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Westminster Local Flood Risk Management Strategy (LFMS)

Appendix 2

Strategic Environmental Assessment (SEA)

Environmental Report April 2015

Abbreviations

AONB Area of Outstanding Natural Beauty

BAP Biodiversity Action Plan

CEMP Construction Environmental Management Plan

CFMP Catchment Flood Management Plan

CRoW Countryside and Rights of Way Act

Defra Department for Environment, Food and Rural Affairs

EA Environment Agency

EIA Environmental Impact Assessment

ER Environmental Report

EU European Union

FCERM Flood and Coastal Erosion Risk Management

FRM Flood Risk Management

FWMA Flood and Water Management Act

GI Green Infrastructure

LLFA Lead Local Flood Authority

LFRMS Local Flood Risk Management Strategy

NERC Natural Environment and Rural Communities

ODPM Office of the Deputy Prime Minister

PFRA Preliminary Flood Risk Assessment

PPG Planning Policy Guidance

PPP Plans, Policies and Programs

SAC Special Area of Conservation

SEA Strategic Environmental Assessment

SINC Site of Important Nature Conservation

SO Strategic Objectives

SPA Special Protections Area

SSSI Site of Special Scientific Interest

SuDS Sustainable Drainage System

SWMP Surface Water Management Plan

WCC Westminster City Council

WFD Water Framework Directive

ContentsIII

Section Page

Non-Technical Summary...................................................................................................................1Introduction..............................................................................................................................1Strategy Area...........................................................................................................................1The Draft Strategy....................................................................................................................2Consultation.............................................................................................................................3Baseline Environment..............................................................................................................3Environmental Effects of the Strategy......................................................................................5Opportunities with Multiple Benefits.........................................................................................7Monitoring................................................................................................................................7Next Steps...............................................................................................................................8

1 Introduction and Background...............................................................................................11.1 Overview......................................................................................................................11.2 Strategy Area...............................................................................................................11.3 Background to Strategy................................................................................................11.4 Objectives of the Westminster LFRMS........................................................................21.5 The Draft Strategy........................................................................................................21.6 Structure of Environmental Report...............................................................................2

2 SEA Approach and Methodology.........................................................................................52.1 Legal Requirement for SEA.........................................................................................51.2 SEA Scoping................................................................................................................52.3 Establishing SEA Objectives and Assessment Criteria...............................................72.4 Baseline Data Collection..............................................................................................92.5 Option Development....................................................................................................9

Review of Policies, Plans and Programmes................................................................9Option Identification and Appraisal..............................................................................9Integration of Environmental Considerations.............................................................10

2.6 Selection of Draft LFRMS..........................................................................................112.7 Monitoring..................................................................................................................112.8 Water Framework Directive (WFD) Assessment.......................................................112.9 Data Gaps, Assumptions and Limitations..................................................................121.10 SEA Compliance........................................................................................................12

3 Consultation.........................................................................................................................183.1 Approach....................................................................................................................183.2 Stakeholders..............................................................................................................183.3 Consultee Comments.................................................................................................183.4 Future Involvement....................................................................................................20

4 Baseline Environment.........................................................................................................214.1 Existing Environment Relevant to LFRMS.................................................................214.2 Inter-relationships of Environmental Issues...............................................................23

5 Assessment Results............................................................................................................245.1 Introduction................................................................................................................245.2 Compatibility of LFRMS Objectives with SEA Objectives..........................................245.3 Compatibility of Key Actions against SEA Objectives................................................245.4 Summary of Strategy Impacts....................................................................................25

Population and Human Health...................................................................................26Material Assets...........................................................................................................26Biodiversity, Flora and Fauna....................................................................................27Soils, Geology and Geomorphology..........................................................................27Water 27The Historic Environment...........................................................................................28Townscape.................................................................................................................28Cumulative and Synergistic Impacts..........................................................................29

5.5 Avoidance and Mitigation Measures..........................................................................29

IV

5.6 Environmental Opportunities with Multiple Benefits...................................................295.7 Using Green Infrastructure to Alleviate Flood Risk....................................................30

6 Implementation and Monitoring.........................................................................................326.1 Introduction................................................................................................................326.2 Monitoring Plan..........................................................................................................32

7 Next Steps............................................................................................................................367.1 Overview....................................................................................................................367.2 Next Steps..................................................................................................................36

8 References............................................................................................................................38

AppendicesA Environmental Baseline Report including FiguresB Plans, Policies and Programmes ReviewC Assessment MatricesD WFD Assessment

Tables1.1 Key Actions for 2014 – 20152.1 SEA Stages2.2 Issues Scoped Out2.3 SEA Objectives and their Assessment Criteria2.4 Examples of LFRMS Measures2.5 SEA Signposting Table3.1 Statutory Consultee Comments at Scoping Stage4.1 Summary of Baseline Environmental Features and Issues, Scoped into Assessment5.1 LFRMS actions with significant positive impacts on SEA receptors6.1 Proposed SEA Monitoring Framework for Uncertain Impacts Identified

Figures1 Westminster City Council’s Administrative Area2 Principal impacts of the LFRMS on the SEA topic area and inter-relationships

Non-Technical Summary

Introduction

The City of Westminster is a Lead Local Flood Authority, and as such has a duty to prepare Local Flood Risk Management Strategy (LFRMS). A Strategic Environmental Assessment (SEA) of the draft strategy is also required under the EU’s SEA Directive to assess the significant impact of the strategy on the Council’s wider environmental and social objectives.

The strategy sets out the aims and objectives for local flood risk management in Westminster, these are as follows,

To understand and explain the level of risk affecting Westminster;

To understand the roles of partners, businesses and residents in Westminster to manage flood risk.

To take a sustainable and holistic approach to flood risk management; and

To provide an action plan for flood risk management in the city

This SEA Environmental Report identifies, evaluates and describes the likely significant effects of the strategy on the Council’s environmental objectives. It provides an opportunity to develop the strategy that will meet wider environmental and social objectives.

Strategy Area

The strategy area is located in the north of London and covers approximately 21.5km (see Figure 1).

The City of Westminster sits between the London Borough of Brent to the north, the City of London and the London Borough of Camden to the east, the Tidal Thames to the south and the Royal Borough of Kensington and Chelsea to the west.

Figure 1: City of Westminster.

The Draft Strategy

1.2 This Local Flood Risk Management Strategy (LFRMS) sets out how Westminster, in partnership with other stakeholders will manage flood risk. It identifies where flood risk is greatest in Westminster and the responsibilities stakeholders have to manage it. It also sets out specific actions to reduce the risk of flooding in areas at greatest risk.

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Its objectives are

The LFRMS has been developed using evidence and analysis of flood risk, through consultation, and assessment against environmental objectives and assessment sub-criteria.

Table 1 lists the Key Actions for 2015 to 2020 that will help meet the aims and objectives of the LFRMS.

Table 1: Key Actions for 2015-2020

LFRMS 1 Actions: Tackling sources of flooding from highways

HIGH 1 Publication of most significant flood risk assets in Westminster

HIGH 2 Designation of significant flood risks assets to ensure that they are maintained.

HIGH 3 Manage and Maintain drainage assets

LFRMS 2: Tackling flood risk through planning and development

DEV 1: Provide Technical advice and promote SUDS through planning and development

DEV 2:Develop flood risk policy to manage, mitigate and adapt to flood risk

DEV 3 Review and Revise Strategic Flood Risk Assessment, as new data become available, or

on a 6 yearly cycle, whichever is more appropriate.

DEV 4: Review and revise Local Flood Risk Management Strategy and Flood Risk Management

Plan on a 6 yearly cycle.

DEV 5- Use LFRMS to inform development of Local and Neighbourhood and development plans,

drainage management and maintenance plans and programming: contingency plans and asset

management plans

LFRMS 3 Tackling flood risk through Raising Awareness

AWARE 1 Modelling Surface Water Flood Risk

AWARE 2 Prepare Flood Risk Awareness Communications Plan

AWARE 3 Publish significant flood incident reports

AWARE 4 Publish significant flood risk asset register.

LFRMS 4 Tackling flood risk through Partnership working

To understand and explain the level of risk affecting Westminster;




PART 1: Work in partnership with other flood risk management authorities, stakeholders and

relevant departments to address flood when it happens, and ensure contingency plans is

appropriate.

PART 2: Work with Thames Water and other key stakeholders to mitigate and manage flood risk

from surface water and manhole surcharge in Westminster,

Part 3 :Organise, attend and participate in flood risk management meetings such as Drain

London/LoDeg, London Central North Flood Risk Group and Westminster City Council’s flood risk

management group

LFRMS 5:Flood Risk Management and Maintenance

RISK 1: Seek opportunities for Sustainable Drainage Systems across the city

RISK 2: Implementation of LFRMS and action plan

RISK 3 Identify and prioritise programme of flood risk management projects and funding for 2015-

2020 and provide multiple benefits in terms of biodiversity, amenity, health and wellbeing.

Consultation

The statutory consultees for SEAs in England are Natural England, the Environment Agency and English Heritage. These three organisations were consulted on the SEA Scoping Report in 2014 and will also be consulted on the Environmental Report.

Comments received on the Scoping Report were taken into account in this Environmental Report.

Environmental Baseline Information

Baseline information about the existing social, economic and environment state of the city were gathered to identify the key issues, (Table 2) which was used to develop the LFRMS.

Relevant plans, programmes and strategies were reviewed to determine links objectives of the LFRMS and key objectives of other relevant plans and programmes.

Table 2: Environmental Baseline and IssuesBaseline Environmental Issues

People and Health

45,000 residents live within a high risk flood area

Westminster is the most visited London Borough

Direct effects on the population and properties within flood risk areas, including businesses and visitors in Westminster

Overall shortage of open space in


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Baseline Environmental Issues

Westminster contains some of the most deprived areas in London e.g. Queens Park and Church Street

Large area of recreation and open space (including Royal Parks, a network of canals, rivers and lakes, public spaces and Green Infrastructure) in Central Westminster

Westminster and access to these areas could be affected by flooding

Flood risk to important tourist, recreational and amenity resources

Flood risk contributes to quality of life

Material Assets

4 main rail termini and 32 underground stations

4 river bus piers and 157 bus routes passing through the city

New development (e.g. Crossrail ) will be supported by upgrades to existing infrastructure

Risk to existing, critical and proposed key transport infrastructure

New development will need to be appropriately located in terms of flood risk

Biodiversity, Fauna and Flora

Presence of 41 locally designated nature conservation sites (St Johns Wood Church Ground Local Nature Reserve and over 40 Sites of Importance for Nature Conservation)

Habitats and species of principal importance

Potential for negative or positive effects on the conservation sites and wildlife.

Need to ensure that flood risk measures do not negatively affect flow, frequency or duration of flooding to water-dependent wildlife.

Geology and soil Floodplain gravels and alluvial deposits in the

south, Taplow gravel in the central area around Paddington Basin and London Clay to the north

One disused landfill site at Portugal Street near Holborn and potential for other areas of contaminated land

Flood risk on soil quality, which could affect other SEA topics

Geology can influence the extent and likelihood of an area to groundwater flooding and/or the suitability of some types of Sustainable Urban Drainage options.

Water Highly built-up River Thames catchment with

poor water quality Three Groundwater Source Protection Zones

(SPZ) Two water bodies in strategy area – Thames

Middle (estuarine, heavily modified)- Part of the Grand Union Canal (artificial)

Direct and indirect effects on water resources, both surface and ground water, which could affect their ‘good’ chemical and ecological status as required by the WFD.

Heritage Palace of Westminster and Westminster

Abbey World Heritage Site Over 11,000 listed buildings, 56 Conservation

Areas, 21 listed historic parks and gardens, 5 Royal Parks, 85 London Squares, 2 Scheduled Monuments, 5 archaeological priority areas and strategic or protected views.

Non-designated heritage sites Historic landscape

Potential to reduce flood risk to archaeological assets

Potential for impacts on the character of the historic landscape and archaeological assets and their setting

Baseline Environmental Issues

Unrecorded archaeological potential around the Thames foreshore and river walls

Landscape Settled, low scape townscape with relatively

few buildings taller than six to eight storeys. Measures to reduce flood risk need to be

sympathetic to the character of the townscape

Environmental Effects of the Strategy

Environmental assessments of strategic objectives are presented in the Environmental Report.

Significant beneficial effects of the draft strategy are:

Improves flood risk management to local residents, businesses, workers and recreational users/tourists, key infrastructure affected by flooding

Encourages partnership working

Improves the understanding, preparedness and response and recovery from flooding and potential to reduce fear of flooding, thus may improve human health

Potential to reduce the risk of direct physical impacts of flooding

Potential opportunities to deliver social benefits through improved flood risk management as part of delivering the strategy, including opportunities for green and blue infrastructure. The incorporation of SuDs can also provide opportunities for recreational provision, educational provision and community cohesion.

Maximising the use of natural drainage patterns, including the implementation of Sustainable Drainage Systems is likely to have tangible benefits for biodiversity (e.g. habitat creation), water quality (by reducing urban pollution and combined storm sewer overflows entering the River Thames), hydro-morphology, soils and amenity.

No adverse effects have been identified, however uncertain impacts include potential changes that could affect land use, townscape, historic environment, water and biodiversity where objectives such tackling flood risk through highways will be carried out, as insufficient detail is available at this stage to determine the nature of the impact e.g. where the location and nature of structural measures is unknown.

The assessment of the strategic objectives showed that the effects were likely to have neutral, positive or uncertain effects for all SEA receptors. Those LFRMS actions with the most positive scores for environmental receptors are shown in Table 3.

Table 3


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Strategy Actions Relevant LFRMS Action SEA Objectives with positive scores

Tackling Flooding through highways management

HIGH 1 Publication of most significant flood risk

assets in Westminster

HIGH 2 Designation of significant flood assets to

ensure they are maintained

HIGH 3 Manage and Maintain Drainage Assets

.

Tackling flood risk through Planning and Development

DEV 1 Provide Technical Advice on SUDs through

planning

DEV 2 Develop flood risk policy to manage, mitigate

and adapt to flood risk

DEV 3 Review and revise Strategic Flood Risk

Assessments, as new data becomes available or on

a 6 yearly cycle, whichever is more appropriate

DEV 4 Review and revise Local flood risk

management Strategy and Flood Risk Management

plan on a 6 yearly cycle.

DEV 5 Use LFRMS to inform development of Local

and Neighbourhood Development Plans, Drainage

management and Maintenance Plans and

programming; contingency plans and asset

management plans.

All SEA receptors.

Tackling flood risk through improved understanding and raising awareness

AWARE 1 Modelling Surface Water Flood Risk

AWARE 2 Prepare Flood Risk Awareness

Communications Plan

AWARE 3 Publish significant flood incident reports

AWARE 4 Publish significant flood risk asset

register.


Tackling flood risk through partnership working

PART 1 Work in partnership with flood risk

management authorities, stakeholders and relevant

departments to address flood when it happens, and

to ensure contingency plans is appropriate.

PART 2 Work with Thames Water to mitigate and

manage flood risk from manhole surcharge in

Westminster.PART 3 Organise, attend and participate in flood risk

management meetings such as Drain

London/LoDeg, London Central North Flood Risk

Group, internal Flood Risk Management Group,

Flood Risk Management and Maintenance

RISK 1 Seek opportunities for Sustainable Drainage

Systems across the city.

RISK 2 Implementation of Local Flood Risk Strategy

and Action Plan

RISK 3 Identify prioritised programme of flood risk

management projects and funding for 2015-2020

and provide multiple benefits in terms of biodiversity,

amenity, health and wellbeing.

Opportunities with Multiple Benefits

The National Flood and Coastal Risk Management (FCERM) Strategy for England includes a section entitled ‘Achieving wider environmental objectives and other benefits’. This sets out key obligations for flood risk management authorities. In addition to the need for the LFRMS to comply with the SEA Directive, the obligations set out in the national FCERM strategy relate to compliance with the WFD and the Habitats and Birds Directives. One of the ways the LFRMS can achieve multiple social and environmental benefits is through the provision of green and blue infrastructure alongside LFRMS measures

Monitoring

The SEA includes a monitoring framework to measure the environmental performance of the LFRMS throughout its lifetime. Specific monitoring indicators are provided alongside the SEA objectives. This


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monitoring framework will be reviewed annually along with the delivery review of the LFRMS and action plan

Next Steps

This Environmental Report has be sent to City of Westminster departments, neighbouring boroughs, and statutory consultees and made available on line to the public for consultation from 27.April 2015 to June 5 2015.

CONTENTS, CONTINUED

SECTION 1

1 Introduction and Background

1.1 Overview

City of Westminster carried out a Strategic Environmental Assessment (SEA) of its draft Local Flood Risk Management Strategy (LFRMS).

As a Lead Local Flood Authority (LLFA), the City Council is required under Section 9 of the Flood and Water Management Act (FWMA) 2010 to develop, maintain, apply and monitor a LFRMS. The LFRMS sets out aims and objectives for local flood risk management and an action plan to meet them.

This Environmental Report (ER) sets out the results of a SEA carried out for the LFRMS in accordance with the Environmental Assessment of Plans and Programmes Regulations 2004 (the ‘SEA Regulations’). The purpose of the SEA is to identify, evaluate and describe the likely significant effects on the environment of implementing the LFRMS. The SEA is an iterative process, which informs the decision-making in strategy development.

This report is available for consultation, together with the draft LFRMS, to download from the project website at https://www.westminster.gov.uk/council-open-consultations

Comments should be provided by June 5th 2015 either by email or by post to:

[email protected] Westminster City Council 11th floor WestCity Hall64 Victoria StreetSW1E 6QP


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mailto:[email protected]

https://www.westminster.gov.uk/council-open-consultations

CONTENTS, CONTINUED

SECTION 1

1.2 Strategy Area

The strategy area is located in the north of London and covers approximately 21.5km (see Figure 1). The City of Westminster sits between the London Borough of Brent to the north, City of London and the London Borough of Camden to the east, the River Thames to the south (which is tidal) and the London Borough of Kensington and Chelsea to the west. The A40 Westway, A501 Marylebone Road, and Oxford Street run west to east through the Borough, connecting it to central London and neighbouring boroughs.

This area forms the basis for the baseline data collected and presented in Appendix A of this ER.

Figure 1: Westminster City Council Administrative Area

1.3 Background to Strategy

1.1 The Flood and Water Management Act 2010 gave the city council strategic responsibility for managing flood risk from surface water, groundwater and ordinary watercourses.

1.2 This Local Flood Risk Management Strategy (LFRMS) sets out how Westminster, in partnership with other stakeholders will manage flood risk. It identifies where flood risk is greatest in Westminster and the responsibilities stakeholders have to manage it. It also sets out specific actions to reduce the risk of flooding in areas at greatest risk.

1.3 The work identified in this strategy will help to reduce flood risk but cannot stop floods happening. All stakeholders will need to work together to reduce the likelihood of flooding and the impact of


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flooding if it were to happen. This is why it is important that all residents, businesses and other institutions are aware of their roles and responsibilities (Appendix 1).

The LFRMS builds upon work carried out in the last five years to assess the risk of surface water flooding including: -

The Environment Agency ‘Areas Susceptible to Surface Water Flooding’: national flood modelling produced in 2009

Westminster’s Surface Water Flooding Hydraulic Study (Halcrow 2010)

The Environment Agency’s Flood Map for Surface Water (2010)

Westminster Enhanced Surface Water Modelling (WSP) 2015

1.4 Objectives of the Westminster LFRMS

The overarching objectives of the LFRMS are to:

. To understand and explain the level of risk affecting Westminster;




In meeting these objectives, the City Council will take into consideration the impact on people and the environment. The LFRMS will seek to protect or enhance the environment and improve public realm. Wherever possible, the LFRMS will seek to provide the greatest value to the city by delivering multiple benefits through investment in flood risk management.

The LFRMS will cover the period 2015 to 2021, when the Strategy will be formally reviewed. This strategy sets out a range of actions to help achieve its objectives. The Strategic Objectives have been developed to set policy, procedures or processes which provide opportunities to improve the water environment or minimise flood risk or water pollution.

1.5 The Draft Strategy

The draft LFRMS has been identified through our analysis of structural and non-structural flood risk management measures, consultation responses and against environmental objectives and assessment criteria.

The draft strategy comprises local and regional measures involving a combination of recording and maintaining assets such as drains and sewers, responding to flood incidents and working with others to influence planning policy.

Table 1.1 sets out the Key Actions for 2015 to 2020 to manage flood risk,

1.6 Structure of Environmental Report

The remainder of the ER is set out as follows:

Section 2 – “SEA Approach and Methodology” provides background information on the SEA process and how it has been integrated with the development of the Strategy.

Section 3 – “Consultation” provides a method for identifying and method for consulting key stake holders and the consultation responses.

CONTENTS, CONTINUED

SECTION 1

Section 4 – “Baseline Environment” describes the environmental baseline of the Strategy, presents the key environmental effects without the LFRMS.

Section 5 – “Assessment Results” reports on the results of the assessments, the compatibility of the LFRMS with the SEA objectives, proposes mitigation measures, highlights the cumulative environmental benefits and how Green Infrastructure (GI) can alleviate the impacts of flooding.

Section 6 – “Implementation and Monitoring” describes how the Strategy will be implemented and monitored.

Section 7 – “Next Steps” outlines the future stages and the development of the Local Flood Risk Management Strategy (LFRMS) and adoption statement.


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SECTION 2

Table 1.1: Key Actions for 2015 – 2021

LFRMS 1 Actions: Tackling sources of flooding from highways

HIGH 1 Publication of most significant flood risk assets in Westminster

HIGH 2 Designation of significant flood risks assets to ensure that they are maintained.

HIGH 3 Manage and Maintain drainage assets

LFRMS 2: Tackling flood risk through planning and development

DEV 1: Provide Technical advice and promote SUDS through planning.

DEV 2:Develop flood risk policy to manage, mitigate and adapt to flood risk

DEV 3 Review and Revise Strategic Flood Risk Assessment, as new data become available, or

on a 6 yearly cycle, whichever is more appropriate.

DEV 4: Review and revise Local Flood Risk Management Strategy and Flood Risk Management

Plan on a 6 yearly cycle.

DEV 5- Use LFRMS to inform development of Local and Neighbourhood and development plans,

drainage management and maintenance plans and programming: contingency plans and asset

management plans

LFRMS 3 Tackling flood risk through improved understanding and raising awareness

AWARE:1 Modelling surface water flood risk

AWARE 2 Set up Westminster City Council Lead Local Flood Authority website

AWARE 3 Flood incident investigation and recording

AWARE 4 Flood asset register

LFRMS 4 Tackling flood risk through Partnership working

PART 1: Work in partnership with other flood risk management authorities, stakeholders and

relevant departments to address flood when it happens, and ensure contingency plans is

appropriate.

PART 2 Work with Thames Water and other key stakeholders to mitigate and manage flood risk

from surface water and manhole surcharge in Westminster

Part 3 :Organise, attend and participate in flood risk management meetings such as Drain

London/LoDeg, London Central North Flood Risk Group and Westminster City Council’s flood risk

management group

LFRMS 5:Flood Risk Management and Maintenance

RISK 1: Seek opportunities for Sustainable Drainage Systems across the city

RISK 2: Adoption and publication of Local Flood Risk Management Strategy and Action Plan

identifying projects for Flood risk hotspots

RISK 3: Identify prioritised flood risk management projects and funding to reduce flood risk, and

provide multiple benefits in terms of biodiversity, amenity, health and wellbeing in Westminster

CONTENTS, CONTINUED

SECTION 2

2 SEA Approach and Methodology

2.1 Legal Requirement for SEA

SEA is the systematic appraisal of the potential environmental impacts of high-level decision making such as policies, plans, strategies and programmes, before they are approved. It ensures that any implications of plans and programmes on the environment are fully and transparently considered before final decisions are taken.

The requirement to undertake statutory SEA is required by an EC Directive (2001/42/EC) ‘on the assessment of the effects of certain plans and programmes on the environment’, known as the ‘SEA Directive’, which came into force in 2004. The overall aim of the SEA Directive is to ‘provide a high level of protection to the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development’.

The Directive is implemented in England through the Environmental Assessment of Plans and Programmes Regulations (SI 1633 2004) - the SEA Regulations. The SEA Regulations provide a systematic method to consider likely effects on the environment and ensure environmental considerations are addressed as early as possible and in balance with technical and economic factors. They also require the delivery of multiple objectives and stakeholder inclusion.

The Directive and associated regulations make SEA a mandatory requirement for certain plans and programmes, which are likely to have significant effects on the environment. LFRMS are statutory plans that could potentially have significant effects on the environment and are therefore subject to the requirements of SEA. LLFAs need to take a proportionate approach to applying SEA to local strategies, particularly when environmental effects are not evident in the early stages of strategy development.

The principal steps in the SEA process in relation to the assessment of the LFRMS are shown in Table 2.1.

Table 2.1: SEA Stages

SEA Stage What is involved

Stage A: Scoping Setting the context and objectives, establishing the baseline and deciding on the scope

Stage B: Interim Assessment of LFRMS Option Development

Developing and refining LFRMS alternative options and assessing environmental effects in SEA matrices

Stage C: Preparing the Environmental Report

To present the predicted environmental effects of the LFRMS, including alternatives, in a form suitable for public consultation and use by decision-makers.

Stage D: Consulting Consultation on the draft LFRMS and the Environmental Report (and taking into account consultation feedback received)

Stage E: Monitoring Monitoring the significant effects of implementing the LFRMS


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SECTION 2

1.2 SEA Scoping

During the scoping stage of the SEA in early 2014, baseline information for the state of the City of Westminster was collated, which could be used to assess the effects of the LFRMS on sensitive environmental receptors. An SEA Scoping Report was produced and consulted on from April 10 2014 –May16th 2014.

Table 2.2 summarises the issues scoped out of further assessment because they are not considered likely to be significant.

Table 2.2: Issues Scoped Out

SEA Receptor Issues Scoped Out

Population and Human Health

Population: The LFRMS will not have a significant effect on noise. The effects of any local flood risk management activities on noise would be considered further at project EIA stage.

Biodiversity, Flora and Fauna

International Nature Conservation Sites: There are no internationally designated nature conservation sites within the borough and the LFRMS is therefore unlikely to affect international sites. Consequently, a screening assessment under the Habitats Regulations is not required.National Nature Conservation Sites: There are no nationally designated nature conservation sites within the borough and the LFRMS is therefore unlikely to affect national sites.Notable Habitats and Species: Detailed information on species and habitats of principal importance (under Sections 41 and 42 of the NERC Act 2006) should be considered at the EIA stage.

Soil, Geology and Geomorphology

Designated Earth Heritage Sites: There are no designated geological sites within the borough and it is not anticipated that any sites beyond this distance would be affected by the LFRMS.

Water

Flood Risk: The LFRMS aims to more sustainably manage the flood risk to people, businesses and infrastructure in Westminster. The LFRMS actions will ensure that they do not increase flood risk or transfer risk to third party property or land or neighbouring boroughs. There is therefore no requirement for the SEA to duplicate this objective.

Air and Climate

Air Quality: LFRMS options will not be affected by or have a significant effect on air quality.Climatic Factors: LFRMS options will not significantly contribute to climate change. The LFRMS options and measures should be adaptable to climate change, and will be considered through the development of the plan (rather than the SEA).

The Historic Environment

Non-designated features of archaeological and/or heritage interest: Non-designated sites of local or regional importance. The effects on these features would be considered further at project EIA stage. The effects of local flood risk management on as yet unidentified heritage resources will also be considered at project level assessment

Townscape and Public Realm

Landscapes: There are no known designated landscapes in the borough, except historic parks and gardens (see Historic Environment).Important Views and Public Realm Improvements: The LFRMS

CONTENTS, CONTINUED

SECTION 2

SEA Receptor Issues Scoped Outcould affect important views and public realm improvements but these cannot be meaningfully assessed at SEA level in the absence of details. The effects on these views should be considered at project level.

Consultation feedback (see Section 3), including updates to the environmental baseline and SEA ‘objectives’, have been incorporated into this ER.

2.3 Establishing SEA Objectives and Assessment Criteria

An integral part of the strategy development process has been the identification of environmental issues that need to be addressed by future flood risk management, and which are fundamental to policy appraisal. These features were identified through data review and consultation with key external organisations.

SEA objectives have been developed (Table 2.3) in order to assess the environmental effects of the LFRMS with consideration of the following: -

Objectives used in the Integrated Impact Assessment of Westminster’s City Plan;

Objectives developed for other projects, in particular SEAs of surface water management plans, LFRMS SEAs; and

The environmental baseline presented in Appendix A and summarised in Section 4.

SEA assessment criteria (Table 2.3) were also developed to assess the LFRMS objectives and LFRMS ‘actions. Table 2.3 shows the main receptors that were considered in the SEA and associated questions that were addressed to determine the implications of the LFRMS for these receptors. The assessment criteria are posed as questions that focus on key issues for consideration during the assessment of options and description of environmental effects. They provide the framework upon which sustainable objectives for local flood risk management were developed and appraised.

Table 2.3: SEA Objectives and their assessment criteria

SEA Topic(s)

Draft LFRMS SEA /Sustainability Objective

Underlying Assessment CriteriaWould the LFRMS, alone, or in combination with other plans…

Population and Human Health

To protect or improve health and well-being

Reduce the risk to people and human health from the effects of flooding?

To protect and enhance important tourist and recreational amenities, and seek opportunities to increase open

Impact on tourism or recreational pursuits in the long-term?

Opportunities to create new/additional recreational facilities, or increase amenity/access to open space/green infrastructure/blue ribbon network?

Have a positive impact on the local economy (e.g. through improved flood protection or enhanced recreation opportunities and green infrastructure provision)?


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SECTION 2

SEA Topic(s)



space throughout the borough

Material Assets

To manage flood risk to transport infrastructure

Improve protection of existing or proposed key transport routes (recreational and commercial) or infrastructure e.g. closures/ restrictions?

Conflicts between the option and ongoing or planned development?

Biodiversity, Flora and Fauna

To protect, enhance and create environments that encourages and supports biodiversity

Affect the condition of any locally designated conservation sites (e.g. LNRs or SINCs) through fragmentation, loss of existing wildlife?

Affect any priority or notable habitats including habitats supporting fish?

Support opportunities to create and enhance biodiversity? Reduce the risk of spreading non-native invasive species?

Soils, Geology and Geomorphology

To protect soil resources

Reduce risk of soil contamination, e.g. through remediation of contaminated land, or reducing flood risk to areas of known contaminated land?

Retain or enhance groundwater levels to improve soils? Retain or enhance flood attenuation rates and water

retention capacity of soil where necessary to protect soil structure or soil biodiversity?

Protect or increase vegetation and/or organic debris cover of soil?

Protect soil function and structure, i.e. reduce risk of compaction and sealing and promote best practice land management during construction of any FRM measures?

Reduce soil erosion caused by flooding?

Water To protect surface and groundwater quality and support the objectives of the WFD

Result in beneficial or adverse changes in flow regime (e.g. cause low flow; result in more natural variability of flow/ levels)?

Affect surface water and/or ground water quality? Support the WFD objectives of good ecological

status/potential (e.g. by restoring natural flow or morphology)?

Contribute to measures to improve the adjacent Thames Middle water body, as identified in the Thames RBMP?

Increase flood risk or transfer risk to third party property or land or neighbouring boroughs?

The Historic Environment Landscape and Visual Amenity

To conserve and enhance the historic environment and architectural, archaeological and cultural heritage

Affect any known features of historic, archaeological, architectural or artistic interest, or their settings (e.g. through changes in flood regime, hydrology, and hydro morphological adaptations)?

Result in potential loss of archaeological resource? Promote schemes that conserve and enhance the

condition/character of heritage assets and promote understanding of the significance of conservation areas and other heritage assets and their settings?

Conserve the local heritage character and distinctiveness of the historic townscape?

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SEA Topic(s)



Help secure the sustainable use and management of heritage assets?

Townscape To protect and enhance the unique setting and townscape character of Westminster

Affect existing characteristic or locally distinctive elements in the landscape character?

Introduce new structures into the landscape that may change its landscape value or sense of place?

Enhance the existing character of the existing townscape?

2.4 Baseline Data Collection

Data was collated to provide a baseline against which the significant environmental effects of the LFRMS actions could be measured and assessed for each receptor. Relevant baseline environmental information for the strategy is presented in Appendix A (as presented in the Scoping Report) and summarised in Section 4. The environmental baseline focusses on issues that are specifically relevant to flood risk associated with surface and groundwater.

2.5 Option Development

Review of Policies, Plans and ProgrammesAn initial review of policies, plans and programmes (PPP) relevant to the LFRMS was undertaken and included in the Scoping Report. Following consultation on the Scoping Report, the PPP review was updated and is provided in Appendix B of this report.

The review of the PPP objectives shows that there are no policies, plans or programmes that have a direct conflict of interest with the likely objectives of the LFRMS.

In general, the LFRMS has the potential to complement existing and proposed plans, for example the Westminster Biodiversity Action Plan (BAP) and associated habitats and species of principal importance. The LFRMS will also need to harmonise with development policies associated with the Local Development Framework and National Planning Policy Framework. The LFRMS has significant potential to enhance biodiversity associated with future LFRMS measures, as well as complement plans to boost local economies, for example by enhancing the recreational amenity associated with schemes. Enhancement opportunities are discussed in Section 5.

Option Identification and AppraisalTable 2.4 identifies potential LFRMS measures that could be implemented in Westminster city and that were considered during the development of the LFRMS. The table identifies whether the focus of the LFRMS measures is on investigation, source, pathway or receptor and whether they are structural or non-structural measures. It also splits the core themes into sub-themes, such as ‘study’, ‘resilience’ etc.

Table 2.4: Examples of LFRMS Measures

Focus Type Theme ExampleInvestigation Non

structuralStudy local flood risk studies


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Focus Type Theme ExampleInvestigation Non

structuralSurvey/modelling Flow survey, topographical survey,

modellingInvestigation Non

structuralSocial Community perception surveys

Source Structural Flow reduction/Source control

Suds (new and retrofit)Land management practices

Source Non structural

Policy Planning policies to influence location of development


Resilience Temporary or demountable flood defencesImproved resilience and resistance measuresImproved weather warning


Education Social change, education and awareness

Pathway Structural Conveyance Restoring or increasing capacity in drainage systemsSeparation of foul and surface water sewersManaging overland flows (e.g. changing cambers, raising kerbs)

Pathway Structural Diversion (of pluvial runoff) New or altered runoff routesPathway Structural Storage (pluvial) Offline/online attenuation of pluvial

flowPathway Non

structuralMaintenance Improved maintenance regimes or

enforcementPathway Non

structuralPolicy Land management practices

Receptor Structural Protection/permanent defences

Property level resilience (permanent)Community level resilience (permanent)

Receptor Non structural

Resilience Improved weather warningProperty level resilience (non-permanent)Community level resilience (non-permanent)


Education Social change, education and awareness


Policy Planning policies secure mitigation in new development

In identifying the preferred strategy, 15 Initial Assessments at known hotspot locations [areas at risk of surface water flooding] were undertaken of three Critical Drainage Areas (North West, Central and South Westminster) identified through enhanced surface water flood risk mapping carried out by WSP in 2015. .

During the development of the LFRMS, consultation has been undertaken with key stakeholders (see Section 3).

The SEA objectives have been used to assess the potential LFRMS objectives and action plan.

Further detail on the assessment approach is provided in the SEA Scoping Report. This includes a description of cumulative, synergistic and secondary effects and examples of each.

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Integration of Environmental ConsiderationsThe FWM Act aims to improve the sustainability of flood risk management – for example by setting new requirements and the basis for national standards for sustainable drainage systems (Suds). The Act includes a duty for local authorities, highways authorities, and internal drainage boards to contribute to sustainable development in discharging their flood and coastal erosion risk management (FCERM) functions. The Act also provides environmental powers for works that (a) have a net beneficial impact, (b) are consistent with the national FCERM Strategy and, (c) are deemed by the relevant authority to be desirable for the natural environment, the historic environment, landscape, or have amenity or leisure benefits. The LFRMS should in principle, therefore, have a positive impact on the environment. It can also influence and complement existing spatial planning policy and inform decisions on where development can and should not occur.

The SEA will continue to be fully integrated into the final development and implementation of the LFRMS to ensure that environmental considerations are taken into account and show how the SEA has influenced the LFRMS process. The SEA has identified avoidance and mitigation measures (in section 5.5). Enhancement opportunities are also discussed in section 5.6 The SEA also proposes a monitoring framework that is fit for purpose for a strategy of this nature. This is provided in section 6.

2.6 Selection of Draft LFRMS

The preferred LFRMS has been divided into five key objectives with associated actions, as shown in Table 1.1:

2.7 Monitoring

A monitoring framework has been developed to monitor the predicted significant adverse residual environmental effects of the Strategy, a requirement under the SEA Directive, and to update the baseline in order to inform future Strategy reviews. Monitoring also helps to identify any unforeseen effects of the Strategy, and ensure that where these effects are adverse, that action is taken to reduce or offset them.

Section 6 ‘Implementation and Monitoring’ of this report sets out the Monitoring Plan proposed for the Strategy area; this will be developed following consultation on the draft Strategy and SEA.

2.8 Water Framework Directive (WFD) Assessment

The WFD is a European Directive (Council Directive 2000/30/EC) which sets out a strategic planning process to manage, protect and improve the water environment. It came into force on 22 December 2000 and was transposed into UK law in 2003. The Directive aims to help to protect and enhance the quality of:

surface freshwater (including lakes, streams and rivers); groundwater’s; groundwater dependant ecosystems; estuaries; and Coastal waters out to one mile from low-water (not relevant to the Westminster LFRMS).

It establishes a framework for the protection of water bodies (including terrestrial ecosystems and wetlands directly dependent on them) which aims to;

prevent deterioration in the classification status of aquatic ecosystems, protect them and improve the ecological condition of waters;


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achieve at least ‘good’ status for all waters by 2015 or, if this is not possible (for reasons of technical infeasibility or excessive cost), by 2021 or 2027;

promote sustainable use of water as a natural resource; conserve habitats and species that depend directly on water; progressively reduce or phase out release of individual pollutants or groups of pollutants that

present a significant threat to the aquatic environment; progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants;

and Contribute to mitigating the effects of floods and droughts.

An assessment of compliance with the WFD has been undertaken as an integral component of the Strategy, potentially being used to influence decision making throughout the SEA and to guide the identification and development of environmentally acceptable options. This assessment is provided in Appendix D.

The water bodies relevant to this assessment are: Thames Middle (i.d. GB530603911402), which is estuarine and is considered to be heavily

modified by flood protection and navigation such that it does not meet the WFD target of good ecological potential; and

Part of the Grand Union Canal (i.d. GB70610078), an artificial water body that already meets the target of good potential.

2.9 Data Gaps, Assumptions and Limitations

During Strategy development, the following data gaps were identified: Effort has been made to avoid including baseline information or plans and programmes which

are of no clear relevance to the LFRMS, for example on SEA topics that have been scoped out.

The information presented in this report is the result of a desk-based review and no formal requests for records have been made. It may be necessary to collect further data against which to assess the potential environmental effects of the LFRMS with regard to specific LFRMS measures in the Action Plan.

Given the high-level nature of the LFRMS, which sets out actions that have not been defined in terms of their spatial or geographical extent, there is difficulty in developing a set of “reasonable alternatives” or scenarios to the objectives presented in the LFRMS. Rather than undertake a SEA which incorporates an alternative scenario, the SEA considers the environmental effects of a ‘do nothing’ option in Appendix A. Given that the LFRMS is likely to generate further more detailed plans it is anticipated that assessment of alternative scenarios for the strategy actions will be undertaken during any SEA process carried out at that stage in the future.

Our assessment of the environmental effects of the Strategy and the proposed mitigation measures is based on the assumption that a precautionary approach to assessment has been taken, assuming a “worst case” to predict the significance of effects.

The following uncertainties need to be considered as project level schemes are taken forward: As projects are developed through the implementation of the final Strategy and further detail

on the nature and location of proposed measures becomes available, the environmental effects will need to be further investigated, assessed, reviewed and refined. It is assumed that the projects can be designed or managed in such a way as to avoid significant adverse effects. However, if this is not the case, mitigation measures will need to be identified. The mitigation measures will also need to be reviewed and assessed as projects are taken forward.

There are uncertainties in our understanding of climate change, which may alter over the timescale of the Strategy.

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1.10 SEA Compliance

To meet the requirements of the SEA Directive and to ensure that the SEA process has fully integrated environmental considerations into the plan making process, a signposting table (Table 2.5) is provided, which is sub-divided into sections detailing the key requirements of the SEA Regulations (based on Appendix 9 of the ODPM SEA guidance (September 2005)) and where this information can be located within the ER.

Table 2.5: SEA Requirements located in the Environmental Report.

Environmental Requirements Location of information within ER (a) an outline of the:contents;main objectives of the plan or programme; and,relationship with other relevant plans and programmes;

Contents – Contents Section and Section 1.1 “Structure of the Environmental Report”Main Objectives – Section 1.1.2 “Objectives of the Westminster LFRMS”Relationship with other Plans – Section 2.2.2 “Review of Plans, Policies and Programs”, Section 2.8 “Water Framework Directive (WFD) Assessment”, Section 5.2, Section 5.3 and Section 5.4

(b) the relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme;

Appendix A and Section 4 “Baseline Environment”

(c) the environmental characteristics of areas likely to be significantly affected;


(d) any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Directives 79/409/EEC and 92/43/EEC;


(e) the environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation;

Section 2.2.2 “Review of Plans, Policies and Programs”

Table 2.3 ‘SEA Objectives and their assessment criteria’

(f) the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors;

Section 5 “Assessment Results”

(g) the measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme;

Section 5 “Assessment Results”

Section 6 “Implementation and Monitoring”


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Environmental Requirements Location of information within ER(h) an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information;

Selecting Alternatives – Section 2.6 “Selection of draft LFRMS”

Assessment Methodology – Section 2 “SEA Approach and Methodology”

(i) a description of the measures envisaged concerning monitoring in accordance with Article 10;

Section 6 “Implementation and Monitoring”

(j) a non-technical summary of the information provided under the above headings.

Non-Technical Summary

SECTION 3

3 Consultation

3.1 Approach

The statutory consultees for SEAs in England are Natural England, the Environment Agency and Historic England. Although not a requirement of the SEA Directive or the UK SEA Regulations to consult at the SEA Scoping stage, it is best practice to do so. It is a requirement to consult on the SEA Environmental Report, which includes an assessment of the key elements of the LFRMS. It is also a requirement of the SEA Regulations to consult with stakeholders who, ‘in the authority’s opinion, are affected or likely to be affected by, or have an interest in the decisions involved in the assessment and adoption of the plan or programme concerned…’

3.2 Stakeholders

The LFRMS has and will continue to include stakeholder consultation, those consulted include Westminster City Council Departments Water and sewerage companies; Neighbouring LLFAs; Highways Agency; Environment Agency (also a statutory SEA consultee); Historic England (also a statutory SEA consultee; and Natural England (also a statutory SEA consultee)

3.3 Consultee Comments

The SEA Scoping Report was subject to a five week consultation from 10 April 2014 to 16 May 2014. The City of Westminster and statutory stakeholders were invited to comment on the draft Scoping Report in 2014.

Environment Agency English Heritage Natural England

To assist consultees in providing a response, a series of consultation questions were also incorporated into the Scoping Report as follows: -

1) Are there any other plans relevant to the LFRMS that have not been considered in the Plans, programmes and Policy Review (Appendix A of the Scoping Report)?2) Are there any other environmental issues in the borough that should be considered within the SEA?3) Have all issues been appropriately scoped?4) Do you have any further comments on the proposed approach and scope of the SEA?

The response to these consultations is shown in Table 3.1.

Table 3.1: Statutory Consultee Comments at Scoping Stage

Stakeholder Summary of Comments Action

English Heritage

In the context of the National Planning Policy Framework, English Heritage are content that it:

contains a satisfactory assessment objective in relation to the historic environment;

scopes in the correct range of heritage assets and

No action required

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their settings; and identifies the correct issues in relation to the historic

environment.

Environment Agency (EA)

Consider a wider range of plans and policies in PPP review e.g. Thames Estuary 2100, Local Choices document, Mayors London Plan (2014), Thames Catchment Flood Management Plan, Thames RFCC Flood and Coastal Risk Management Medium Term Plan (MTP), Environmental Permitting Regulations, Groundwater Protection Policy, Groundwater Daughter Directive, Westminster’s Surface water management plan (and all neighbouring Boroughs’ Surface Water Management Plans), London Regional Flood Risk Appraisal 2009 GLA, Eel Regulations and Thames Corridor Catchment Abstraction Management Strategy (CAMS) for a more thorough assessment.

The plans identified have been included in the updated PPP review in Appendix B, and their associated objectives identified.

Amendment to text on Groundwater Source Protection Zones (SPZ).

Text updated in Appendix A to reflect changes.

Section 3.8.1 – The EA is not currently consulting on the Thames Estuary 2100 Plan it was published in November 2012.

Section 3.5.2 - this should not be restricted to terrestrial habitats, as we would not expect unmitigated negative impacts to aquatic or riparian habitats either. The value of the intertidal zone should be acknowledged and opportunities to enhance or create intertidal habitat explored/supported.

Updated to include wetland habitats. It is now acknowledged that the Thames is tidal in the study area however we feel it is appropriate to scope out the potential for intertidal habitat creation due to the densely populated nature of the area.

The measures delivered as part of the LFRMS should ensure that measures taken do not increase flood risk or transfer risk to third party property or land or neighbouring boroughs.

Text updated in Appendix A and incorporated into SEA ER.

Suggest making a link between how increased water efficiency will contribute towards less water needing to be abstracted and/or treated at STW before being discharged back into our rivers and water bodies.

Link made in text in Appendix A

The EA recommends that all LFRMS undergo an assessment to take account of the requirements of the WFD and ensure that the LFRMS does not conflict with the relevant local River Basin Management Plan (RBMP) or undermine the aims of the WFD.

A WFD assessment has been undertaken as part of the SEA (see Section 2.8 and Appendix D).

There is a need to understand the restrictions and limitations imposed due to geological conditions. This should be a material factor as part of any SEA because it can influence the extent and likelihood of an area to groundwater flooding and/or the suitability of some types of SUD options.

Text updated in Appendix A and in Table 4.1.

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Within the strategy, regarding environmental benefits to FCRM schemes, WFD should not just be curtailed to water quality and should also look at other options including morphology and floodplain connectivity. Also, enhancement opportunities for wetland habitats.

Agreed and included in SEA ER.

There could be an objective that would require any developer to demonstrate their proposal would not increase the flood risk to all key infrastructure not just transport infrastructure (e.g. pumping stations/STW/ power plants etc)

Agreed now reads key infrastructure

Natural England

A good range of topics are going to be covered within the scope of the SEA, which would fall within the approach and methodology that is expected by Natural England. Natural England have no further comments at this stage.

No action required

3.4 Future Involvement

This Environmental Report is available at https://www.westminster.gov.uk/council-open-consultations

Along with the draft Local Flood Risk Management Strategy. It is available for consultation from April 27th to June 5th 2015.

Consultation responses should be directed to: D James, Westminster City Hall, 11th floor, Asset and Infrastructure Management Team, 64 Victoria Street, London SW1E 6QP or

[email protected]

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4 Baseline Environment

4.1 Existing Environment Relevant to LFRMS

The baseline environmental data (including existing environmental and sustainability information) relevant to a range of environmental receptors is described in Appendix A ‘Baseline Environment’.

A summary of the baseline environmental features and key issues in the study area that have been scoped into the SEA are presented in Table 4.1.

Table 4.1: Summary of Baseline Environmental Features and Issues Scoped into Assessment

Baseline Environmental Issues Likely Evolution of the Baseline Environment without the LFRMS

Population and Human Health Of the 219,400 resident

population (Census 2011), 45,000 residents live within a high risk flood area

Westminster is the most visited London Borough

Westminster contains some of the most deprived areas in London e.g. Queens Park and Church Street

Large area of recreation and open space (including Royal Parks, Blue Ribbon network of canals, rivers and lake, iconic public spaces and Green Infrastructure) in Central Westminster

Direct effects on the population and properties within flood risk areas, including businesses and visitors in Westminster

Quality of life is affected by flooding

Overall shortage of open space in Westminster and access to these areas could be compromised by flooding

Flood risk to important tourist, recreational and amenity resources

Flood risk contributes to level of deprivation

Population projected to rise by approximately 240,000 by 2031 (Westminster City Council 2012).

Direct and indirect risks to human health from all flood sources likely to increase, and exacerbated by climate change;

Tourism and associated recreational areas will continue to be affected by flooding.

Increasing development will exert pressure on the floodplain.

Material Assets 4 main rail termini and 32

underground stations 4 river bus piers and 157 bus

routes passing through the city New development (e.g.

crossrail) will be supported by upgrades to existing infrastructure

Risk to existing, critical and proposed key transport infrastructure

New development will need to be appropriately located in terms of flood risk from River Thames

Climate change will increase risks to material assets and critical transport infrastructure (with associated capacity increases) affected by flooding.

Proposed developments will require greater flood defences

Biodiversity, Flora and Fauna 1 Local Nature Reserve (St

Johns Wood Church Ground) and over 40 Sites of Importance for Nature

Potential for negative or positive effects on the LNR, SINCs and terrestrial, aquatic or riparian habitats.

Climate change and land management activities will increasingly affect habitats

Water dependent habitats will SECTION 0 4 BASELINE ENVIRONMENT

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Conservation (SINCs) Habitats and species of

principal importance

Need to ensure that flood risk measures do not adversely affect flow, frequency or duration of flooding to water-dependent habitats.

come under increasing pressure as demand for water increases.

Soil, Geology and Geomorphology Floodplain gravels and alluvial

deposits in the south, Taplow gravel in the central area around Paddington Basin and London Clay to the north

One historic landfill site at Portugal Street near Holborn and potential for other areas of contaminated land

Flood risk on soil quality, which could affect other SEA topics

Geology can influence the extent and likelihood of an area to groundwater flooding and/or the suitability of some types of SUD options.

Soil erosion will continue due to surface water flash flooding and other causes

Continued compaction and sealing through an increase in developed areas/impermeable surfaces

Potential flood risk to contaminated land or historic landfill

Water Highly urbanised River

Thames catchment with poor water quality

Three Groundwater Source Protection Zones (SPZ)

Two water bodies in strategy area – Thames Middle (estuarine, heavily modified)- Part of the Grand Union Canal (artificial)

Direct and indirect effects on water resources, both surface and ground water, which could affect their ‘good’ chemical and ecological status as required by the WFD.

Requirement for a preliminary WFD Assessment (see Appendix D).

Water quality and water resources may increasingly be affected by urban flooding, which provides a potential pathway for pollution.

Historic Environment Palace of Westminster and

Westminster Abbey World Heritage Site

Over 11,000 listed buildings, 56 Conservation Areas, 21 listed historic parks and gardens, five Royal Parks, 85 London Squares, 2 Scheduled Monuments, 5 archaeological priority areas and strategic or protected views.

Non-designated sites and HER sites of national importance

Historic landscape Unrecorded archaeological

potential around the Thames foreshore and river walls

Potential to reduce flood risk to archaeological assets

Potential for impacts on the character of the historic landscape and archaeological assets and their setting

Historic environment will continue to shape the character of the borough

Archaeological assets will continue to be threatened by development pressures, inadequate management of landscapes and inappropriate development.

Potential loss or damage to historically significant features, particularly non-statutory historic buildings from increasing flood risk and indirect impacts e.g. from changes in water table levels.

Townscape and Public Realm


Westminster LFRMS SEA: Environmental Report


Settled, low scape townscape with relatively few buildings taller than six to eight storeys.

Measures to reduce flood risk need to be sympathetic to the character of the townscape

Increasing urbanisation increasing pressure on the skyline

Plans to de-clutter streets and improvements to the townscape likely to be implemented.

4.2 Inter-relationships of Environmental Issues

Figure 2 is intended to simplify the depiction of potential impacts and not portray all conceivable indirect impacts. The thickness of the line shows the relative importance of the link and influence between the topic areas. Green arrows represent the links between SEA topic areas.

Climatic factors are not included in the core diagram area as it has been assumed that the LFRMS would likely lead to better climate change adaptation and resilience, through reduced flood risk, and be in harmony with this topic rather than have a potentially negative influence on it in the same way as the other SEA topics. This SEA receptor was scoped out of further assessment.

There are clearly many, often more subtle, relationships that are not represented in this diagram – for example flood risk to areas with high levels of deprivation may disproportionately affect human health if people, or their neighbourhoods, are less able to address the consequences of flooding. Conversely, environmental opportunities may also be delivered through the LFRMS that deliver multiple benefits, including environmental, economic (e.g. through increased tourism) and social benefits. These enhancement opportunities are described further in section 5.6 ‘Environmental Opportunities with Multiple Benefits’.

Figure 2: Principal impacts of the LFRMS on the SEA topic areas and Inter-relationships

Key: Impact on (+ve or –ve):Connections with:Strong impact or connection:


5 Assessment Results

5.1 Introduction

The LFRMS strategic objectives have been assess against the SEA objectives and potential significant environmental effects that may occur with the implementation of the LFRMS, the underlying assessment criteria and the environmental baseline. The assessment of these environmental effects has been informed by professional judgement and experience with other LFRMS SEAs.

The appraisal methodology used during the assessment is presented in Appendix C.

Appendix C ‘Assessment Matrices’ also presents the assessment of the compatibility of the LFRMS Objectives with the SEA Objectives (Section 5.2), and presents the environmental assessment of the key actions of the LFRMS (Section 5.3).

5.2 Compatibility of LFRMS Objectives with SEA Objectives

Table C3 in Appendix C, assesses each of the draft LFRMS objectives against each of the SEA objectives. The assessment results show positive, neutral or uncertain outcomes for all LFRMS objectives.

1. To understand and explain the level of risk affecting Westminster;

2. To understand the roles of partners, businesses and residents in Westminster to manage flood risk.

3. To take a sustainable and holistic approach to flood risk management; and

4. To provide an action plan for flood risk management in the city

LFRMS objective 1 ‘To understand and explain the level of risk affecting Westminster’ will help improve the understanding of flood risk within the local community but is likely to have a neutral impact on some SEA receptors, as it does not directly manage flood risk to environmental assets. However, this objective may positively affect human health, by improving the understanding and preparedness of the local community to flooding (and thus may reduce the fear of flooding).

LFRMS objective’s 3 ‘to take a sustainable and holistic approach to flood risk management ‘4 ‘To provide an action plan for areas at particular risk from surface water flooding ’ and 2 to understand the roles of partners, businesses and residents in Westminster to manage flood risk’ will result in the provision of key actions to manage flood risk, which will directly benefit a range of environmental and built assets. Uncertain effects on biodiversity, landscape and the historic environment have been identified where the implementation proposals have the potential to affect the condition of nature conservation/habitats (positively or negatively), the landscape/townscape character and heritage, dependent on the nature and location of the proposals.

5.3 Compatibility of Key Actions with SEA Objectives

The environmental effects of the draft Strategy for each action have been assessed against the SEA objectives, Table 5.1 below, together with an assessment the likely significance of their implications for different receptors in the short-term (ST) to long-term (LT). ST effects are those



expected in the next 1 to 2 years (2014-2015); MT effects are those expected in the next 2-4 years (until 2018); and LT effects are those expected in the next 5+ years (post strategy).

5.4 Summary of Impacts of Strategic objectives against SEA objectives.

The assessment of the strategy actions that underlie the strategy objectives showed that the measures were likely to have neutral, positive or uncertain effects for all SEA receptors. Those LFRMS actions with the most positive scores for environmental receptors are shown in Table 5.1.Table 5.1: LFRMS actions with significant positive impacts on SEA receptors


Tackling sources of flooding from highways

HIGH 1Publication of most significant assets in WestminsterHIGH 2 Designation of significant flood risks assets to ensure that they are maintained.HIGH 3 Manage and Maintain drainage assets

Population and human health, material assets, soils and geology, water, historic environment and townscape.

Tackling flood risk through planning and development

DEV 1 Provide Technical advice and promote SUDs through planningDEV 2 Develop flood risk policy to manage, mitigate and adapt to flood riskDEV 3 Review and Revise Strategic Flood Risk Assessment, as new data becomes available, or on a 6 yearly cycle, whichever is more appropriateDEV 4 Review and revise LFRMS and Flood Risk Management Plan on a 6 yearly cycleDEV 5 Use LFRMS to inform development of Local and Neighbourhood and Development Plans, drainage management and maintenance plans and programming; contingency plans and asset management plan

All SEA receptors

Tackling flood risk through improved understanding and raising awareness

AWARE 1 Modelling surface water flood riskAWARE 2 publish flood risk awareness communications planAWARE 3 investigate and publish significant flood incident reportsAWARE 4 publish significant flood risk asset register

. Human Health, Material Assets

Tackling flood risk through partnership working

PART 1 Work in partnership with other flood risk management authorities, stakeholders and relevant departments to address flood when it happens, and ensure contingency plans are appropriatePART 2 Work with Thames Water and other key stakeholders to mitigate and manage flood risk from surface water and manhole surcharge in Westminster.

All SEA receptors

Flood Risk Management and Maintenance

RISK 1 Seek opportunities for Sustainable Drainage Systems across the cityRISK 2 Implementation of Local Flood Risk Management Strategy and action planRISK 3 identify prioritised programme of flood risk management projects and funding for 2015-2020 and provide multiple benefits in terms of biodiversity, amenity, health and wellbeing

All SEA receptors


The effects of the draft Strategy on SEA environmental receptors are summarised below: -

Population and Human HealthNo adverse effects on population and human health have been identified.

The Strategy provides measures to improve flood risk management to the local residents, businesses, workers and recreational users/tourists affected by flooding. These include the recording and maintaining of assets such as drains and sewers, responding to flood incidents in partnership with the Environment Agency and Thames Water (to provide a unified strategy) and influencing planning policy for the approval of new developments. These measures including improvements to the highway drainage network aid in the reduction of the occurrence of flood instances, which will have direct beneficial impacts on the population currently at flood risk. To not record and maintain assets (i.e. under a ‘do nothing’ scenario) would result in negative impacts by increasing the incidents of flooding with associated impacts on human health and wellbeing.

Particular actions have been identified to tackle flood risk from buildings and development including the requirement for incorporating SuDS into new developments and sustainable design to manage surface water flood risks, the requirement for site specific flood risk assessments and the need to consider climate change impacts. Some of the actions include advice to increase awareness of flooding in local communities and to improve partnership working.

Working in partnership with departments and bodies responsible for flooding (e.g. the Environment Agency, RMAs, BIDS etc) will have a positive effect on all SEA objectives. Improving maintenance and raising awareness of the community to surface water systems will help to reduce the risk of flooding created by blockages within the surface water drainage systems and have a major beneficial impact on human health and wellbeing.

Most activities in the action plans are considered to have neutral to major positive impacts (with the exception of a few uncertain impacts where further detail is required to enable assessment) on human health by improving the understanding, preparedness and response of the local community to flooding. They may also help to reduce fear of flooding (although some uncertain impacts have been identified where increased awareness could increase stress if the flood risk is in close proximity to land ownership (and raises potential property insurance issues), and may even reduce the risk of direct physical impacts of flooding to people, human health and tourist/recreational assets in the strategy area.

Alleviating pressure on London’s sewer network will greatly benefit human receptors. These local to regional scale effects are likely to be positive for the local population.

The LFRMS will also look at a range of opportunities to deliver social benefits through improved flood risk management as part of the strategy and its delivery, including opportunities for green and blue infrastructure, which are discussed in Section 5.6 and 5.7. Some actions such as the incorporation of SuDs can also provide opportunities associated with green and blue infrastructure for recreational provision, educational provision and community cohesion.

There are also specific actions (RISK8 to identify flood management projects and funding programme for next five years to reduce flood risk, and provide multiple benefits in terms of biodiversity, amenity, health and wellbeing in Westminster and RISK4 Integrate open space strategy and green infrastructure objectives into LFRMS and Action Plan), which have direct objectives to improve human health.

Material AssetsNo adverse effects on material assets have been identified.

Most actions identified as part of the strategy should help manage flood risk to key transport routes including rail and bus routes and infrastructure, improving climate change adaptation (by reducing flood risk) and improving highway drainage. These actions are considered to have



neutral to major positive impacts on material assets (with the exception of a few uncertain impacts where further detail is required to enable assessment).

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on existing or proposed transport routes and infrastructure.

Care will need to be taken in implementing the strategy to ensure that any structural measures do not conflict with ongoing or proposed development and do not exacerbate surface water run-off on some highways.

Biodiversity, Flora and FaunaNo adverse effects on biodiversity have been identified.

Some actions such as the incorporation of SuDs will have major positive impacts on biodiversity, being sympathetic to the local environment while providing opportunities to create new habitats for wildlife.

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on biodiversity.

There are some actions such as drainage improvement works or where partnership working to reduce flooding on highways will be carried out, where insufficient detail is available at this stage to determine the nature of the impact e.g. where the location and nature of structural measures is unknown.

Care will need to be taken in implementing the strategy to ensure that any structural measures do not affect qualifying features of the locally designated conservation sites or priority or notable habitats in Westminster.

The LFRMS will also look at a range of opportunities to deliver biodiversity benefits through improved flood risk management as part of the strategy and its delivery, including opportunities for green and blue infrastructure, which are discussed in Section 5.6 and 5.7. There is also a specific action (to identify flood management projects and funding programme for next five years to reduce flood risk, and provide multiple benefits in terms of biodiversity, amenity, health and wellbeing in Westminster), which has a direct objective to improve biodiversity.

Soils, Geology and GeomorphologyNo adverse effects on soils or geology have been identified. The actions in the strategy are considered to have neutral to major positive impacts on soils and geology.

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on soils and geology.

WaterNo adverse effects on water have been identified. The actions in the strategy are considered to have neutral to major positive impacts on water resources.

The WFD Assessment (Appendix D) concluded that overall the draft actions in the Westminster LFRMS are unlikely to have any significant adverse impacts on any water bodies. Given the current level of detail on specific actions no detailed WFD compliance assessment is required at this stage, and no Article 4.7 assessment (derogation) is required.

Some of the draft actions in the LFRMS may give rise to schemes or physical interventions that themselves could require WFD compliance screening assessment; these are:

Highways drainage improvements HIGH3 HIGH4; Partnership schemes PART6; Investigate flooding hotspots VUL1 VUL2 VUL3.


Some of the draft actions will promote schemes or physical interventions that could make positive contributions towards WFD environmental objectives; these are:

Highways drainage improvements HIGH3 HIGH4; Development control (SUDS) DEV1 DEV4 DEV6; Partnership schemes PART6; Integrating flood risk management and greenspace RISK4; Investigate flooding hotspots VUL1 VUL2 VUL3.

Some actions such as the incorporation of SuDs will have major positive impacts on water, being sympathetic to the local environment while protecting water quality by reducing urban pollution and combined storm sewer overflows entering the River Thames. There are also opportunities for SuDS to create fountains (that use roof run-off), small ponds and wetlands as identified in the action for the Church Street Masterplan area (a vulnerable location at risk of surface water flooding), which would have major beneficial impacts on this SEA receptor.

These requirements for future assessment, and opportunities for positive contributions, will depend on the location and scale of the proposed physical interventions.

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on water.

The Historic EnvironmentNo adverse effects on the historic environment have been identified.

The actions in the strategy are considered to have neutral to major positive impacts on features of historic, archaeological, architectural or artistic interest.

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on the historic environment.

There are some actions such as drainage improvement works or where partnership working to reduce flooding on highways will be carried out, where insufficient detail is available at this stage to determine the nature of the impact e.g. where the location and nature of structural measures is unknown. During the design and implementation of these actions, care will need to be taken to ensure that any structural measures avoid harm to any known features of archaeological interest, and their settings (e.g. through changes in flood regime, hydrology, hydromorphological adaptation etc) and do not result in the potential loss of an archaeological resource.

English Heritage is currently producing Historic Environment National Guidance on SuDS, which should be followed as actions to tackle flood risk using SuDS are designed and implemented e.g. in relation to actions DEV1, DEV4, DEV6 and VUL4. This will include the need to assess the feasibility of SuDS in the historic setting of Westminster and identifying opportunities where the sensitive design of the strategy actions can bring benefits to the historic environment.

Implementation of the LFRMS will also look at a range of other opportunities to deliver environmental benefits through improved flood risk management, and schemes should be promoted that conserve and enhance the condition/character of heritage assets, the distinctiveness of the historic townscape and the local heritage character.

TownscapeNo adverse effects on townscape have been identified.

The actions in the strategy are considered to have neutral to major positive impacts on the character of the existing townscape.

Some of the actions involving non-structural measures or studies (e.g. developing risk based approach for maintaining assets, requiring developers in surface water hotspots) will have neutral impacts on the historic environment. Similarly, there are some actions such as drainage



improvement works or where partnership working to reduce flooding on highways will be carried out, where insufficient detail is available at this stage to determine the nature of the impact e.g. where the location and nature of structural measures is unknown. Any new structures will need to be carefully designed to ensure they blend in with the surrounding landscape character and any landscape protection and enhancement measures implemented as part of the LFRMS should consider the Trees and the Public Realm Strategy (Westminster City Council 2011) for Westminster.

Cumulative and Synergistic ImpactsIn line with the requirements of the SEA Directive, the identification and assessment of the cumulative and synergistic effects of the strategy has been undertaken and these are summarised: -

By better managing flood risk, the LFRMS actions should generally help to facilitate development identified in Westminster’s City Plan: Strategic Policies (2013) and ensure new developments have reduced flood risk, thus having beneficial cumulative impacts on population and human health.

Additionally, the LFRMS will help to complement the Housing Renewal Strategy (Westminster City Council 2010) and could potentially assist the implementation of one of the five priorities – i.e. improve the quality of the local environment, for example by identifying flood management projects with multiple benefits in terms of biodiversity, amenity, health and well-being (ACTION RISK 8), and through the provision of SuDS with opportunities for green and brown roofs, wetlands, roof gardens etc.

Actions outlined in the LFRMS for the implementation of SuDs are likely to complement the environmental objectives of most relevant plans identified in Appendix B in addition to the WFD.

The LFRMS has the potential to provide a high degree of synergy with complementary strategies whose primary focus is the reduction of flood risk, through implementing measures that minimise the risk of flooding and the associated effects on land use. For example, the LFRMS will have synergy with the Thames Catchment Flood Management Plan, as well as policies within the Local Development Framework related to managing flood risk.

The draft LFRMS was developed in such a way to ensure it was fully integrated with the plans identified in Appendix B and those summarised above.No cumulative impacts have been identified at this stage (in the absence of details relating to the spatial and temporal distribution of the LFRMS actions). The proposed strategy is likely to complement many other local plans but does have the potential for cumulative impacts on some SEA receptors, which would require further consideration at scheme level to ensure that these can be managed to avoid negative environmental impacts.

5.5 Avoidance and Mitigation Measures

As the assessment has found no negative impacts are likely at this strategy level, there are no recommended mitigation measures at this stage. However, mitigation will be considered at scheme level as part of any EIAs that are required to ensure that the identified environmental sensitivities in Westminster are safeguarded.

5.6 Environmental Opportunities with Multiple Benefits

The Natural Environment White Paper The Natural Choice: securing the value of nature, published in 2011, recognises that a healthy, properly functioning natural environment is the foundation of sustained economic growth, prospering communities and personal well-being. The National Planning Policy Framework also recognises the importance of the natural environment to wellbeing and sustainable development. Through the development of LFRMS, LLFAs can


help deliver LFRMS schemes that have environmental, social and economic benefits, thereby contributing to sustainable development.

Defra’s Making Space for Water makes a case for flood risk management that delivers the greatest environmental, social and economic benefit, consistent with the Government’s sustainable development principles. The National Flood and Coastal Erosion Risk Management (FCERM) Strategy for England also includes a section entitled ‘Achieving wider environmental objectives and other benefits’, which sets out key obligations for flood risk management authorities. These obligations relate to compliance with the WFD, Habitats and Birds Directives and other domestic commitments, notably including:

Environmental objectives under the WFD, including conservation objectives for Protected Areas (i.e. those parts of a water body that are designated under any other European Directive) under Article 4.1;

SSSI conservation objectives - as public bodies, every flood authority has a duty under Section 28G of the Wildlife and Countryside Act 1981 to take reasonable steps, consistent with the proper exercise of its functions, to further the conservation and enhancement of the features for which the SSSI was designated;

Physical restoration of lakes and rivers to meet SSSI objectives for; and UK national and local Biodiversity Action Plan (BAP) targets - Section 40(1) of the

Natural Environment and Rural Communities (NERC) Act 2006 places a duty on flood authorities to have regard, so far as is consistent with the proper exercise of their functions, to conserve biodiversity, including restoring or enhancing species populations or habitats. FCERM activities should involve no net loss of habitats and species of principal importance under Sections 41 and 42 of the NERC Act.

The LFRMS will also look at a range of opportunities to deliver social and environmental benefits as part of the strategy and its delivery. Improving green or blue infrastructure, biodiversity, recreation areas or access to these areas is likely to complement schemes such as the ‘Living Landscapes’ project promoted by the Wildlife Trusts and Natural England’s ‘Access to Nature’ grant scheme, which is aimed at encouraging people from all backgrounds to understand, access and enjoy the natural environment.

5.7 Using Green Infrastructure to Alleviate Flood Risk

The Green Infrastructure (GI) network includes parks and gardens, amenity and urban greenspace (from village greens to green roofs), green corridors (such as river, canal and rail corridors), and various other areas, including allotments, community gardens, city farms and churchyards.

The National Planning Policy Framework highlights the importance of green infrastructure in adapting to climate change. It states that; ‘New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure.‘

In relation to flood risk management (including flood risk from sources outside of the scope of the LFRMS), GI networks can be used for various purposes. These include;

providing dedicated flood water storage areas – thereby providing water for nature conservation or other purposes;

providing opportunities to aid a more natural and slower response to heavy rainfall - for example by developing and restoring GI to favour open water courses, through channel restoration and de-culverting;

helping manage surface water, by reducing flood risk from streams, rivers and sewers. Sustainable drainage systems (SuDS) can be used to recycle grey water and harvest rainwater, or, where appropriate, reduce flash flooding; and



make a direct contribution to improving home and community resilience to climate change, for example through green roofs that improve localised drainage.

Research by the University of Manchester has shown that:

increasing the green space cover in urban areas by 10 per cent reduces surface run-off by almost 5 per cent;

increasing tree cover in urban areas by 10 per cent reduces surface water run-off by almost 6 per cent; and

adding green roofs to all the buildings in town centres can reduce surface water run-off by almost 20 per cent.

GI can also reduce fossil fuel consumption by providing corridors for walking and cycling, thereby potentially reducing private vehicle usage and the air pollution associated with it. Increased uptake of walking and cycling can also improve general wellbeing, health and fitness as well as help reduce obesity levels. By providing recreation opportunities, GI can also reduce visitor pressure on vulnerable habitats. Due to the many social and environmental benefits of GI, the LFRMS should maximise opportunities to either create new GI or help extend, link up or improve the condition of existing GI. Plans for GI, including any delivered by the LFRMS, should seek to mimic natural drainage processes wherever possible. The landscape character assessment work undertaken by Natural England for Gloucestershire could potentially be used to assess the suitability of land for GI creation, extension or improvement. Factors such as land cover, habitat, soil type, topography and groundwater should all be considered in planning for GI. Locating new GI features on top of groundwater source protection zones could also help to avoid risks of groundwater contamination.

In any LFRMS scheme design, both planting and surfacing should aim to minimise surface water run-off in addition to meeting other design requirements. LFRMS schemes should aim to maximise the use of SuDS. SuDS encourage surface water to remain on site and infiltrate the ground. They have many environmental and social benefits, including;

Providing storm water attenuation that prevents flooding downstream; Protecting and potentially enhancing surface water quality by filtering pollutants; Improving groundwater recharge; Providing habitats for wildlife; and Providing landscape amenity for the community; Providing potential opportunities for community engagement, management and

ownership of SuDS.

As well as planning for new GI, the LFRMS needs to protect existing wetlands due to their important role in surface water management.


6 Implementation and Monitoring

6.1 Introduction

Under the SEA Directive there is a statutory requirement to monitor the environmental impacts of LFRMS implementation. Monitoring of the LFRMS will ensure that WCC continues to identify any environmental problems and issues that need resolving. The review of the Action Plan annually would provide a good opportunity to review and describe any changes to the environmental baseline from the implementation of the LFRMS, and, how WCC will work to mitigate any adverse effects identified. Monitoring the success of any enhancement schemes that are implemented as a result of the LFRMS should also be undertaken, as well as monitoring of potential adverse effects.

6.2 Monitoring Plan

Table 6.1 provides an overview of monitoring proposed in relation to the predicted ‘uncertain’ effects of the Strategy that have been identified, taking into consideration the SEA Assessment Criteria.



Table 6.1: Proposed SEA Monitoring Framework for Uncertain Impacts Identified

SEA Objectives Potentially Uncertain Impacts[relevant actions]

Monitoring Identified by SEA for Project Level EIA

Strategic Monitoring Required

Responsible Authority

1. To protect or improve health and well-being?

Potential for positive or negative changes to health and well-being from the effects of flooding

(RISK 1,2,3, HIGH 3, DEV 1,2,4,5, PART 1,2; AWARE 1,2,3.

Environmental assessment of detailed policy actions to inform design choices.

Number of properties at risk of flooding from all flood sources

WCC, Environment Agency and Thames Water

2. To protect and enhance important tourist and recreational amenities, and seek opportunities to increase open space throughout the borough

Potential for positive or negative impacts on tourism or recreational pursuits.

[RISK1,2,3; PART 2,3, DEV 4,5)]

Environmental assessment of detailed policy actions (including proposed location and nature of SuDS) to inform design choices and identify opportunities for green and blue infrastructure, where possible.

Change in area, number or quality of recreational and amenity facilities and access to open space, green infrastructure and blue ribbon network as a result of LFRMS implementation

WCC

3. To manage flood risk to transport infrastructure

Potential for positive or negative impacts on existing or proposed key transport routes

[RISK 2,3;HIGH 3, DEV 1,2,4,5, PART 1]

Environmental assessment of detailed policy actions (including proposed location and nature of SuDS) to inform design choices and avoid conflicts with ongoing or planned developments.

Number and severity of flood incidents leading to disruption (closures/restrictions) or damage to existing or proposed key transport routes or infrastructure

WCC

4. To protect, enhance and create environments that encourages and supports biodiversity

Potential for changes in locally designated habitat sites and priority or notable habitats

[RISK 1,2,3,DEV4,5; PART 2]

Environmental assessment of detailed policy actions (including proposed location and nature of drainage improvements, SuDS and measures to reduce flood risk) to inform design choices.

Annual monitoring of condition of LNRs and SINCs – and understand reasons for any changes recorded. Review and if necessary, revise actions (timing or nature) if observed changes indicate adverse effects.

WCC






Number of LFRMS measures that require habitat offsetting or mitigation [safeguard monitoring measure only - it is assumed that this monitoring will not be required as any action will be appropriately designed and implemented].

5. To protect soil resources

Potential for changes in soil quality, risk of soil contamination and change in organic debris cover of soil.

[HIGH 3, RISK 2,3, HIGH 3,DEV4,5]

Environmental assessment of detailed policy actions (including proposed location and nature of SuDS) to inform design choices.

Number of LFRMS measures constructed on previously undeveloped land

WCC

6. To protect surface and groundwater quality and support the objectives of the WFD

Potential changes in flow regime and water quality.

Uncertain whether actions and physical interventions will support WFD objectives or contribute to measures to improve the relevant water bodies.

[HIGH 3; RISK 2,3; DEV4,5, PART 2]

WFD compliance screening assessment of detailed policy options (including proposed location and nature of SuDS) will be undertaken at project level and will inform design choices.

Identify positive contributions to WFD objectives in relation to HIGH3 HIGH4; DEV1 DEV4 DEV6; PART6; RISK4; VUL1 VUL2 and VUL3.

Number of LFRMS measures that improve or reduce the status of the water bodies.

Ecological and chemical status of water body

Number of LFRMS measures that help restore riparian corridors, including floodplain connectivity and natural processes.

WCC and Environment Agency

7. To conserve and enhance the historic environment, and

Potential for positive or negative impacts on historic, archaeological, architectural or artistic

Appropriate archaeological assessments during project level of detailed policy actions (including proposed location

Number of heritage sites and Conservation Areas classified as ‘heritage at risk’.

WCC







architectural, archaeological and cultural heritage

interests, and their settings.

[DEV1,5; RISK 2,3]

and nature of SuDS and measures to reduce flood risk) to inform design choices.Consultation with English Heritage and City Archaeologist/ Conservation Officer.

Number and condition of heritage assets and historic landscapes that are affected by the LFRMS, and that are at risk of flooding.

Monitor development of English Heritage national guidance on development of SuDS and the historic environment, and its implications for relevant strategy actions.Number of enhancements to the historic environment as a result of LFRMS implementation

English Heritage

8. To protect and enhance the unique setting and townscape character of Westminster

Changes in character of townscape

[DEV1,4,5 RISK1,2,3]

Landscape and visual impact assessments (LVIA) undertaken, as appropriate, during project level of detailed policy actions (including proposed location and nature of SuDS and measures to reduce flood risk) to inform design choices, where actions involve new structures.

Number of LVIAs undertaken as part of implementation of LFRMS measures

Number of LFRMS measures that enhance the existing character of the townscape

WCC


7 Next Steps

7.1 Overview

The majority of measures within the LFRMS are likely to have a positive effect on the environment and the assessment matrices of Appendix C show the ‘headline’ effects in terms of their positive, uncertain or neutral nature.

Significant beneficial impacts of the draft strategy are:

Improves flood risk management to local residents, businesses, workers and recreational users/tourists, key transport routes affected by flooding.

Provides a unified strategy in partnership with the Environment Agency and Thames Water.

Improves the understanding, preparedness and response of the local community to flooding and potential to reduce fear of flooding, and thus may improve human health.

Potential to reduce the risk of direct physical impacts of flooding to people, human health and tourist/recreational assets in strategy area.

Potential opportunities to deliver social benefits through improved flood risk management as part of delivering the strategy, including opportunities for green and blue infrastructure. The incorporation of SuDs can also provide opportunities for recreational provision, educational provision and community cohesion.

Maximising the use of natural drainage patterns, including the implementation of Sustainable Drainage Systems is likely to have tangible benefits for biodiversity (e.g. habitat creation), water quality (by reducing urban pollution and combined storm sewer overflows entering the River Thames), hydromorphology, soils and amenity.

No adverse effects have been identified, however uncertain impacts include potential changes that could affect land use, townscape, historic environment, water and biodiversity where actions (such as drainage improvement works or where partnership working to reduce flooding on highways) will be carried out, as insufficient detail is available at this stage to determine the nature of the impact e.g. where the location and nature of structural measures is unknown.

7.2 Next Steps

The Environmental Report will be made publically available for consultation from April 27th 2015 to June 5th 2015 at the following https://www.westminster.gov.uk/council-open-consultations along with the Westminster’s Draft Local Flood Risk Management Strategy April 2015.

As the LFRMS is developed further, and future LFRMS schemes are considered, the SEA objectives and the underlying assessment criteria that relate to each SEA objective should be referred to. This will help to ensure that all receptors that relate to the objectives, including social, economic and cultural heritage receptors as well as natural environmental ones, are protected and enhanced, where possible.

In order to ensure positive effects of the LFRMS on the environment, it will be necessary to ensure that project level environmental assessment or appraisal feeds into the choice of location and scheme design for any new LFRMS measures and that detailed Environmental Impact Assessments




(EIA), if required, include measures to mitigate any adverse effects, for example through Construction Environmental Management Plans (CEMPs). Further environmental assessment of the LFRMS will take place via the SEA of the SWMPs in the county.

Project level Environmental Impact Assessment (EIA) may also be required for the construction of some LFRMS schemes.


8 References

CABE (2011). Available on: http://webarchive.nationalarchives.gov.uk/20110118095356/http:/www.cabe.org.uk/sustainable-places/advice/green-infrastructure-and-flood-risk

Communities and Local Government, 2012. National Planning Policy Framework. Available on: http://www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/planningpolicyframework/, accessed on 3/10/2012.

Defra (2005): Making Space for Water: Taking forward a new Government strategy for flood and coastal erosion risk management in England, http://archive.defra.gov.uk/environment/flooding/documents/policy/strategy/strategy-response1.pdf, accessed on 22/10/2012.

Defra (2012): UK Climate Change Risk Assessment: Floods and Coastal Erosion. Available on www.defra.gov.uk/environment/climate/government/risk-assessment

Defra (2013): The National Adaptation Programme: making the country more resilient to a changing climate.

Environment Agency (2009): Thames River Basin Management Plan

Major of London (2010): Draft Climate Change Adaptation Strategy: Sustainability Appraisal Report, February 2010.

Major of London (2014): Draft Further Alterations to the London Plan

Westminster City Council (2010): Core Strategy Sustainability Appraisal Appendices

Westminster City Council (2012): Integrated Impact Assessment, Scoping Report for Westminster’s City Plan

Westminster City Council (2013): Westminster’s City Plan: Strategic Policies

UK CCRA (2012): Climate Change Risk Assessment for the Water Sector. Available on: http://randd.defra.gov.uk/Document.aspx?Document=CCRASummaryWater.pdf, accessed on 1/10/2012

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