Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy

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Strategic Environmental Assessment for the

Luton Local Flood Risk Management Strategy

Environmental Report

Client: Luton Borough Council

Report No.: UE-0161 SEA- Luton LFRMS ER_3_150805 Version: 3 Status: Final Date: August 2015 Author: SP/NP Checked: SP Approved: NP

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List of Tables and Figures

Table 2.1: SEA stages and those addressed in this report 5

Table 3.1: Strategic Environmental Assessment Objectives 11

Table 3.2: Assessment of compatibility between LFRMS and SEA Objectives 11

Table 4.1: Cumulative, synergistic and indirect effects 30

Table 5.1: Proposed monitoring framework 31

Figure 1.1: Five guiding principles of the UK Sustainable Development Strategy, Securing the Future

(2005) 4

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Abbreviations

ALC Agricultural Land Classification AONB Area of Outstanding Natural Beauty BMV Best and Most Versatile

CDA Critical Drainage Area CWS County Wildlife Site

DAM Detailed Assessment Matrix DWS District Wildlife Site

FAS Flood Alleviation Scheme HER Historic Environment Record HLA High Level Assessment

LFRMS Local Flood Risk Management Strategy LLFA Lead Local Flood Authority

LNR Local Nature Reserve

SAM Scheduled Ancient Monument SEA Strategic Environmental Assessment SSSI Site of Special Scientific Interest SuDS Sustainable Drainage Systems

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0 Non-Technical Summary

0.1 About Strategic Environmental Assessment

0.1.1 A Strategic Environmental Assessment (SEA) is being carried out alongside the preparation of the Luton Local Flood Risk Management Strategy (LFRMS).

0.1.2 Plan-making bodies use SEA to assess strategy documents against a set of environmental objectives developed in consultation with local stakeholders and communities. This assessment helps the plan-makers to identify the relative environmental performance of proposed Objectives, Policies and Actions, and to evaluate which of these may be more sustainable. 0.1.3 SEA is a statutory process incorporating the requirements of the European Union Strategic

Environmental Assessment Directive.

0.2 About the Luton Local Flood Risk Management Strategy

0.2.1 Luton Borough Council is a Lead Local Flood Authority and therefore has a duty to produce, maintain, implement and monitor a Local Flood Risk Management Strategy for its area. The Luton LFRMS will:

 Ensure a clear understanding of the risks of flooding locally, so that investment in risk management can be prioritised more effectively;

 Set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of the remaining risk;  Manage flood risks in an appropriate way, taking account of the needs of communities

and the environment;

 Ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond effectively to flood forecasts, warnings and advice; and  Help communities to recover more quickly and effectively after incidents.

0.3 Purpose and Content of the Environmental Report 0.3.1 The purpose of this Environmental Report is to:

 Identify, describe and evaluate the likely significant effects of the LFRMS and its reasonable alternatives; and

 Provide an early and effective opportunity for statutory consultees, interested parties and the public to offer views on any aspect of the SEA process which has been carried out to date.

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0.3.2 The Environmental Report contains:

 An outline of the contents and main objectives of the LFRMS and its relationship with other plans, programmes and strategies;

 Relevant aspects of the current state of the environment and key sustainability issues for the borough;

 The SEA Framework of objectives and decision-making criteria against which the LFRMS has been assessed;

 The appraisal of alternative options for the LFRMS;  The likely significant environmental effects of the LFRMS;

 The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects which may arise as a result of the LFRMS;

 A description of the measures envisaged concerning monitoring; and  The next steps for the SEA.

0.4 The SEA Scoping Stage

0.4.1 The Scoping Report was published for consultation between 26 November 2014 and 14 January 2015. It set out the intended scope and level of detail to be included in the SEA and included a plan, programme and strategy review, an evidence base for the assessment, key issues and environmental challenges to address, and an SEA Framework of objectives against which the LFRMS can be assessed.

0.4.2 The SEA Framework is comprised of six SEA Objectives, listed below, which were developed for use in the appraisal.

# SEA Objective Relationship to SEA Directive

1 To conserve and enhance biodiversity Biodiversity, flora and fauna 2 To promote adaptation to climate change Climatic factors; Material assets;

Population; Human health 3 To conserve and enhance the historic environment, heritage

assets and their settings

Landscape; Historic environment 4 To conserve and enhance the character of the landscape Landscape; Historic

environment 5 To protect water resources and minimise water pollution Water 6 To conserve and manage natural resources (land, minerals,

agricultural land, materials)

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0.4.3 Following consultation the information presented in the Scoping Report was updated to take account of the responses received. The revised scoping information is included in this Environmental Report.

0.5 Assessment of Reasonable Alternatives

0.5.1 The purpose and content of the LFRMS is clearly defined by law which means that there is limited scope for the consideration of markedly different alternatives. However, at points during the development of the LFRMS certain decisions were made for which alternatives were available.

0.5.2 Following the conclusion of the scoping stage, the SEA team contributed to the development of options work carried out for the LFRMS via the High Level Assessment. The purpose of this interaction between the SEA and the LFRMS was to inform and influence the strategy’s development and to provide an early and effective environmental input, and included suggestions for additional reasonable alternatives which could be considered alongside the Policies and Actions proposed for inclusion in the LFRMS. These can be summarised as:

 Policy 1: Thresholds for flood investigations;

 Alternative 1a: Set lower thresholds for initiating formal flood investigations (e.g. 5 or more adjacent dwellings and/or 1 or more business premises);

 CDA 1a: High priority Critical Drainage Areas (CDA) are high risk and have synergy with other projects; medium priority are those with <£25,000 cost per property mitigated; all others are low;

 CDA 1b: Alternative - Different approach to prioritisation of CDAs (e.g. medium priority are those with <£30,000 cost per property mitigated; all others are low);

 Policy 2: Sand bags;

 Alternative 2a: Supply sand bags to selected groups of residents in chosen locations;  Action 6.1: Water efficiency (retrofitting); and

 Action 6.1a: Alternative - Water Efficiency (retrofitting) - higher target e.g. 60% of existing housing stock.

0.5.3 Overall the High Level Assessment found the Luton LFRMS to be a broadly sustainable strategy with a wide range of positive effects and few negative environmental effects. However, a number of Flood Alleviation Scheme (FAS) proposals for certain Critical Drainage Areas were flagged as leading to uncertain or mixed environmental effects the nature of which would largely depend on their means of implementation. Further discussion with the Council confirmed that a secondary level of options generation had taken place for reducing flood risk in CDAs. These options do not strictly form part of the LFRMS as they are subject to funding and final scheme design, however, it was decided that they would form the most appropriate basis for detailed assessment.

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0.6 Detailed Assessment and Recommended Mitigation

0.6.1 Four CDA proposals were assessed in greater detail. A summary of assessment findings and recommendations for each CDA is presented below.

Barton Road / Great Bramingham High Priority CDA Summary of predicted environmental effects:

 Temporary loss of semi-natural habitats/species resulting from the route of the culvert and swales in Icknield Park. Minor temporary negative effects are predicted at a local scale over the short term.

 Temporary or permanent loss of protected habitats would result in minor to major negative effects at a local to national scale, and could also lead to impacts on protected species, depending on the location of flood storage bunds near Turnpike Drive and Burford Close.

 Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term, although creating swales in Icknield Park could adversely affect its use as a playing field, resulting in a functional loss of green infrastructure and minor indirect effects on human health.

 Earthworks required for the construction of swales or installation of a larger culvert could result in the disturbance or destruction of archaeological remains, resulting in permanent minor to moderate impacts at a local to regional scale.

 Loss of protected heritage features would result in major negative effects at a national scale depending on the location of flood storage bunds near Turnpike Drive and Burford Close.

 New permanent flood storage areas could result in minor to moderate negative effects on a nationally important protected landscape over the long term.

 Short term minor negative impacts to water quality during construction are predicted at a local scale due to introduction of sediments to the water course.

 Permanent loss of agricultural land would result in minor to moderate negative effects at a local scale over the long term, depending on the location of flood storage bunds near Turnpike Drive and Burford Close.

Summary of recommended mitigation:

 Loss of protected habitats should be avoided or minimised through site selection, layout and design. Impacts to habitats and species may be avoidable through final scheme design, or otherwise mitigated. Ecological surveys and assessment will be required to establish which (if any) protected species may be using the site and to design a suitable mitigation strategy. Habitats of greatest interest should be retained where possible.

 Functional loss of playing fields would need to be replaced on a like-for-like basis to ensure community accessibility to these facilities is maintained.

 Loss of protected heritage features should be avoided or minimised through site selection, layout and design, while measures should be taken to protect the setting of these features. Heritage Statements should be prepared and, where evidence points to potential presence of remains, mitigation will be required.

 It should be possible to reduce negative landscape effects via a high quality design which responds to landscape constraints and uses an appropriate selection of materials.

 Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction.

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 Mitigation for the loss of agricultural land is not feasible, however, losses should be avoided or minimised through site selection, layout and design, while measures should be taken to ensure that good quality top soil is either re-used on site or put to productive use off site.

Chapel Street / Arndale Centre High Priority CDA Summary of predicted environmental effects:

 Temporary loss of semi-natural habitats/species resulting from the route of the new drainage pipe from George Street to Manor Road Park. Minor temporary negative effects are predicted at a local scale over the short term.

 Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term, although the new pipe could also increase the extent and depth of flooding at Manor Road Park.

 Engineering works could negatively affect the character of the Town Centre and Luton South Conservation Areas), resulting in temporary minor impacts at a local scale.

 Short term minor negative impacts to water quality during construction are predicted at a local scale due to introduction of sediments to the water course.

Summary of recommended mitigation:

 Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction. Barnfield West Academy / Poynters Road High Priority CDA

Summary of predicted environmental effects:  No strategically significant effects predicted. Summary of recommended mitigation:

 No mitigation required at the strategic level, however, further investigations (e.g. ecological survey) may be necessary at the detailed project proposal stage.

Vauxhall Way High Priority CDA

Summary of predicted environmental effects:

 Minor temporary negative effects are predicted at a local scale over the short term resulting from a temporary loss of semi-natural habitats/species, depending on the route of the proposed thrust pipe or open cut, and design and location of flood storage areas between Eaton Valley Road and Vauxhall Way and to the east of Parkway Road.

 Minor positive effects are predicted at a local scale as a result of the reduction in flood risk over the long term.

 Minor to moderate negative effects to a nationally important heritage feature are possible over the long term depending on the location, route and design of engineering works.

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scale due to introduction of sediments to the water course. Summary of recommended mitigation:

 Standard site procedures as recommended by the Environment Agency will be required to ensure that no contaminants or effluent are released into aquatic environments during construction.

0.7 Monitoring

0.7.1 Chapter 5 of the Environmental Report contains proposals for a monitoring programme to measure the significant environmental effects of implementing the Luton LFRMS. Monitoring for the SEA will be aligned with or incorporated within monitoring that is scheduled for the LFRMS itself, both to avoid duplication and ensure that appropriate remedial action can be taken.

0.8 Next Steps

0.8.1 The LFRMS and its SEA will be published for a period of representations. Comments received on both documents will be considered by the Council prior to finalising and adopting the strategy. Any significant changes to the strategy which arise as a result of consultation will need to be assessed as part of the SEA process, which may lead to a further edition of, or addendum to the Environmental Report.

0.8.2 An Environmental Statement will be published with the adopted LFRMS. The purpose of the Environmental Statement is to outline how the SEA process has informed and influenced the planning process and demonstrate how consultation on the SEA was taken into account.

0.8.3 This Environmental Report is available online or in hard copy to view at the following addresses:

www.luton.gov.uk/floodriskmanagement

Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ

0.8.4 The consultation period runs from 10 August to 7 September 2015. Responses should be submitted via the Luton Borough Council consultation portal or to the following addresses: Email: flooding@luton.gov.uk

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1 Introduction

1.1 Purpose of this Report

1.1.1 This Environmental Report has been prepared for Luton Borough Council as part of the Strategic Environmental Assessment (SEA) for the Luton Local Flood Risk Management Strategy (LFRMS).

1.1.2 The Environmental Report has been produced in compliance with the Environmental Assessment of Plans and Programmes Regulations 2004. It incorporates the information which is required in accordance with EU Directive 2001/42/EC on Environmental Assessment of Plans and Programmes (the SEA Directive). The report represents the latest stage in the SEA and forms part of the evidence base upon which the LFRMS is based.

1.2 The Luton Local Flood Risk Management Strategy

1.2.1 Luton Borough Council is a Lead Local Flood Authority (LLFA) under the Flood Risk Regulations (2009) and the Flood and Water Management Act (2010). The legislation created a duty for LLFAs to produce, maintain, implement and monitor Local Flood Risk Management Strategies for their area. The LFRMS must be consistent with the Environment Agency’s National Flood Risk Management Strategy.

1.2.2 The Luton LFRMS will:

 Ensure a clear understanding of the risks of flooding locally, so that investment in risk management can be prioritised more effectively;

 Set out clear and consistent plans for risk management so that communities and businesses can make informed decisions about the management of the remaining risk;  Manage flood risks in an appropriate way, taking account of the needs of communities

and the environment;

 Ensure that emergency plans and responses to flood incidents are effective and that communities are able to respond effectively to flood forecasts, warnings and advice; and  Help communities to recover more quickly and effectively after incidents.

1.2.3 Box 1 sets out the key facts relating to the Luton Local Flood Risk Management Strategy.

1.3 The Study Area

1.3.1 Luton is a densely populated town with a rich cultural diversity. Surrounded by Green Belt and situated within the Chilterns Area of Outstanding Natural Beauty, the town benefits from easy access to high quality landscapes, wildlife areas, parks and other sub-regional leisure

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attractions, such as Luton Hoo, Dunstable Downs, and Woburn Abbey. At the same time the town benefits from good strategic north-south access to the midlands and to Greater London via the M1 and Midland Mainline Railway. It is also served by London Luton Airport which is growing and plays an important role in the economy of the town.

Box 1: Key facts about the Luton Local Flood Risk Management Strategy Name of Responsible Authority: Luton Borough Council.

Title of plan: _{Luton Local Flood Risk Management Strategy.} What prompted the plan

(e.g. legislative, regulatory or administrative provision):

The Council has a statutory duty as Lead Local Flood Authority to prepare an LFRMS under the Flood Risk Regulations (2009) and the Flood and Water Management Act (2010).

Subject (e.g. transport): _{Flood risk management strategy.} Period covered: _{2015 to 2018.}

Frequency of updates: _{Action Plan reviewed annually.} Area covered: _{The Borough of Luton.}

Purpose and scope of the

plan: See paragraph 1.2.2.

Contact point: Flood Risk Management, Luton Borough Council, Town Hall, George Street, Luton LU1 2BQ. Tel: 01582 547371; Email: flooding@luton.gov.uk

1.3.2 Despite the underlying permeable geology, Luton has a history of surface water flooding. This is due to rapid development of the town without corresponding upgrade of the local surface water drains. Also, the River Lea and its tributaries in Luton, Houghton Brook, Lewsey Brook, Cat Brook and Riddy Brook, are partially fed by surface water drains and hence have developed flashy responses during heavy rainfall events. Infrastructure and properties within the River Lea corridor are also at risk from groundwater flooding, especially downstream of the town centre. A small area in the most north-eastern part of the borough is at risk of flooding in case of the Sundon reservoir failure.

1.3.3 Flood mitigation works have been carried out across many locations in the borough, including upgrades to and redevelopments of the highway drains, culvert repairs, improving conveyance of the natural channels and removal of silt. However, extensive infill development in the town centre and projected changes to rainfall could add to pressure on the sewer network and watercourses in the Luton catchment.

1.4 Sustainable Development

1.4.1 The UK’s sustainable development agenda is shaped by the Sustainable Development Strategy, Securing the Future (2005) and in planning terms by the National Planning Policy Framework (NPPF), which replaced previous national planning policy (Planning Policy Statements and Planning Policy Guidance notes) in March 2012. The NPPF includes a presumption in favour of sustainable development, which it goes on to interpret in a planning context with reference to the Sustainable Development Strategy.

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The UK Sustainable Development Strategy

1.4.2 Securing the Future (2005) suggests that for a policy to be sustainable, it must respect all five of the principles set out in Figure 1.1. The strategy also recognises that some policies, while underpinned by all five principles, will place more emphasis on certain principles than others. The strategy states that “we want to achieve our goals of living within environmental limits and a just society, and we will do it by means of a sustainable economy, good governance, and sound science” (Securing the Future, 2005).

1.4.3 The strategy states that the five guiding principles are promoted through four shared priorities: “Sustainable Consumption and Production – Sustainable consumption and production is about achieving more with less. This means not only looking at how goods and services are produced, but also the impacts of products and materials across their whole lifecycle and building on people’s awareness of social and environmental concerns. This includes reducing the inefficient use of resources which are a drag on the economy, so helping boost business competitiveness and to break the link between economic growth and environmental degradation.

“Climate Change and Energy – The effects of a changing climate can already be seen. Temperatures and sea levels are rising, ice and snow cover are declining, and the consequences could be catastrophic for the natural world and society. Scientific evidence points to the release of greenhouse gases, such as carbon dioxide and methane, into the atmosphere by human activity as the primary cause of climatic change. We will seek to secure a profound change in the way we generate and use energy, and in other activities that release these gases. At the same time we must prepare for the climate change that cannot now be avoided. We must set a good example and will encourage others to follow it.

“Natural Resource Protection and Environmental Enhancement – Natural resources are vital to our existence and that of communities throughout the world. We need a better understanding of environmental limits, environmental enhancement and recovery where the environment is most degraded to ensure a decent environment for everyone, and a more integrated policy framework.

“Sustainable Communities – Our aim is to create sustainable communities that embody the principles of sustainable development at the local level. This will involve working to give communities more power in the decisions that affect them and working in partnership at the right level to get things done. The UK uses the same principles of engagement, partnership, and programmes of aid in order to tackle poverty and environmental degradation and to ensure good governance in overseas communities. These priorities for action within the UK will also help to shape the way the UK works internationally, in ensuring that our objectives and activities are aligned with international goals.”

1.4.4 The SEA for the LFRMS will incorporate these key principles at the heart of the assessment process.

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Figure 1.1: Five guiding principles of the UK Sustainable Development Strategy, Securing the Future (2005)

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2 Methodology

2.1 Strategic Environmental Assessment

2.1.1 Strategic Environmental Assessment is a systematic process for evaluating the environmental consequences of proposed plans or programmes to ensure environmental issues are fully integrated and addressed at the earliest appropriate stage of decision making. SEA was introduced to the UK through the EU Directive 2001/42/EC. In England this Directive has been transposed via the Environmental Assessment of Plans and Programmes Regulations 2004. The Luton LFRMS has been screened as a plan or programme which is likely to have significant environmental effects and which is being prepared for water management; it therefore requires an SEA under the Directive.

2.1.2 The SEA is based upon the following principles:

 SEA Objectives are used for appraising the potential impacts of objectives, policies and actions proposed for inclusion in the LFRMS, on the various environmental receptors;  Baseline and spatial environmental information is collected and collated. Predicted

effects of policies and proposals are evaluated against the baseline and likely evolution thereof in the absence of the strategy;

 Alternative options and preferred options for the strategy are appraised using an SEA Framework , combined with careful consideration of baseline conditions; and

 Decision-making criteria are devised for all SEA Objectives to assist in monitoring delivery of the plan and any significant effects thereof.

2.2 Assessment Stages

2.2.1 Table 2.1 provides a summary of the procedural steps for the assessment, based on both the National Planning Practice Guidance (DCLG, 2014) and A Practical Guide to the SEA Directive (ODPM, 2005a). The steps shaded in green are the stages addressed in this report. The second column indicates where information about each respective stage can be found (see also Appendix A).

Table 2.1: SEA stages and those addressed in this report

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

Location in this report

1.Identify other relevant policies, plans, programmes, & sustainability objectives Section 3.3

2.Collect baseline information Section 3.4

3.Identify environmental issues and challenges Section 3.4

4.Develop the Strategic Environmental Assessment Framework Section 3.5

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Stage B: Developing and refining alternatives and assessing effects

1.Test the Plan objectives against the SEA Framework Section 3.6

2.Develop the Plan options including reasonable alternatives Chapter 4 3.Evaluate the likely effects of the Plan and alternatives Chapter 4 4.Consider ways of mitigating adverse, and maximising beneficial effects Chapter 5 5.Propose measures to monitor the significant effects of implementing the Plan Chapter 5 Stage C: Prepare the Environmental Report

Including all requirements of the SEA Directive Whole Document

Stage D: Publish & consult on the Environmental Report & Plan 1.Consult the consultation bodies and public on the draft Plan and

Environmental Report

Chapter 6 2.Appraise significant changes resulting from representations, and amend the

Plan

n/a Stage E: Post-adoption reporting and monitoring

1.Prepare and publish the post-adoption Environmental Statement n/a

2.Monitor SEA indicators during Plan implementation n/a

3.Respond to adverse effects n/a

2.3 Approach to Assessing Significant Effects

2.3.1 The proposed Objectives, Policies and Actions to be considered for inclusion in the LFRMS are assessed against the baseline and SEA Framework using a three-stage process. An important aspect of this process is selecting the preferred options from a range of reasonable alternatives, and justifying these decisions in light of assessment conclusions.

High level assessments

2.3.2 The appraisal of options engages a strategic High Level Assessment (HLA) technique which uses the SEA Framework to evaluate the likely environmental performance of each option. The SEA Framework was developed through the scoping process (see Chapter 3) and consists of six SEA Objectives with corresponding ‘decision-making criteria’, which are derived from the review of plans, programmes and policies and baseline data.

2.3.3 For each option, with reference to onsite or nearby environmental constraints where relevant, the impact of the proposal on the SEA Objectives is assessed (from Strong Positive, Positive or Neutral, to Negative, Strong Negative or Mixed/Uncertain). The main function of the high level assessment is to identify whether or not the proposals are likely to bring positive, negative or uncertain effects in relation to the SEA Objectives. A benefit of this approach is that a range of options may be assessed, which can then be scrutinised in further detail if a significant number of uncertainties or potential negative effects arise.

2.3.4 Within this SEA, options which are taken forward for detailed assessment are those which are appraised as having greater negative than positive effects overall, or those with one or more

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strong negative impacts on at least one SEA Objective, or those which are likely to significantly affect sites designated pursuant to the Habitats1_{or Birds Directives}2_{(i.e. European sites).}

Detailed assessments

2.3.5 Where potential negative effects or uncertainties are identified through the high level assessment in association with a particular option, a secondary level of assessment takes place to examine the proposal in more detail. At the scoping stage it was envisaged that this stage would use Detailed Assessment Matrices to address the range of criteria identified in Annex II of the SEA Directive for determining the likely (positive or negative) significance of effects (Box 2). However, where physical changes are discussed within the LFRMS their precise location and extent is not certain, their delivery is subject to further design and funding, and often several options for implementation still remain.

2.3.6 As a result it was decided that the methodology should be adjusted to suit the level of detail available for assessment. The detailed assessments presented in Chapter 3 instead focus on known environmental constraints within and close to the areas proposed for flood mitigation work, before presenting an assessment against these constraints in the context of the SEA Framework. Where significant effects are predicted or uncertain, a range of mitigation measures is recommended.

Box 2: Criteria for the assessment of significant effects

Criteria for determining the likely significance of effects referred to in Article 3(5) of the SEA Directive The characteristics of plans and programmes, having regard, in particular, to

a. the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources;

b. the degree to which the plan or programme influences other plans and programmes including those in a hierarchy;

c. the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development;

d. environmental problems relevant to the plan or programme;

e. the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste management or water protection).

Characteristics of the effects and of the area likely to be affected, having regard, in particular, to a. the probability, duration, frequency and reversibility of the effects;

b. the cumulative nature of the effects; c. the trans boundary nature of the effects;

d. the risks to human health or the environment (e.g. due to accidents);

e. the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);

f. the value and vulnerability of the area likely to be affected due to: special natural characteristics or cultural heritage;

1_{European Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora} 2_{European Council Directive 2009/147/EC on the conservation of wild birds}

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exceeded environmental quality standards or limit values; intensive land-use;

the effects on areas or landscapes which have a recognised national, Community or international protection status.

Cumulative effects assessment

2.3.7 As required by the SEA Regulations, cumulative, synergistic and indirect effects are identified and evaluated during the assessment. An explanation of these is as follows:

 Indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway;

 Cumulative effects arise where several developments each have insignificant effects but together have a significant effect, or where several individual effects of the plan have a combined effect;

 Synergistic effects interact to produce a total effect greater than the sum of the individual effects.

2.4 Limitations to the Strategic Environmental Assessment

2.4.1 It is acknowledged that there are a number of limitations and difficulties surrounding the SEA process which stem largely from the nature of strategic assessment at the plan level, using secondary data. In many cases assessment has been undertaken for proposals which do not lead to physical changes on the ground (e.g. engineering works or flood risk mitigation) or without data on environmental limits. Where physical changes are discussed within the LFRMS their precise location and extent is not certain, and their delivery is subject to further design and funding. In these circumstances the appraisals have erred on the side of caution. To address these issues, monitoring proposals should seek to monitor the effects of the plan as it is implemented as well as addressing data gaps.

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3 Scoping

3.1 Scoping Report

3.1.1 The first phase of the SEA was the scoping stage. Scoping is the process of deciding the scope and level of detail of an SEA, including the environmental effects to be considered, the assessment methods to be used, and the structure and contents of the SEA Report. The purpose of the Scoping Report (UEEC, 2014) is to set the criteria for assessment (including the SEA objectives), and establish the baseline data and other information, including a review of relevant policies, programmes and plans.

3.1.2 The Scoping Report presents information in relation to the following tasks:

 Identifying other relevant policies, plans and programmes, and sustainability objectives;  Collecting baseline information;

 Identifying sustainability opportunities and challenges; and  Developing the SEA Framework.

3.2 Scoping Consultation

3.2.1 The Scoping Report was published for consultation between 26 November 2014 and 14 January 2015.

3.2.2 Responses were received from the three Consultation Bodies (English Heritage, Environment Agency and Natural England) and LBC Officers. Appendix B contains an analysis of scoping consultation responses including a description of how the comments have been taken into account. Following receipt of responses, the SEA information, including the baseline and policy and plan review, was updated. The updated SEA information is included in this Environmental Report.

3.3 Policy, Plan and Programme Review

3.3.1 The LFRMS may be influenced in various ways by other policies, plans or programmes (PPPs), or by external environmental objectives such as those put forward in other strategies or initiatives. The SEA process takes advantage of potential synergies between these PPPs and addresses any inconsistencies or constraints.

3.3.2 The Scoping Report presented an evaluation of the key PPPs that are likely to be relevant to the SEA process and LFRMS. Each PPP is discussed on the basis of how its objectives and environmental requirements affect, or are affected by, the LFRMS. The list was updated following scoping consultation and the revised PPP review can be viewed at Appendix C.

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3.4 Baseline Data and Key Environmental Issues

3.4.1 A key part of the scoping process is the collection of baseline data. The purpose of the exercise is to help identify key opportunities and challenges facing the area which might influence the LFRMS, and to provide an evidence base from which to make the assessment. The baseline sections in the Scoping Report review the social, economic and environmental conditions affecting the borough. One of the purposes of consultation on the Scoping Report was to seek views on whether the data selected was appropriate. Comments were received from a range of stakeholders and in some cases new sources of baseline information were provided or suggested.

3.4.2 The revised baseline data and its likely evolution in the absence of the LFRMS can be viewed at Appendix D, together with a summary of the key environmental issues facing the strategy.

3.5 The SEA Framework

3.5.1 The purpose of the SEA Framework is to provide a means of ensuring that the LFRMS considers the environmental effects of selecting and implementing strategic options. It enables the significant effects of the strategy to be consistently described, analysed and compared.

3.5.2 The SEA Framework consists of objectives which, where practicable, can be expressed in the form of targets, the achievement of which is measurable using indicators. There is no statutory basis for setting objectives but they are a recognised way of considering the environmental effects of a plan and comparing alternatives, and as such provide the basis from which effects of the plan can be tested. The SEA Objectives were derived through consideration of the PPP review, the baseline data collection, and the key sustainability issues identified for the borough. They seek to reflect each of these influences to ensure the assessment process is robust, balanced and comprehensive.

3.5.3 Annex I(f) of the SEA Directive (see Appendix A) contains a list of environmental receptors which require consideration, including biodiversity, flora and fauna, population, human health, soil, water, air, climatic factors, material assets, cultural heritage (including architectural and archaeological heritage), landscape and the inter-relationship between these factors. However, not all of these receptors are likely to be significantly affected by the LFRMS, and some were thus scoped out of the SEA at the scoping stage (see Chapter 3 of the Scoping Report). 3.5.4 Following the receipt of consultation responses on the Scoping Report, the SEA Framework was

updated to address the comments received. The updated SEA Framework is presented at Appendix E while Table 3.1 lists the SEA Objectives and their relationship to the SEA Directive requirements.

3.6 Assessing the LFRMS Objectives against the SEA Framework

3.6.1 Table 3.2 presents a compatibility appraisal of the LFRMS objectives against the SEA objectives. The assessment shows that the strategy objectives broadly support the full range of SEA objectives and that there is a good degree of compatibility (or neutrality) between the two sets

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of objectives. Some potential for conflict exists between the strategy objective for Flood Risk Mitigation, and SEA objectives which seek protection for Biodiversity, Landscape and Cultural Heritage, but these largely depend on the how the objective would be implemented by Policies and Actions within the LFRMS.

Table 3.1: Strategic Environmental Assessment Objectives

# SEA Objective Relationship to SEA Directive

1 To conserve and enhance biodiversity Biodiversity, flora and fauna 2 To promote adaptation to climate change Climatic factors; Material assets;

Population; Human health 3 To conserve and enhance the historic environment, heritage

assets and their settings

Landscape; Historic environment 4 To conserve and enhance the character of the landscape Landscape; Historic

environment 5 To protect water resources and minimise water pollution Water 6 To conserve and manage natural resources (land, minerals,

agricultural land, materials)

Material assets; Soil

Table 3.2: Assessment of compatibility between LFRMS and SEA Objectives

SEA1 SEA2 SEA3 SEA4 SEA5 SEA6

No LFRMS Objective

1 Improve the Understanding of Flood Risk in Luton 0 P 0 0 0 0

2 Flood Risk in Planning and Development Control P P P P P P

3 Emergency Planning, Response and Resilience 0 P 0 0 0 0

4 Flood Risk Mitigation ? P ? ? P P

5 Partnership Working 0 P 0 0 0 0

6 Wider Environmental Benefits P 0 0 P P 0

7 Economics 0 P 0 0 0 0

SEA1 SEA2 SEA3 SEA4 SEA5 SEA6

Key to the Compatibility Assessment Matrix

P Compatible

? Potentially incompatible

O

Incompatible

0 No link

Luton Local Flood Risk Management Plan

Objectives Compatibility Assessment

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4 Assessing Reasonable Alternatives

4.1 Responding to the Requirements of the SEA Directive

4.1.1 The SEA Directive requires that the Environmental Report should consider:

‘Reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme’ and give ‘an outline of the reasons for selecting the alternatives dealt with’ (Article 5.1 and Annex I (h)).

4.1.2 The purpose and content of the LFRMS is clearly defined by the 2009 Regulations and 2010 Act which means that there is limited scope for the consideration of markedly different alternatives. However, at points during the development of the LFRMS certain decisions were made for which alternatives were available.

4.1.3 Following the conclusion of the scoping stage, the SEA team contributed to the development of options work carried out for the LFRMS via the High Level Assessment. The purpose of this interaction between the SEA and the LFRMS was to inform and influence the strategy’s development and to provide an early and effective environmental input, and included suggestions for additional reasonable alternatives which could be considered alongside the Policies and Actions proposed for inclusion in the LFRMS. These can be summarised as:

 Policy 1: Thresholds for flood investigations;

 Alternative 1a: Set lower thresholds for initiating formal flood investigations (e.g. 5 or more adjacent dwellings and/or 1 or more business premises);

 CDA 1a: High priority Critical Drainage Areas (CDA) are high risk and have synergy with other projects; medium priority are those with <£25,000 cost per property mitigated; all others are low;

 CDA 1b: Alternative - Different approach to prioritisation of CDAs (e.g. medium priority are those with <£30,000 cost per property mitigated; all others are low);

 Policy 2: Sand bags;

 Alternative 2a: Supply sand bags to selected groups of residents in chosen locations;  Action 6.1: Water efficiency (retrofitting); and

 Action 6.1a: Alternative - Water Efficiency (retrofitting) - higher target e.g. 60% of existing housing stock.

4.1.4 Checks were made during the High Level Assessment to ensure that the preferred alternative does not lead to significant negative effects on the SEA objectives. The findings of the High Level Assessment, which are described in detail in section 4.2 below, concluded that none of the proposed Objectives, Policies or Actions were predicted to result in (a) greater negative than positive effects overall, (b) one or more strong negative impacts on at least one SEA

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Objective, or (c) likely significantly effects on European sites. As result, none required detailed further assessment.

4.1.5 However, a number of Flood Alleviation Scheme (FAS) proposals for certain Critical Drainage Areas were flagged as leading to uncertain or mixed environmental effects the nature of which would largely depend on their means of implementation. Further discussion with the Council confirmed that a secondary level of options generation had taken place for reducing flood risk in CDAs. These options do not strictly form part of the LFRMS as they are subject to funding and final scheme design, however, it was decided that they would form the most appropriate basis for detailed assessment at the current stage.

4.2 High Level Assessment

4.2.1 The findings of the HLA are summarised in matrix format which illustrates the impact of each proposal on each of the SEA Objectives and can be viewed at Appendix F. This is accompanied below by a commentary discussing and comparing the options’ environmental performance in relation to the SEA Objectives. The commentary is structured according to each of the LFRMS Objectives under which Policies and Actions are proposed.

LFRMS Objective 1: Improve the Understanding of Flood Risk in Luton

4.2.2 This objective has few direct links with the SEA Objectives, as illustrated at Table 3.2. However, it is compatible with SEA Objective 2 (To promote adaptation to climate change).

4.2.3 One Policy is proposed under the objective, which sets thresholds for the circumstances under which a formal investigation of a flooding incident would be initiated by the Council as LLFA. The thresholds are based on flood characteristics and significance criteria which strike an appropriate balance between recording and investigating the causes and consequences of flooding, and the cost and resources required to undertake an investigation. The thresholds address human health, economic activity and environment (although there is no direct reference to biodiversity) and so are predicted to positively affect SEA Objectives 2 to 6, as is its corresponding Action in the Action Plan.

4.2.4 Two alternatives to this proposed Policy were considered: to set higher thresholds which would result in fewer formal investigations, or to set lower thresholds which would result in a greater quantity of information being collected on the causes and consequences of flooding. Setting higher thresholds was rejected as not being a reasonable alternative because the preferred thresholds are already higher than national thresholds. The preferred thresholds are considered by the Council to be justified because of the densely populated nature of Luton which means that a given flooding event typically results in a greater number of properties being affected than would be the case in a less densely populated area experiencing the same volume of rainfall.

4.2.5 Setting lower thresholds is predicted to lead to greater positive effects on SEA Objectives 2 to 6 than the Policy as proposed, because formal investigations would be initiated more frequently. However, the cost of undertaking formal investigations is not insignificant and may not be the best use of limited resources. The Council may still investigate flooding below the

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preferred thresholds, but would do so at the Council’s discretion, not necessarily following the prescribed process under the legislation.

4.2.6 Although not specifically encapsulated in its Policy or Action Plan, this section of the LFRMS also considers how to prioritise implementation of flood risk solutions in Critical Drainage Areas (CDA). High priority CDAs are based on overall verified risk and potential synergy with other projects, using sound engineering judgement, as recommended by the Surface Water Management Plan3_{. Medium priority CDAs are those with a cost per property mitigated of less}

than £25,000, with all other CDAs being low priority. This is considered to be a reasonable approach to prioritisation based on risk and evidence which seeks to achieve an acceptable balance between costs and benefits, and predicted to positively affect all six of the SEA Objectives.

4.2.7 However, it was also considered reasonable to exame an alternative approach to prioritisation whereby medium priority CDAs would be all those with a cost per property mitigated of less than £30,000. This would have the effect of promoting the three CDAs which are currently proposed to be low priority to medium priority and result in flood risk solutions being developed to protect a further 50 dwellings at risk from a 0.5m flood depth under the 1in100yr rainfall event. This is predicted to have greater positive effects on SEA Objectives 1 to 6 in comparison to the currently proposed approach to prioritisation, however, there would clearly be a significant cost in selecting this as the preferred approach.

4.2.8 Fourteen Actions are proposed under LFRMS Objective 1 within the Action Plan, all of which are predicted to positively affect SEA Objective 2 (climate change adaptation). The majority of Actions are predicted to be neutral with regard to the other SEA Objectives. However, to “Produce riparian advice/guidance” is predicted to positively affect SEA1 (biodiversity), SEA3 (heritage), SEA5 (water quality) and SEA6 (natural resources). Similarly “Groundwater study/investigation” is predicted to positively affect SEA3, SEA5 and SEA6.

LFRMS Objective 2: Flood Risk in Planning and Development Control

4.2.9 This objective is assessed as broadly compatible with all the SEA Objectives. Similarly, each of its nine Actions is predicted to result in positive or neutral effects on the SEA Objectives. “Floodplain protection” is predicted to positively affect SEA1 (biodiversity), SEA3 (heritage), SEA4 (landscape), SEA5 (water quality) and SEA6 (land and natural resources) by promoting the restoration of natural river forms and floodplains as areas of biodiversity and improved amenity value. “Development and flood risk” is assessed in a similar light because it seeks to prevent development in areas of high flood risk, recreate river corridors in urban areas and provide space for water, wildlife and recreation.

4.2.10 “Assessment of Sustainable Drainage Systems (SuDS) applications” and “SuDS retrofitting for reducing runoff” are expected to result in positive effects for biodiversity (SEA3) and landscape because they often include areas of wetland habitat and semi-natural vegetation with amenity

3_{Capita Symonds (2012): Luton Surface Water Management Plan – Final Draft [Updated September 2013]. Accessed online at}

[October 2014]: http://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Luton%20SWMP%20-%20Final%20Draft%20-%20V1%207.pdf

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value (SEA4), and can improve water quality (SEA5) by removing pollutants. All of the Actions under this objective are predicted have positive or strong positive effects on SEA2 (climate change adaptation).

4.2.11 The safeguarding of land from development in the Upper Lea Catchment near Lewsey Farm, Houghton Brook and Limbury is considered to have strong positive effects because of the presence of environmental assets in these areas, including River Lea County Wildlife Site (CWS), Leagrave Common CWS, River Lea District Wildlife Site (DWS), Lewsey Park DWS, Waulud’s Bank Scheduled Ancient Monument (SAM) and archaeological areas on the Historic Environment Record (HER15812, HER820 and HER115).

LFRMS Objective 3: Emergency Planning, Response and Resilience

4.2.12 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The two Actions proposed under this objective are assessed in a similar way because they focus on procedure and planning rather than on-the-ground activities. 4.2.13 One policy is proposed under this objective, which makes it clear that the Council does not

provide sand bags to the general public for use during flood events, instead using its limited supply to protect highways and public buildings. The policy is broadly neutral with respect to the SEA Objectives, with minor positive effects on SEA3 (heritage) because some public buildings are listed. An alternative approach could be to reverse this policy so that the Council does provide sand bags, or provides sand bags to selected groups of residents in chosen locations. This would lead to minor positive effects on SEA2 (climate change adaptation) but may not be an efficient use of resources and does not address the stated limitations of sand bags as a flood protection measure.

LFRMS Objective 4: Flood Risk Mitigation

4.2.14 This objective is compatible with SEA2 (climate change adaptation), SEA5 (water quality) and SEA6 (land and natural resources) but potentially incompatible with SEA1 (biodiversity), SEA3 (heritage) and SEA4 (landscape) depending on where and how mitigation is implemented. 4.2.15 In total, 40 Actions are proposed under this objective, the majority of which involve studies,

consultation and data gathering to investigate which solutions may be effective and acceptable, or inspection, maintenance and use of powers. Furthermore, while most of the Actions target flood risk mitigation in a broad area, they are not sufficiently spatially specific to enable assessment of potential environmental effects other than in the broadest terms. All of these Actions (Act4.7 to Act4.40 in Appendix F) are predicted to lead to at least minor positive effects on SEA2 (climate change adaptation), and a handful may also have beneficial effects on water quality (SEA5).

4.2.16 However, two Flood Alleviation Schemes (FAS) and projects proposed under the four high priority CDAs are further developed and can be assessed to a slightly finer level of detail at this stage. Each of these is predicted to have strong beneficial effects for climate change adaptation (SEA2) but mixed or uncertain effects on at least one other SEA Objective.

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4.2.17 The Houghton Regis FAS (Act4.1 in Appendix F) aims to reduce flood risk in the Upper Lea around Houghton Brook, Lewsey Brook and Limbury, and could involve construction of a flood storage area on the Houghton Brook between the M1 and Houghton Regis (see Figure 4.1, map reference 01). This is a greenfield site just outside of the borough boundary and currently in arable use (Agricultural Land Classification (ALC) Grade 2). The proposal could negatively affect an Iron Age or Roman settlement (HER15812) which underlies the western part of the site, depending on the final layout and design. It would also result in a loss of best and most versatile (BMV) agricultural land and could negatively affect landscape character, however, it is expected to deliver significant flood risk benefits to properties in parts of the Lewsey Farm, Parkside up to Marsh Farm and Limbury areas. No further details were available for appraisal and it is recommended that the scope for significant environmental effects is assessed at the project proposal stage.

4.2.18 The Icknield Way FAS (Act4.2, map reference 02) aims to utilise SuDS (e.g. swale and sewer upgrades) to alleviate surface water system surcharges at Icknield Way. The site is within the urban area but could negatively affect Limbury/Biscot Roman settlement (HER115), an extensive area of Roman occupation indicative of a large village, which underlies the southern part of the site, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals). No further details were available for appraisal and it is recommended that the scope for significant environmental effects is assessed at the project proposal stage.

4.2.19 Potential capital solutions in the Barton Road / Great Bramingham CDA (Act4.3) include flood storage areas to the north. Environmental constraints in the vicinity include Dray's Ditches SAM, the line of a route-way known as the Theedway (HER 10843) which may have prehistoric origins, the Chilterns Area of Outstanding Natural Beauty (AONB), Galley & Warden Hills Local Nature Reserve (LNR), and Grade 2 agricultural land. Consequently, the proposal could negatively affect biodiversity, heritage features, landscape character and BMV agricultural land, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals).

4.2.20 Potential capital solutions in the Chapel Street / Arndale Centre CDA (Act4.4) include installation of a new culvert from the corner of Chapel Street and George Street to Manor Road Park. Environmental constraints in the vicinity include Luton medieval town (HER16993), the Town Centre Conservation Area, and a number of listed buildings. Consequently, the proposal could negatively affect heritage features, depending on the final layout and design. However, positive effects would be expected for climate change adaptation and water quality (as a result of SuDS proposals).

4.2.21 Potential capital solutions in the Barnfield West Academy / Poynters Road CDA (Act4.5) include removal of silt from Lewsey Brook to restore flow capacity and provide in-bank flood storage. This could result in negative effects on the River Lea CWS, River Lea DWS, Lewsey Park DWS depending on the final extent and methods proposed; it could also result in long-term benefits to biodiversity and water quality if a sensitive river restoration design is adopted. Positive effects would be expected for climate change adaptation.

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4.2.22 Potential capital solutions in the Vauxhall Way CDA (Act4.6) include: flood storage areas along Vauxhall Way; increased conveyance from Airport Way underpass; and creation of a storage area or wetland in the vacant lot adjacent to Parkway Road and associated pipe work to route excess flow under Parkway Road and the A505 into the River Lea. Environmental constraints in the vicinity include The Chase CWS, Luton Hoo Park CWS, River Lea CWS, and Luton Parkway Verges DWS. Depending on the layout and final design proposals, the works could negatively affect any of these assets with consequent impacts on ecological receptors. However, certain parts of the proposal could result in long-term positive effects, including water quality improvements in the River Lea and creation of new wetland habitats. Positive effects would be expected for climate change adaptation.

LFRMS Objective 5: Partnership Working

4.2.23 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The three Actions proposed under this objective are assessed in a similar way because they focus on stakeholder engagement, cooperation, data sharing and partnership working, rather than on-the-ground activities which could result in environmental effects.

LFRMS Objective 6: Wider Environmental Benefits

4.2.24 This is the only objective that is not directly related to SEA2 (climate change adaptation), although it is compatible with SEA1 (biodiversity), SEA4 (landscape) and SEA5 (water quality). However, the Actions proposed under this objective are predicted to positively affect SEA2 (climate change adaptation) and SEA5 (water quality) because they promote water efficiency and SuDS retrofitting. Act6.3 has additional positive effects on biodiversity (SEA1), landscape (SEA4) and the sustainable use of land (SEA6) because it promotes the creation and enhancement of wetland habitats and green infrastructure.

4.2.25 One reasonable alternative was considered in relation to Act6.1 Water Efficiency (retrofitting) whereby a higher target could be set for the installation of easy-fit water saving devices, aiming for 60% of the existing housing stock instead of 20%. This is predicted to have greater positive effects on SEA2 and SEA5 by comparison but would also require a higher level of investment. Furthermore, as the Action Plan is to be reviewed on a regular basis there is nothing to prevent this target being aspired to over the longer term as the LFRMS is implemented.

LFRMS Objective 7: Economics

4.2.26 This objective has few direct links with the SEA Objectives, however, it is compatible with SEA2 (climate change adaptation). The six Actions proposed under this objective are assessed in a similar way because they focus on funding opportunities, partnership schemes and insurance, rather than on-the-ground activities which could result in environmental effects.

Conclusions

4.2.27 Overall the High Level Assessment has found the Luton LFRMS to be a broadly sustainable strategy with a wide range of positive effects and few negative environmental effects. Using the summary matrix from the HLA of the proposed Policies and Actions, the options with the most

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adverse impact(s) on the SEA Objectives can be identified. These options are summarised below:

 Action 4.1: Capital Improvement Project – Houghton Regis Flood Alleviation Scheme  Action 4.2: Capital Improvement Project – Icknield Way Flood Alleviation Scheme  Action 4.3: Capital Improvement Project – Barton Road / Great Bramingham High

Priority CDA (BRGB) Flood Alleviation Scheme

 Action 4.4: Capital Improvement Project – Chapel Street / Arndale Centre High Priority CDA (CHAST) Flood Alleviation Scheme

 Action 4.5: Capital Improvement Project – Barnfield West Academy / Poynters Road High Priority CDA (BWPR) Flood Alleviation Scheme

 Action 4.6: Capital Improvement Project – Vauxhall Way High Priority CDA (VAUX) Flood Alleviation Scheme

4.2.28 Whilst none of these Capital Improvement Projects meet the criteria for further assessment set out in paragraph 2.3.4, a further stage of options generation has taken place for Actions 4.3 to 4.6 and these are taken forward for detailed assessment.

4.3 Detailed Assessment

4.3.1 The following sections present a detailed assessment of the likely significant effects of currently preferred options for the four Capital Improvement Projects (BRGB, CHAST, BWPR, VAUX).

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Action 4.3: Capital Improvement Project – Barton Road / Great Bramingham High Priority CDA (BRGB) Flood Alleviation Scheme

Environmental Constraints Data

Environmental constraints within the area:

 13 national priority habitats which include deciduous woodland, lowland calcareous grassland and lowland fens.

 Two archaeological sites: Dray's Ditches SAM, the line of a route-way known as the Theedway (HER 10843) which may have prehistoric origins.  Little Bramingham Farmhouse is a listed building.

 There are 29 greenspace areas which include 26 amenity greenspaces and three natural and semi-natural greenspace.  Four areas marked as fluvial flood zone 3.

 One CWS; Bramingham Woods.

 Two DWS; Turnpike Drive and Whitehorse Vale. Environmental constraints within 250m:

 44 national priority habitats which include deciduous woodland, lowland calcareous grassland, lowland fens and lowland meadow.  Source protection zones 2 and 3.

 Agricultural land: Grade 2, Grade 3, Grade 4.

 5 archaeological sites, which include ‘Dray’s Ditches’ prehistoric boundary at Luton/Streatley and Roman settlement at Limbury/Biscot, Luton.  The one listed building is Little Bramingham Farmhouse.

 One ancient monument, which has been amended to include the eastern extent of Dray’s Ditches.

 There are 51 greenspace sites all of which are amenity greenspace, allotment and leisure gardens or natural and semi-natural greenspaces.  Chilterns ANOB.

 Greenbelt.

 22 areas marked as fluvial flood zone 2, and 9 areas marked as fluvial flood zone 3.  One Site of Special Scientific Interest (SSSI) at Galley and Warden Hills.

 One LNR at the Galley and Warden Hills SSSI.  There are 11 CWS.

Strategic Environmental Assessment for the Luton Local Flood Risk Management Strategy