implemented.
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4 Landscape
4.1 Designated Sites
4.1.1 Luton is bordered to the north and south-west by the Chilterns Area of Outstanding Natural Beauty (AONB) and small sections of the north-east of the borough fall within this designation; see Figure 4.1. The Chilterns AONB covers 839km2 of countryside, stretching from the River Thames in southern Oxfordshire up through Buckinghamshire and Bedfordshire to Hitchin in Hertfordshire. Farmland covers nearly two-thirds of the AONB and over one-fifth of the area is wooded. Attractive villages with brick and flint cottages nestle in quiet valleys. The chalk rock underlying the Chilterns gives rise to hillsides of velvety chalk downland. Water stored in the rock emerges from springs to feed clear, sparkling chalk streams like the Chess and Misbourne6.
4.1.2 Luton is surrounded on virtually all sides by the southern Bedfordshire Green Belt, apart from to the east and south-east of Luton where the North Hertfordshire Green Belt completes the ring (an extension of the Metropolitan Green Belt). Luton itself currently has only six small areas of Green Belt remaining, totalling 138.2ha as listed in Table 4.1, which are protected through the Luton Local Plan.
Table 4.1: Luton Green Belt
Name Area (ha)
Dane Street 6.58
Oaket Wood 0.75
Putteridge 5.77
Someries 22.70
Stopsley Common 100.57
Warden Hill 1.83
4.1.3 Additionally, the Luton Local Plan seeks to protect locally designated Areas of Great Landscape Value (AGLV) and Areas of Local Landscape Importance (ALLI) in the following locations:
Bradgers Hill AGLV; Dallow Downs AGLV;
Dane Street AGLV; Someries AGLV;
Hart Hill ALL; and Stockwood Park ALLI.
6 The Chilterns Area of Outstanding Natural Beauty, accessed online at [October 2014]: http://www.chilternsaonb.org/about- chilterns.html
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Figure 4.1: Designated landscapes in and around the borough
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4.2 Key Issues for Landscape
4.2.1 Areas of significant landscape value are not likely to be significantly affected by the LFRMS.
4.3 Likely Evolution of the Baseline in the Absence of the LFRMS
4.3.1 As with the historic environment, the borough’s landscape and townscape are unlikely to change dramatically with or without an LFRMS, however, the number of heritage features (which are an essential component of landscape and townscape character) at risk of flooding is likely to progressively increase with climate change unless suitable adaptation and flood protection measures are implemented.
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5 Material Assets
5.1 Properties and Infrastructure at Risk of Flooding
5.1.1 The Draft Luton Surface Water Management Plan7 defines 17 Critical Drainage Areas (CDA) which are “discrete geographic areas (usually a hydrological catchment) where multiple and interlinked sources of flood risk (surface water, groundwater, sewer and/or river) often cause flooding during severe weather thereby affecting people, property or local infrastructure” (p.47). More information on the various types of flood risk is given at Chapter 8.
5.1.2 Table 5.1 to Table 5.16 provide a summary of the locations, sources and consequences of flooding for properties and infrastructure, for each CDA within the borough, based on the 1in100yr rainfall event. Figure 5.1 illustrates the location of CDAs within Luton.
Table 5.1: Barnfield College / Barnfield Avenue CDA (Adapted from Capita Symonds, 2013)
CDA ID: BCBR Barnfield College / Barnfiled Avenue
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 109 0 0 5
>0.5m 22 0 0 2
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts: Numerous households are predicted to be affected by flooding during this rainfall event. Barnfield College grounds are affected, but not the buildings themselves.
7 Capita Symonds (2012): Luton Surface Water Management Plan – Final Draft [Updated September 2013]. Accessed online at [October 2014]: http://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Luton%20SWMP%20-%20Final%20Draft%20- %20V1%207.pdf
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Figure 5.1: Luton Critical Drainage Areas (Source: Capita Symonds, September 2013)
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Table 5.2: Barton Road / Great Bramingham CDA (Adapted from Capita Symonds, 2013)
CDA ID: BRGB Barton Road / Great Bramingham
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater Reservoir
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 892 120 25 79
>0.5m 374 4 10 17
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 1 4 1
>0.5m 0 1 2 1
Flood impacts: The flood level reaches between 1.5-2.0m during the 100 year event around Icknield Way and is predicted to flood a substantial number of properties. Many residential properties along A6 near Statham Close roundabout, Chard Drive, Sacombe Green and the Whitehorse Vale are observed to have a significant hazard rating. The highly vulnerable infrastructure identified is the church / community hall at the corner of Catsbrook Road and Icknield Way. More vulnerable items are schools throughout the CDA.
Table 5.3: Barnfield West Academy/Poynters Road CDA (Adapted from Capita Symonds, 2013)
CDA ID: BWPR Barnfield West Academy/Poynters Road
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 225 29 5 10
>0.5m 7 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 2 0
>0.5m 0 0 0 0
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CDA ID: BWPR Barnfield West Academy/Poynters Road
Flood impacts: The properties between Poynters Road and Amhurst Road are flooded with observed flood depths between 0.4m and 0.75m, this is due to the area of ground which is lower than the surrounding area. Similarly a group of properties along Pastures Way is also identified to be flooded by approximately 0.2m. Minor flooding is predicted at two schools within the CDA (more vulnerable infrastructure).
Table 5.4: Beechwood Primary School / Railway Line CDA (Adapted from Capita Symonds, 2013)
CDA ID: BWSRL Beechwood Primary School / Railway Line
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 184 0 2 11
>0.5m 27 0 0 3
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 1
>0.5m 0 0 0 0
Flood impacts: The majority of flooded households are centred on Morgan Close, Linden Road and Mostyn Road – typical depths are between 0.7m and 1.0m for the 1% AEP event.
Table 5.5: Chapel Street, Stuart Street CDA (Adapted from Capita Symonds, 2013)
CDA ID: CHAST Chapel Street, Stuart Street
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 103 308 124 112
>0.5m 0 9 6 20
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
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CDA ID: CHAST Chapel Street, Stuart Street
>0.1m 0 0 3 1
>0.5m 0 0 0 0
Flood impacts: The majority of household flooding is predicted along the Russell Street / Elizabeth Street overland flow path. Predicted commercial property flooding is generally centred within and around The Mall. Of most concern is the predicted 0.4m to 0.6m deep overland flow through The Mall.
Table 5.6: Dalroad Enterprise Estate CDA (Adapted from Capita Symonds, 2013)
CDA ID: DREE Dalroad Enterprise Estate
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 51 4 21 17
>0.5m 0 0 2 8
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts: Most of the predicted flooded properties are along Kingsway or within the Bilton Way Industrial Estate or Dalroad Estate.
Table 5.7: Dunstable Road / Luton Town FC Ground CDA (Adapted from Capita Symonds, 2013)
CDA ID: DURD Dunstable Road / Luton Town FC Ground
Local Other
Surface water Sewer Flood Source Ord. watercourse Main river Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 29 148 38 55
>0.5m 3 4 0 1
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CDA ID: DURD Dunstable Road / Luton Town FC Ground
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 1
>0.5m 0 0 0 0
Flood impacts: Residential property flooding is generally associated with the predicted flooding at Leagrave Road underpass and at Waldeck Road. Commercial property flooding is concentrated in the rail depot on Leagrave Road and Wingate Road. Flooding of A6 at New Bedford Road underpass and B579 at Leagrave Road underpass (both are main east-west routes through Luton).
Table 5.8: Farley Hill CDA (Adapted from Capita Symonds, 2013)
CDA ID: FHILL Farley Hill
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 3 33 3 2
>0.5m 0 1 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts: All of the household flooding predicted in this CDA is located in the Farley Hill area. Deeper flooding is associated with the predicted overland flow path through The Grove, Farley Farm Road and Leyhill Drive.
Table 5.9: Junction 11 M1 CDA (Adapted from Capita Symonds, 2013)
CDA ID: J11M1 Junction 11 M1
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
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CDA ID: J11M1 Junction 11 M1
>0.1m 7 0 0 2
>0.5m 0 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts: Predicted household flooding is adjacent to the M1 motorway. One ‘other’ property listed here as flooded is one of the outbuildings at Challney High School. The second ‘other’ property no longer exists and is now part of the north bound M1 off-slip (OS mapping still shows this as a large warehouse and hence is included in the overall flooded property count). While the M1 itself is not predicted to be flooded the Junction 11 access point may be affected.
Table 5.10: Luton Sixth Form College CDA (Adapted from Capita Symonds, 2013)
CDA ID: L6FC Luton Sixth Form College
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 42 0 1 0
>0.5m 2 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts: Residential properties along Avebury Avenue, Marston Gardens, Old Bedford Road and Foxhill Road are flooded as a result of overland flow. More significant flooding is predicted for the properties between the Luton College playing field and Marston Gardens, with modelled flooding of between 0.4m and 0.5m near the houses.
Table 5.11: Luton High Town CDA (Adapted from Capita Symonds, 2013)
CDA ID: LUHT Luton High Town
Flood Local Other Source Surface water Sewer
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CDA ID: LUHT Luton High Town
Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 86 54 6 25
>0.5m 0 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 1 0
>0.5m 0 0 0 0
Flood impacts: A large number of flooded households are centred around the low point on Frederick Street. The more vulnerable infrastructure identified as being at risk of minor flooding is a drugs clinic on Clarendon Road.
Table 5.12: Sundon Park / Railway Line CDA (Adapted from Capita Symonds, 2013)
CDA ID: SPRL Sundon Park / Railway Line
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 138 0 25 47
>0.5m 21 0 4 5
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 2 0
>0.5m 0 0 1 0
Flood impacts: The residential properties within the modelled flood extent are generally along both sides of Sundon Park Road while the commercial properties are located around Dencora Way. The infrastructure predicted to be affected by flooding is Lealand High School on Sundon Park Road (two buildings).
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Table 5.13: Vauxhall Road CDA (Adapted from Capita Symonds, 2013)
CDA ID: VAUX Vauxhall Road
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 184 31 9 28
>0.5m 0 0 1 6
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 1
>0.5m 0 0 0 0
Flood impacts: Predicted commercial property flooding is primarily within the General Motors area along Vauxhall Way and Vauxhall Road. Modelled residential property flooding is generally related to smaller overland flows contributing to the main flow path along Vauxhall Way. In addition to the infrastructure noted above, Parkway Road is also predicted to experience significant flooding. This is currently the only access road to Luton Airport Parkway Station. Similarly, significant overland flow is predicted along Vauxhall Way (A505).
Table 5.14: Wigmore Lane / Eaton Green Road CDA (Adapted from Capita Symonds, 2013)
CDA ID: WIGP Wigmore Lane / Eaton Green Road
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 124 0 4 2
>0.5m 18 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 2 0
>0.5m 0 0 1 0
Flood impacts: Depths of water along majority of Wigmore Lane are in the range of 0.3m to 0.7m
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CDA ID: WIGP Wigmore Lane / Eaton Green Road during the 1%AEP event. Under these conditions, the road is likely to be impassable to vehicles - especially at the southern end where ponding reaches 1m deep. The majority of predicted residential property flooding is located adjacent to Wigmore Lane. Flooding is likely to make the Wigmore Lane / Eaton Green Road intersection impassable. Predicted flooding of infrastructure includes the Thames Water foul water pumping station at the Wigmore Lane / Eaton Green Road intersection.
Table 5.15: Summary of Risk Outside CDAs (Adapted from Capita Symonds, 2013)
CDA ID: n/a Summary of Risk Outside CDAs
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 1254 727 83 244
>0.5m 29 90 32 53
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 1 11 2
>0.5m 0 1 3 1
Flood impacts: Key items of infrastructure predicted as being affected by surface water flooding deeper than 0.5m are summarised below: - Highly vulnerable: Fire Station (Corner of New Bedford Road and Studley Road) – mainly influenced by Main River flooding from the River Lea - More vulnerable: Health Care Centre (Mill Street) – Mainly influenced by Main River flooding from the River Lea through the Luton Town Centre - More vulnerable: Health Care Centre (Bridge Street) - Mainly influenced by Main River flooding from the River Lea through the Luton Town Centre - More vulnerable: Educational Building – Driver Training (Corner Telford Road and New Bedford Road) - Mainly influenced by Main River flooding from the River Lea through the Luton Town Centre - Other: Electricity Substation (Corner of Mill Street and New Bedford Road) - Mainly influenced by Main River flooding from the River Lea through the Luton Town Centre
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Table 5.16: Summary of Risks in CDAs Outside the Borough Boundary * (Adapted from Capita Symonds, 2013)
CDA ID: n/a Summary of Risks in CDAs Outside the Borough
Local Other
Flood Surface water Sewer Source Ord. watercourse Main river
Groundwater -
Approx. Households Commercial / Unclassified land industrial use Depth Non-deprived Deprived
>0.1m 154 0 18 9
>0.5m 0 0 0 0
Approx. Infrastructure Depth Essential Highly vulnerable More vulnerable Other
>0.1m 0 0 0 0
>0.5m 0 0 0 0
Flood impacts – Nimbus Park / The Herculean CDA: Commercial property flooding is generally located in the three business parks – Townsend Estate, Apex Business Centre and The Herculean. Most of the residential flooding is located on the Townsend Industrial Estate flow path on Dunstable Road and Cemetery Road. Flood impacts – Upstream of Houghton Park CDA: Minor flooding is predicted for properties between Kent Road and Sundon Road with several more affected along the western side of Houghton Park Road. Although part of the overland flow is predicted to be through Hillcrest School, the depths are not predicted to significantly affect buildings. Flood impacts – Windsor Drive CDA: Minor surface flooding is predicted to affect the residential properties and local roads in this area.
* Three CDAs described in the draft SWMP are outside of the borough boundary. LBC is not therefore responsible for managing flood risk to properties in these areas, however, the overland flows that are generated can impact on infrastructure and properties within the borough, especially in the Houghton Brook floodplain. The relevant CDAs are: Nimbus Park / The Herculean; Upstream of Houghton Park; and Windsor Drive.
5.2 Key Issues for Materials Assets
5.2.1 In total, 5,500 properties and infrastructure assets are at risk of surface water flooding in excess of 0.1m in Luton, including:
Non-deprived households: 3,140;
Deprived households: 1,429;
Commercial/industrial premises: 331;
Unclassified land uses: 568; and
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Infrastructure: 32.
5.3 Likely Evolution of the Baseline in the Absence of the LFRMS
5.3.1 As stated in the draft Surface Water Management Plan, many of the borough’s drainage and flood protection assets have an effective life of 30 years or less. Furthermore, the frequency and intensity of extreme rainfall events is likely to increase with climate change. In this context, the baseline risk of flooding to material assets in the borough is likely to increase in future in the absence of an LFRMS.
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6 Population and Human Health
6.1 Demographics
6.1.1 The population of Luton has grown from 185,900 in 2001 to 205,800 in 2012, an increase of 10.7% in 11 years8. Over the same period, the East of England population has grown from 5,400,500 to 5,907,300 or 9.4%. However, the borough has a relatively young population when compared to the East of England and England averages9; see Figure 6.1.
Figure 6.1: Age profile of Luton (June 2012), with regional and England comparators
6.1.2 Male life expectancy (for males born in 2007-09) in Luton is 77.2, slightly less than the regional (79.3) and England (78.3) figures. For females (born in 2007-09) life expectancy is slightly longer at 80.6 but still less than the regional (83.0) and England (82.3) figures. The borough has seen a continual improvement in life expectancy which in 2000-02 was 75.0 for males and 79.1 for females, mirroring but slightly behind regional and national trends.
8 Neighbourhood Statistics: Resident Population Estimates. Accessed online at [October 2014]: http://www.neighbourhood.statistics.gov.uk/dissemination/LeadTrendView.do?a=7&b=6275157&c=luton&d=13&e=13&f=34025&g =6394327&i=1001x1003x1004x1005&l=1818&o=391&m=0&r=1&s=1414701339992&enc=1&adminCompId=34025&variableFamilyId s=6766&xW=1293&xW=1293 9 Neighbourhood Statistics: Key Figures for People and Society: Population and Migration. Accessed online at [October 2014]: http://www.neighbourhood.statistics.gov.uk/dissemination/LeadKeyFigures.do?a=7&b=6275157&c=luton&d=13&e=13&g=6394327 &i=1001x1003x1004&m=0&r=1&s=1414702136289&enc=1
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6.1.3 The population in Luton is expected to grow from 205,800 in 2012, to 241,100 in 2027, to259,600 in 2037, a growth rate of 26.1% over 25yrs. During the same period, Bedford’s population will grow from 159,200 to 198,700 or 24.8%, while Central Bedfordshire will grow from 260,000 to 332,900 or 28.0%10; see Figure 6.2.
6.1.4 The borough has an excellent record of taking account of Environment Agency advice regarding development in flood risk areas, with zero permissions having been granted contrary to agency advice between 2007-08 and 2010-1111.
6.1.5 The health profile of Luton’s population is broadly comparable with the regional and England averages, with slightly more people reporting good health or very bad health, and slightly fewer people reporting very good health, fair health or bad health12; see Figure 6.3.
Figure 6.2: Population projections, 2012, 2027, 2037
10 Office for National Statistics: Subnational Population Projections, 2012-based projections. Accessed online at [October 2014]: http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-335242 11 Luton Borough Council (March 2013): Scoping Report for the Sustainability Appraisal of the Luton Local Plan 2011-2031: Appendix 2: Baseline Information. Access online at [October 2014]: http://www.luton.gov.uk/Environment/Planning/Regional%20and%20local%20planning/Pages/Planning-policy-evidence.aspx 12 Office for National Statistics: Key Figures for Health and Care. Accessed online at [October 2014]: http://www.neighbourhood.statistics.gov.uk/dissemination/LeadKeyFigures.do?a=7&b=6275157&c=luton&d=13&e=6&g=6394327 &i=1001x1003x1004&m=0&r=1&s=1414706353674&enc=1
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Figure 6.3: Health profile (March 2011)
6.2 Key Issues for Population and Human Health
6.2.1 Luton is an already densely populated borough, with projections indicating that the population could grow by more than a quarter over the next 25 years, to almost 260,000 residents, increasing the pressure for development in areas at risk of flooding. Many of these people will be elderly people (despite the borough’s generally younger ager profile) and children who are more vulnerable to the impacts of flooding.
6.3 Likely Evolution of the Baseline in the Absence of the LFRMS
6.3.1 Demographic characteristics and trends in Luton are unlikely to dramatically change with or without an LFRMS. However, in the absence of an LFRMS, the number of people at risk from the impacts of flooding is likely to increase.
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7 Soil
7.1 Agricultural Land
7.1.1 As highlighted by the Soil Strategy for England13, soil is a vital natural resource, with a range of key functions. These include:
Nutrient cycling;
Water regulation;
Carbon storage;
Support for biodiversity and wildlife; and
Providing a platform for food and fibre production and infrastructure.
7.1.2 Soil quality has a strong influence on the quality of agricultural land. The Agricultural Land Classification system provides a method for assessing the quality of farmland to enable informed choices to be made about its future use within the planning system. A number of consistent criteria used for assessment include; climate (temperature, rainfall, aspect, exposure, frost risk), site (gradient, micro-relief, flood risk) and soil (depth, texture, stoniness).
7.1.3 The Agricultural Land Classification (ALC) system classifies land into five grades, with Grade 3 subdivided into Subgrades 3a and 3b. The best and most versatile (BMV) land is defined as Grades 1, 2 and 3a, which is deemed to be the land which is most flexible, productive and efficient in response to inputs and which can best deliver future crops for food and non-food uses such as biomass, fibres and pharmaceuticals.
7.1.4 Agricultural Land Classification maps were produced for England and Wales in the 1970s to provide general strategic guidance on land quality to planners, and are supplied by Natural England. They show only five grades because their preparation preceded the subdivision of Grade 3 and the refinement of criteria, which occurred after 1976. Figure 7.1 illustrates mapped ALC data in and around Luton and indicates that the majority of the borough was classified as urban or non-agricultural land. Segments of Grade 2 agricultural land are shown at the northern and western fringes of the town, with areas of Grade 3 land at the east, south and south-western fringes, however, the majority of these have been built over since the 1970s.
7.2 Minerals and Waste Sites
7.2.1 The Bedfordshire and Luton Minerals and Waste Local Plan Strategic Sites and Policies document was adopted in early 2014. It sets out strategic policies on which future waste management and mineral extraction will be assessed. It identifies strategic sites for mineral extraction, non-hazardous waste landfill and other waste management activities.
13 Defra (2011) Soil Strategy for England: http://www.defra.gov.uk/publications/2011/04/08/pb13297-soil-strategy/
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Figure 7.1: Agricultural Land Classification in and around the borough
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7.2.2 Waste recycling and recovery, including generating energy where appropriate, is an important part of the plan. The nearest strategic site to Luton will be at Thorn Turn, on the A5 near Houghton Regis. The plan safeguards the existing rail served aggregates depots at Leagrave Road and Crescent Road, which are shown on Figure 7.2, as well as the following asphalt- making plants and concrete batching plants that provide essential materials for road construction and maintenance14:
Concrete Batching Plants Asphalt Plants
Selbourne Road, Luton 30-31 Cosgrove Way, Luton
Cosgrove Way, Luton
Limbury Sidings, Leagrave Rd, Luton
Kingsway Luton
7.2.3 No sites in the borough are identified for mineral extraction or for large scale waste management because no sites have been previously proposed and Luton is a heavily built up area.
Figure 7.2: Policies Inset Map 9 (Source: Bedfordshire and Luton Minerals and Waste Local Plan)
14 Bedfordshire and Luton Minerals and Waste Local Plan – Strategic Site and Policies Plan Adopted 2014, accessed online at [October 2014]: http://www.centralbedfordshire.gov.uk/planning/minerals-and-waste/development-framework.aspx
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7.3 Previously Developed and/or Derelict Land
7.3.1 There are no sites currently on the Council’s register of contaminated land. However, in May 2009 the Council determined the land at 2-10 Guildford Street, Luton, as land within the Council’s area which was contaminated land for the purposes of section 78A(2) of the Environmental Protection Act 1990, in particular:
the contaminated land was causing pollution of controlled waters; and
the contaminant (hydrocarbons) is listed in Schedule 1 to the regulations; and
the waters being polluted were contained within a strata (upper cretaceous chalk) listed in Schedule 1 to the regulations.
7.3.2 Remediation works were completed between January 2010 and February 2011 followed by post-remediation groundwater monitoring. The advice of the Environment Agency was sought, which considered that there is no longer significant pollution of controlled waters being caused or a significant possibility of such pollution being caused, while the site and those sites immediately down-gradient remain in their current condition. It added that the source has not been completely removed and contamination remains in controlled waters within the putty chalk layer of the principal aquifer and the pathway has not been permanently broken.
7.3.3 The Council has concluded (in November 2012) that, having regard to the current use of the land and the advice provided by the Environment Agency, the land no longer meets the definition of contaminated land as defined by section 78A(2) of the Environmental Protection Act 1990. It should be noted that this statement is subject to the reservations set out above as to the use of the site and those down-gradient, and as to the remaining contamination.
7.3.4 Between 2001 and 2011 more than 95% of new dwellings in Luton were built on previously developed land. This figure reduced significantly in 2011/12 to 20112/13 due to the New Homes for Luton programme which delivers high levels of affordable housing on open space, a trend which is set to continue in the short-term. Despite this a high proportion of sites in the housing trajectory for Luton are considered to be previously developed15.
7.4 Key Issues for Soil
7.4.1 Luton has very limited soil and mineral resources, however, given the heavily developed nature of the borough and past industrial land uses, there are likely to be unidentified areas where land contamination could pose a threat to the water environment.
15 Luton Borough Council (April 2014): Strategic Housing Land Availability Assessment. Accessed online at [November 2014]: http://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Planning/Local%20Plan/Strategic%20housing%20land%20availab ility%20assessment%20April%202014.pdf
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7.5 Likely Evolution of the Baseline in the Absence of the LFRMS
7.5.1 The few remaining areas of agricultural land within the borough are likely to come under increasing development in future to meet housing needs, a situation which is unlikely to change with or without an LFRMS. However, the LFRMS will provide an important mechanism for developing and prioritising flood risk management actions, and will need to be mindful of the potential presence contamination sources and their effects on the aquatic environment.
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8 Water
8.1 Water Resources
8.1.1 Luton lies within the Upper Lee Abstraction Licensing Strategy (ALS) area, as indicated on Figure 8.116. The Upper Lee ALS covers an area that drains into the River Lea from its source near Luton downstream to Feildes Weir to north east of Hoddesdon where the River Stort meets the Lea. Below this point the River Lea is assessed in the London ALS. The Upper Lee catchment covers an area of approximately 1,033 km², includes the Rivers Upper Lee, Mimram, Beane, Rib, Ash, and Stort, and incorporates parts of Hertfordshire, Essex and Bedfordshire, including the urban areas of Luton, Stevenage, Harlow, Hertford, Welwyn Garden City and Bishops Stortford.
Figure 8.1: Upper Lee abstraction licensing area (Source: Upper Lee ALS 2013)
8.1.2 Outside of the urban areas the catchment is characterised by open farmland, predominately for arable use. The catchment contains a number of Sites of Special Scientific interest (SSSIs) and
16 Environment Agency (February 2013): Upper Lee Abstraction Licensing Strategy. Accessed online at [October 2014]: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/289885/LIT_2576_f0a9e6.pdf
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part of the Lee Valley Special Protection Area (SPA). Many of the watercourses exhibit characteristics of chalk stream habitat; the Mimram is considered to be the best example in the catchment.
8.1.3 The source of the River Lea is at ‘Five Springs’ in Leagrave, Luton, in Bedfordshire. The river is further fed by springs to the south east of Luton and then joined by the flow from East Hyde sewage treatment works which makes up the bulk of the flow. This is also the source of the river during sustained dry periods. The catchment lies predominantly on unconfined chalk. The River Lea and tributaries are dependent on the underlying groundwater aquifer for much of their flow with a smaller proportion coming from overland runoff. Because of this, many tributaries of the Lea are winterbourne and suffer from low flows during periods of low rainfall.
8.1.4 In summary, the Upper Lea catchment is classified as ‘water not available for licensing’ under all flow conditions, for all waterbodies (surface and groundwater). This is due to a combination of ecological sensitivities, the groundwater-fed nature of surface waterbodies, and downstream requirements (existing licences and environmental conditions in the London ALS catchment). In the Upper Lea catchment the most vulnerable and therefore critical Assessment Points (AP) are AP13, Lea source to Luton Hoo Lakes, and AP1, Rye Bridge.
8.1.5 The vulnerability of the chalk aquifer in Luton is further demonstrated by the presence of a groundwater Source Protection Zone (SPZ). Groundwater vulnerability to pollution is determined by the physical, chemical and biological properties of the soil and rocks, which control the ease with which an unprotected hazard can affect groundwater. Groundwater Source Protection Zones indicate the risk to groundwater supplies from potentially polluting activities and accidental releases of pollutants. Designed to protect individual groundwater sources, these zones show the risk of contamination from any activities that might cause pollution in the area. In this context they are used to inform pollution prevention measures in areas which are at a higher risk, and to monitor the activities of potential polluting activities nearby. The majority of the borough is covered by SPZ1, SPZ2 or SPZ3; see Figure 8.2. The Environment Agency sub-divides Source Protection Zones into four zones:
Zone 1 (Inner protection zone): Any pollution that can travel to the borehole within 50 days from any point within the zone is classified as being inside zone 1. This applies at and below the water table. This zone also has a minimum 50 metre protection radius around the borehole. These criteria are designed to protect against the transmission of toxic chemicals and water-borne disease.
Zone 2 (Outer protection zone): The outer zone covers pollution that takes up to 400 days to travel to the borehole, or 25% of the total catchment area – whichever area is the biggest. This travel time was established as the minimum amount of time needed to dilute, reduce in strength or delay pollutants before they reach the borehole.
Zone 3 (Total catchment): The total catchment is the total area needed to support removal of water from the borehole, and to support any discharge from the borehole.
Zone 4 (of special interest): Where local conditions mean that industrial sites and other polluters could affect the groundwater source even though they are outside the normal catchment area.
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8.1.6 There are three Groundwater Safeguard Zones in Luton: one is for nitrate from urban sources and includes most of central Luton, the other two, which are for boron and nitrate overlap with Luton to the west and east respectively. Some parts of Luton are in a groundwater Nitrate Vulnerable Zone.
Figure 8.2: Source Protection Zones in Luton
8.2 Water Quality
8.2.1 River Basin Management Plans focus on the protection, improvement and sustainable use of the water environment, as required by the Water Framework Directive. An essential part of the process is to determine the current status of waterbodies within a river basin district, and establish objectives for their improvement, accompanied by measurable actions. For surface waters there are two separate status classifications for water bodies; ecological and chemical. For a water body to be in overall ‘good’ status both ecological and chemical status must be at least ‘good’17.
8.2.2 For groundwater there are two separate classifications for groundwater bodies; chemical status and quantitative status. Each must be reported in addition to the overall groundwater body status. For a groundwater body to be at good status overall, both chemical status and
17 Environment Agency (2009): River Basin Management Plan: River Thames Basin District. Accessed online at [October 2014]: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/289940/geth0910bswc-e-e.pdf
39 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
quantitative status must be good. In addition to assessing status, there is also a requirement to identify and report where the quality of groundwater is deteriorating as a result of pollution and which may lead to a future deterioration in status. Table 8.1 shows the ecological, chemical and/or quantitative status of the waterbodies in Luton18.
Table 8.1: Luton waterbodies, status and objectives 2014/2015
Surface Waterbody Status and Objectives
Name Overall Ecological Chemical Objective
Lee (Luton to Luton Hoo Lake; Bad Bad Fail Good includes Cat, Houghton & Lewsey Brooks))
Ground Waterbody Status and Objectives
Name Overall status Quantitative status Chemical status Objective
Upper Lee Chalk Poor Poor Poor Good
Chiltern Chalk Scarp Poor Good Poor Good
Mid Chilterns Chalk Poor Poor Poor Good
8.3 Flood Risk
8.3.1 The Environment Agency fluvial flood map for Luton (August 2013) is shown at Figure 8.3. Flood Zone 2 is defined as having between 0.1% and 1% (or between 1 in 1000 and 1 in 100 year) probability of flooding each year; Flood Zone 3 is defined as having a 1% or greater (or 1 in 100 or greater) probability of flooding each year. Flood Zone 1 comprises all land outside Flood Zones 2 and 3 and is defined as having less than 0.1% probability of flooding each year. Areas at risk of fluvial flooding are associated with the River Lea and its tributaries.
8.3.2 The Upper Lea catchment covers an area of approximately 71km2 draining from its source at Leagrave, north of Luton, including the Houghton Brook and Lewsey Brook tributaries, to south of Wheathampstead (outside the study area) where it becomes the Middle Lea; see Figure 8.419. Apart from the urban areas of Luton and Dunstable in its headwaters, the catchment is predominantly used for arable farming on unconfined chalky soils. Luton and Dunstable are major urban areas within the catchment; the M1 and London-Luton airport are major transport links that also fall within the catchment.
8.3.3 The geology of the study area consists of Chalk with the Lambeth Group along the north east and south west sides of the borough and Glaciofluvial Deposits along the River Lea. The topography of Luton generally slopes towards the River Lea which runs in a south easterly direction through the centre of the town.
18 Environment Agency Catchment Data Explorer, accessed online [13/7/2015] at: http://environment.data.gov.uk/catchment- planning/WaterBody/GB106038033391 19 Capita Symonds (February 2013): Luton Strategic Flood Risk Assessment Level 1 (Update). Accessed online at [October 2014]: http://www.luton.gov.uk/Environment/Planning/Regional%20and%20local%20planning/Pages/Planning-policy-evidence.aspx
40 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
Figure 8.3: Fluvial flood risk in Luton
41 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
Figure 8.4: River catchments and watercourses (Source: Capita Symonds, 2012)
Figure 8.5: Susceptibility to groundwater flooding (Source: Capita Symonds, 2012)
42 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
8.3.4 The highest elevations are in the north-west and the lowest in the south east. Due to the local geology the study area has extensive aquifers, many being used for potable and/or industrial water supply. In addition, most of the watercourses in the area are spring-fed, indicating groundwater levels are at or very close to the ground surface in some locations throughout the study area. Figure 8.5 indicates the extent of the borough susceptible to groundwater flooding.
8.3.5 Historically, areas of Luton have experienced flooding due to surcharged sewers. This is thought to be associated with rapid expansion to the north of the town in the 1950’s and 60’s, without upgrade of the sewer system in the centre of the town. Areas at risk from sewer flooding were determined through a review of records of sewer flooding provided by Thames Water as part of the SWMP. The data provided by Thames Water for use in the SWMP shows postcodes where properties are known to have experienced sewer flooding prior to February 2012. The data provides a broad overview of flood incidents in the borough as it is not property specific, instead providing information in postcode sectors (a four digit postcode). The majority of the incidents of sewer flooding are located in the Limbury area of Luton but no further details on the locations of sewer flooding events or actions taken to mitigate against future sewer flowing were available. Figure 8.6 indicates the extent of the borough susceptible to sewer flooding; the numbers listed in the legend indicate the number of recorded sewer flooding incidents in each postcode sector during the ten years to 2012.
8.3.6 Additionally, areas of steep ground have the potential to generate runoff which can present a flood source. The steep topography in parts of the study area may present a flood source to areas down slope. Figure 8.7 indicates the extent of the borough susceptible to surface water (pluvial) flooding.
8.4 Key Issues for Water
8.4.1 Luton sits atop of important chalk aquifers and hosts the source of the River Lea, both of which provide important sources of water for household and commercial use. The area is currently deemed to be over abstracted and scope for additional abstraction licences is very limited. Surface and ground water quality is at best moderate; for example, the River Lea (from Luton to Luton Hoo Lake) is a heavily modified waterbody with poor ecological potential, while the Upper Lea Chalk and Chiltern Chalk Scarp suffer from poor overall status.
8.4.2 Large parts of the borough are subject to flood risk from a range of sources, including fluvial, pluvial, groundwater and sewer flooding.
8.5 Likely Evolution of the Baseline in the Absence of the LFRMS
8.5.1 The status (quality and quantity) of water resources in the borough should steadily improve if the objectives of the Abstraction Licensing Strategy and River Basin Management Plan are progressed. The LFRMS is unlikely to have a significant bearing on these factors, but will provide a key mechanism for managing and communicating flood risks, and developing and implementing flood protection measures (including sustainable drainage systems) which should help to reduce negative impacts on the quality and quantity of water resources.
43 SEA for the Luton Local Flood Risk Management Strategy: Scoping Report July 2015 UE-0161 SEA- Luton LFRMS Scoping_4_150715
Figure 8.6: Sewer flooding probability areas (Source: Capita Symonds, 2012)
Figure 8.7: Surface water depths during a 100yr rainfall event (Source: Capita Symonds, 2012)
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Appendix E: SEA Framework
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J SEA Framework Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy # SEA Objective Indicator / Decision making criteria: - Will the option/proposal help to… Relationship to SEA Directive 1 To conserve and enhance biodiversity Q1a Protect and enhance nationally designated habitats Biodiversity, flora and fauna
Q1b Protect and enhance locally designated habitats and green spaces
Q1c Protect and enhance priority habitats, and the habitat of priority species
Q1d Achieve a net gain in biodiversity
Q1e Enhance biodiversity through the restoration and creation of well-connected multifunctional green and blue infrastructure 2 To promote adaptation to climate change Q2a Sustainably manage surface water run-off Climatic factors; Material assets; Population; Human health Q2b Ensure that development does not increase the risk of flooding (either on site or downstream) Q2c Where possible, reduce flood risk through changes in land use, reconfigurations to drainage and flood protection infrastructure, or de-culverting of water courses Q2d Facilitate the provision, protection and enhancement of green infrastructure within the borough 3 To conserve and enhance the historic environment, Q3a Assess, record and preserve archaeological features Landscape; Historic environment heritage assets and their settings Q3b Preserve and enhance buildings and structures of architectural or historic interest
Q3c Preserve and enhance the setting of cultural heritage assets
Q3d Establish and monitor the number of heritage features at risk of flooding
Q3e Support access to, interpretation and understanding of the historic environment
UE-0161 SEA Framework_4_150120 Luton LFRMS SEA Framework 1 / 2 SEA Framework Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy # SEA Objective Indicator / Decision making criteria: - Will the option/proposal help to… Relationship to SEA Directive 4 To conserve and enhance the character of the Q4a Protect and enhance the setting of, and views to/from, the Chilterns AONB Landscape; Historic environment landscape Q4b Protect and enhance landscape features within the borough
5 To protect water resources and minimise water Q5a Protect groundwater, especially in the most sensitive areas (i.e. source protection zones) Water pollution Q5b Support sustainable levels of water abstraction and minimise water consumption
Q5c Maintain and where possible improve water quality
Q5d Facilitate measures to move towards good ecological, chemical and quantitative status of waterbodies 6 To conserve and manage natural resources (land, Q7a Promote the most sustainable use of land Material assets; Soil minerals, agricultural land, materials) Q7b Minimise the loss of best and most versatile agricultural land
Q7c Encourage recycling of materials and minimise consumption of resources during construction
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Appendix F: High Level Assessment
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L Luton Local Flood Risk Management Plan SEA Objectives High Level Assessment SEA1 SEA2 SEA3 SEA4 SEA5 SEA6 ID Proposed Alternatives, Policies, Actions Improve the Understanding of Flood Risk in Luton
Pol1 Thresholds for Flood Investigations 0 + + + + + Alternative - Set lower thresholds for initiating formal flood investigations (e.g. 5 or Alt1a 0 ++ ++ ++ ++ ++ more adjacent dwellings and/or 1 or more business premises) High priority CDAs are high risk and have synergy with other projects; medium CDA1a + + + + + + priority are those with <£25,000 cost per property mitigated; all others are low Alternative - Different approach to prioritisation of CDAs (e.g. medium priority are CDA1b ++ ++ ++ ++ ++ ++ those with <£30,000 cost per property mitigated; all others are low) Act1.1 Produce riparian advice/ guidance + + + 0 + +
Act1.2 Investigation of riparian ownership 0 + 0 0 0 0
Act1.3 Raise community awareness of flood risk 0 + 0 0 + 0
Act1.4 Awareness and education 0 + 0 0 0 0
Act1.5 Raise awareness of flood risk mitigation measures 0 + 0 0 0 0
Act1.6 Prepare a community engagement strategy 0 + 0 0 0 0
Act1.7 Creation of asset register 0 + 0 0 0 0
Act1.8 Information Gathering – Highway Assets 0 + 0 0 0 0
Act1.9 Information Gathering – Flood Risk Assets 0 + 0 0 0 0
Act1.10 Reporting and recording of flooding incidents 0 + 0 0 0 0
Act1.11 Formal Investigations 0 + + + + +
Act1.12 Investigation into flooding of Critical Drainage Areas (CDAs) 0 + 0 0 0 0
Act1.13 Preliminary Flood Risk Assessment (PFRA) update 0 + 0 0 0 0
Act1.14 Groundwater study/investigation 0 + + 0 + +
Flood Risk in Planning and Development Control
Act2.1 Safeguarding areas from future development ++ ++ ++ + + ++
Act2.2 Floodplain protection ++ ++ + + + ++
Act2.3 Development and flood risk ++ ++ + + + ++
Act2.4 Runoff from future development 0 ++ 0 0 0 +
Act2.5 Assessment of SuDS applications + ++ 0 + + +
Act2.6 SuDS Retrofitting for reducing runoff + ++ 0 + + +
Act2.7 Sustainable development 0 + 0 0 0 0
Act2.8 Water Efficiency 0 + 0 0 + 0
Act2.9 Future development near flood defences 0 ++ + 0 + 0
Emergency Planning, Response and Resilience
Pol2 Sand Bags 0 0 + 0 0 0
Alt2a Supply sand bags to selected groups of residents in chosen locations 0 + + 0 0 0
Act3.1 Emergency Response Procedures 0 ++ 0 0 0 0
Act3.2 Establish resilience plans for Infrastructure Services 0 ++ 0 0 + 0
Flood Risk Mitigation
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Act4.1 Capital Improvement Project – Houghton Regis Flood Alleviation Scheme 0 ++ +/- +/- 0 +/-
Act4.2 Capital Improvement Project – Icknield Way Flood Alleviation Scheme 0 ++ +/- 0 0 0 Capital Improvement Project – Barton Road / Great Bramingham High Priority Act4.3 +/- ++ +/- +/- + +/- CDA Flood Alleviation Scheme Capital Improvement Project – Chapel Street / Arndale Centre High Priority CDA Act4.4 0 ++ +/- 0 0 + (CHAST) Flood Alleviation Scheme Capital Improvement Project – Barnfield West Academy / Poynters Road High Act4.5 +/- ++ 0 0 +/- 0 Priority CDA (BWPR) Flood Alleviation Scheme Capital Improvement Project – Vauxhall Way High Priority CDA (VAUX) Flood Act4.6 +/- ++ 0 0 + + Alleviation Scheme Capital Improvement Project – Barnfield College, Barnfield Avenue Flood Act4.7 0 + 0 0 0 0 Alleviation Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Beechwood Primary School/Railway Line Flood Act4.8 0 + 0 0 0 0 Alleviation Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Dalroad Enterprise Estate Flood Alleviation Act4.9 0 + 0 0 0 0 Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Dunstable Road/Luton Town Football Ground Act4.10 0 + 0 0 0 0 Flood Alleviation Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Farley Hill Flood Alleviation Scheme (LOCATION Act4.11 0 + 0 0 0 0 NOT SPECIFIED) Capital Improvement Project – Junction 11 M1 Flood Alleviation Scheme Act4.12 0 + 0 0 0 0 (LOCATION NOT SPECIFIED) Capital Improvement Project – Luton Sixth Form College Flood Alleviation Act4.13 0 + 0 0 0 0 Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Luton High Town Flood Alleviation Scheme Act4.14 0 + 0 0 0 0 (LOCATION NOT SPECIFIED) Capital Improvement Project – Nimbus Park/The Herculean Flood Alleviation Act4.15 0 + 0 0 0 0 Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Sundon Park/Railway Line Flood Alleviation Act4.16 0 + 0 0 0 0 Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Upstream of Houghton Park Flood Alleviation Act4.17 0 + 0 0 0 0 Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Wigmore Lane/ Eaton Green Road Flood Act4.18 0 + 0 0 0 0 Alleviation Scheme (LOCATION NOT SPECIFIED) Capital Improvement Project – Windsor Drive Flood Alleviation Scheme Act4.19 0 + 0 0 0 0 (LOCATION NOT SPECIFIED) Act4.20 Investigation/Study for Acworth Crescent/Pirton Road/ Montague Avenue 0 + 0 0 0 0
Act4.21 Investigation/Study for Pastures Way 0 + 0 0 0 0
Act4.22 Investigation/Study for Icknield Road 0 + 0 0 0 0
Act4.23 Investigation/Study for Midhurst Gardens 0 + 0 0 0 0
Act4.24 Inspection/Maintenance for Eighth Avenue 0 + 0 0 0 0
Act4.25 Investigation/Study for Blenheim Crescent 0 + 0 0 0 0
Act4.26 Investigation/Study for Enderby Road and source of Riddy Brook 0 + 0 0 + 0
Act4.27 Investigation/Study for Old Bedford Road 0 + 0 0 0 0
Act4.28 Investigation/Study for Chapter House Road 0 + 0 0 0 0
Act4.29 Investigation/Study for flood alleviation in CDAs 0 + 0 0 0 0
Act4.30 Investigation of condition of Mill Stream banks 0 + 0 0 0 0
Act4.31 Investigation/Study of impacts of Airport Extension 0 + 0 0 0 0
Act4.32 Investigation/Study of impacts of Marsh Farm Project 0 + 0 0 0 0
Act4.33 Inspection/Maintenance of watercourses and defences 0 ++ 0 0 + 0
UE-0161 Luton LFRMS HLA_3_150714 HLA 2 / 4 Luton Local Flood Risk Management Plan SEA Objectives High Level Assessment SEA1 SEA2 SEA3 SEA4 SEA5 SEA6
Act4.34 Inspection/Maintenance of highways drainage 0 + 0 0 + 0
Act4.35 Inspection and maintenance of surface water sewers 0 + 0 0 + 0
Act4.36 Inspection of River Lea culvert through town centre 0 + 0 0 + 0
Act4.37 Designation 0 + 0 0 0 0
Act4.38 Powers to undertake works 0 + 0 0 0 0
Act4.39 Property Level Protection 0 + + 0 0 +
Act4.40 Buildings Information Modelling (BIM) 0 + 0 0 0 0
Partnership Working
Act5.1 Stakeholder Engagement 0 + 0 0 0 +
Act5.2 Co-operation and data sharing 0 + 0 0 0 0
Act5.3 Catchment Partnership 0 + 0 0 + 0
Wider Environmental Benefits
Act6.1 Water Efficiency (retrofitting) 0 + 0 0 + 0 Alternative - Water Efficiency (retrofitting) - higher target e.g. 60% of existing Act6.1a 0 ++ 0 0 ++ 0 housing stock Act6.2 Water Efficiency (promotion/education) 0 + 0 0 + 0
Act6.3 Water Framework Directive ++ + 0 + + +
Act6.4 SuDS Retrofitting for water quality 0 + 0 0 + +
Economics
Act7.1 Funding Opportunities (FDGiA bids) 0 + 0 0 0 0
Act7.2 Developer Contributions 0 + 0 0 0 +
Act7.3 Funding Opportunities (SEMEP partnership) 0 + 0 0 0 0
Act7.4 Explore Partnership Schemes 0 + 0 0 0 0
Act7.5 Infrastructure Funding 0 + 0 0 0 +
Act7.6 Insurance 0 + 0 0 0 0 SEA1 SEA2 SEA3 SEA4 SEA5 SEA6 Key to the High Level Assessment Matrix ++ Likely strong positive effect + Likely positive effect 0 Neutral/no effect - Likely adverse effect -- Likely strong adverse effect +/- Uncertain effects SEA Objectives 1 To conserve and enhance biodiversity 2 To promote adaptation to climate change 3 To conserve and enhance the historic environment, heritage assets and their settings 4 To conserve and enhance the character of the landscape 5 To protect water resources and minimise water pollution 6 To conserve and manage natural resources (land, minerals, agricultural land, materials)
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Urban Edge Environmental Consulting Ltd Unit 5 | Westergate Business Centre | Brighton | BN2 4QN T: 01273 68 67 66 | E: [email protected] www.ueec.co.uk | @UrbanEdgeEnviro © Urban Edge Environmental Consulting Ltd 2015
Urban Edge Environmental Consulting Ltd
Unit 5 | Westergate Business Centre | Brighton | BN2 4QN
T: 01273 68 67 66 | E: [email protected] www.ueec.co.uk | @UrbanEdgeEnviro
© Urban Edge Environmental Consulting Ltd 2015