Flood risk activity risk assessment for your environmental permits
Check if you need to do a risk assessment, how to do a risk assessment, and how the Environment Agency can help you.
Read this guide to find out:
- when you do or don’t need to do a risk assessment(s)
- how to complete a risk assessment
- where you can find information about environmental, flood and land drainage risks
- how the Environment Agency can help you
Generic risk assessment for standard rules permits
You don’t need to do your own risk assessment if you’re applying for a standard rules permit and can meet all the requirements.
The Environment Agency has done generic risk assessments for all standard rules. These list the potential risks and how to manage them. You need to check the generic risk assessment for the standard rule set you want to apply for so you understand the potential risks and can manage them effectively.
You will also need to show how you are managing risks through your management system.
Risk assessments for bespoke permits
You must do a risk assessment if you want to apply for or change (vary) a bespoke permit. You must demonstrate that your proposal will not:
- increase flood risk
- impact on drainage
- harm the environment
Your risk assessment must show that you have considered all the risks from your activity and have either:
- changed the way you carry out your activity so that it doesn’t cause any adverse effects
- put plans in place to reduce the risks
The Environment Agency may refuse your application if you have not done this, or if they consider the risks to be unacceptable.
If you’re applying for a bespoke permit but most of your activities are covered by a standard rules permit, you only need to assess the risks from the activities that aren’t covered by the relevant generic risk assessment. For example, if your activity meets all the conditions of the standard rules, but you are operating in a Site of Special Scientific Interest (SSSI) you only need to consider the risks to the SSSI in your risk assessment. Contact the Environment Agency if this situation applies to you.
If your proposal requires detailed modelling or a complex assessment you may prefer to find a consultant to do it for you. They will charge for their services. The Environment Agency will not do your risk assessment for you.
If you don’t think there are significant risks, you need to state why in your permit application.
Your written risk assessment can be in any format but must include the:
- relevant plans
You also need to include a plan that is to scale, eg on an Ordnance Survey map. It must show:
- your site(s) and the location of each specific activity on the site(s)
- all receptors that could be affected by the works
Check with the Environment Agency to see if they have any specific requirements on how you should present your information and any supporting data.
You must also include a copy of your risk assessment in your management system.
If your application requires public consultation, your risk assessment will be part of that consultation. Your application will also be on the Environment Agency’s public register of permits granted. Anyone can request to see the public register - contact the Environment Agency to find out where your nearest office is.
How the Environment Agency can help you
You can ask the Environment Agency for pre-application advice before you commit to a project. They can help you identify what risks you need to address and what information you need to provide in your application.
How to do a risk assessment
Follow these steps to do a risk assessment.
- Identify the risks of carrying out your proposed activity (including during construction) at your proposed site.
- Identify the receptors that could be at risk, eg people, animals and property.
- Identify the possible pathways from the risks to the receptors.
- Assess the risks relevant to your proposed activity and check they are acceptable, or can be screened out.
- For risks you can’t screen out, state what you will do to control or mitigate them including when things do not go according to plan (this may include changing the design or location of your work).
- Submit your risk assessment as part of your permit application.
Identify the risks from your activity
In your risk assessment you must identify what risks could occur and what the impact could be on flood risk, land drainage or the environment.
When assessing the risks, you need to consider the whole environmental footprint of your works. Here are some examples of risks you may need to consider, but there may be others you also need to take into account.
Creating or worsening flood risk or impeding drainage
Your work could permanently or temporarily increase flood risk. This could be as a result of:
- impeding the flow of the river
- blocking or narrowing a river channel or flood plain
- storing excavated materials in a flood plain
- doing work to a flood defence that will temporarily render it ineffective
- blocking drainage routes or pipes
- making surfaces impermeable
- creating overland surface water runoff that affects another property
Disturbing or undermining the stability of a bank
This could be caused by:
- putting a structure through the bank or on the bank
- cutting into the bank
- placing heavy machinery or equipment on the bank
- driving machinery, riding animals, or allowing them to graze on the bank
- excavating into the bank for planting or installing structures
Damaging structural integrity or performance
There is a risk that your work could damage or undermine flood defence structures, river control works, land drainage works, sea defences or remote defences. This could be caused by:
- an outfall or temporarily redirected flow causing erosion or scour
- drilling through a defence
- the weight of machinery on a defence causing damage
Damaging habitats and species
There is a risk that your work could physically damage habitats and species or you could create changes in the natural environment that would result in the loss of habitats and species. Your works could affect fish movement or mortality or could damage fish spawning grounds. It could also affect the ability of mammals to migrate.
Damage could be caused by:
- sediment mobilisation causing damage to fish spawning grounds and other habitats, or increasing flood risk downstream
- deliberate or accidental discharge of polluting materials such as oil, silt, dust, litter, and construction debris
- spreading non native invasive species during works or by moving contaminated machinery and personal equipment (boots and hand tools) to a new site
- changes to habitats by reducing the size of or breaking the continuity of the green corridor provided by watercourses
- noise, vibration or light affecting species either during construction works or from the permanent installation of works
You must identify all the receptors that are at risk from your proposed activity before, during and after your work.
Which receptors are important can vary greatly depending on your location and proposed activity. Some examples of receptors include:
- homes, factories, businesses, schools, hospitals and other public buildings that might be at risk of flooding
- roads, footpaths, railways or other infrastructure like electricity substations
- flood defence structures, pumping stations and gauge weirs
- drain and sewer systems that could become blocked by your work
- protected environmental sites and species
- water resources including groundwater and public water supply
- water bodies including ponds, streams, rivers and lakes
Sources of information about receptors
- protected wetlands (Ramsar sites)
- Sites of Special Scientific Interest
- Special Protection Areas
- Special Areas of Conservation
- priority habitats and county wildlife sites
The ‘designations’ tab of the Magic map allows you to search for land with a statutory designation.
Other information sources you should check are:
Your local council, wildlife trust or local records centre can also provide information on sites or species of conservation importance.
To find out if you have historic or listed buildings or archaeological sites near your site, check with:
- your local planning authority
- the Institute of Historic Building Conservation
- the National Trust
- the county archaeologist at your county council
- Historic England
The Environment Agency has information that may help with your risk assessment, including:
- data on flood, land drainage and environmental receptors
- records of where flood defence structures, sea defences, remote defences or river control works are located
- records of where dredging or other maintenance has been carried out
Their records are not definitive - you will need to check if there are other works or structures near your site. You will also need to inspect the site and check whether neighbours have carried out any work.
If you are carrying out maintenance of a main river or flood defence where this has previously been done by the Environment Agency, you must familiarise yourself with the nature and extent of the work they have carried out.
Risk assessment for effects on water bodies
Carrying out some flood risk activities can affect the quality of water within a river as well as the physical habitat and ecology.
You will need to carry out a Water Framework Directive (WFD) risk assessment as part of your bespoke permit risk assessment if your activity could affect a water body that is at high status or high status morphology. The Environment Agency can give you information about the location of high status water bodies and advise you on the level of assessment you need to do.
You will also need to carry out a WFD risk assessment if you are carrying out:
- work on culverts
- channel widening, deepening, straightening or realigning
- structure impoundment
- bed reinforcement
- sediment management (including dredging and de-silting)
- bank reinforcement
- work on embankments and set-back embankments (over 10m in total length)
- work on by-pass channels (over 10m in total length)
- bank re-profiling (over 10m in total length)
- work to remove or install woody debris (over a length of 20m or greater)
- work to install flow deflectors (over a length of 20m or greater)
- work on bridges or crossings
- work on outfalls
In your WFD risk assessment you must consider the direct and indirect effects of your work on these receptors:
- physical habitat – the distribution and diversity of habitat including the physical processes that sustain and create new habitat
- water quality – particularly physico-chemical aspects of water quality, such as levels of dissolved oxygen, phosphorus and ammonia
- fish and eels
- macrophytes - water plants visible to the naked eye, growing in the river
- invertebrates - insects, worms, molluscs, crustacea etc living on the river bed
If your work could affect these receptors then you need to assess whether or not there is a risk to the objectives set out in your local river basin management plan. For more information on how to do this please read the WFD risk assessment guide.
Summarising the risks and how you will deal with them
You will need to present your risk assessment in a way that demonstrates how you have identified the risks and will address them.
Complex assessments need a summary that can be followed by non-technical people with an interest in your proposal. It may be useful to summarise the risks in a table like this:
|Hazard||Receptor||Pathway||Probability of exposure||Consequence||Severity||Risk management techniques||Overall risk|
|Flooding as a result of temporary works in a river||Gardens of people living at Land End Cottages – 400m east of the site (houses are outside recorded flood plain due to their elevation)||Overland flow from river||Works are being carried out in summer when ground saturation is low||Water logging of gardens, damage to plants||Low to medium||Temporary flood barrier along back line of gardens, sign up for flood warnings, upon receipt of flood warning stop on site work and remove all temporary work from river||Low if we use the management techniques|
|Damage to water vole habitats in an area where they are known to be present||Protected species||Direct from construction activity (for example river bank revetment works or pipeline crossing a watercourse)||Survey before application has identified a population within the works footprint||Damage or loss of habitat that supports water voles, or killing of voles||Medium||Identify how the effect of the impact can be avoided or minimised, eg avoiding areas of water vole habitat and providing an adequate buffer - obtain licence from Natural England if needed||Low if we use the management techniques|
Submit your risk assessment
Send your completed risk assessment(s) as part of your permit application to the Environment Agency .
Other flood risk assessment guidance
The Environment Agency has produced guidance to help you carry out a flood risk assessment for a local authority planning application. Whilst this guidance is not directly relevant to applying for an environmental permit, it may provide additional useful advice on how to do a flood risk assessment.
Contact the Environment Agency if you need help with your risk assessment.
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