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Rollesby Neighbourhood Plan
Habitats Regulations Assessment
October 2019
1. Background 1.1. Introduction
This report is the Habitats Regulations Assessment (HRA) of the Rollesby Neighbourhood Plan. It has been prepared by Collective Community Planning on behalf of Rollesby Parish Council. It forms part of the evidence base for the Neighbourhood Plan. A HRA considers the implications of a plan or project for European wildlife sites, in terms of any possible harm to the habitats and species that form an interest feature of the European sites in close proximity to the proposed plan or project, which could occur as a result of the plan or project being put in place, approved or authorised. Where significant negative effects are identified, alternative options should be examined to avoid any potential damaging effects. HRA will also be required for development projects that come forward in the future in accordance with the Great Yarmouth Borough Council Local Plan.
1.2. Legal Requirement of Habitats Regulations Assessment HRA of land-use plans relates to Special Protection Areas (SPA), Special Areas of Conservation (SAC) and Ramsar Sites. SPAs are classified in accordance with Article 4 of the EC Directive on the conservation of wild birds (79/409/EEC), more commonly known as the Birds Directive. They are classified for rare and vulnerable birds, listed in Annex I to the Birds Directive, and for regularly occurring migratory species. SACs are classified in accordance with EC Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). Article 3 of this Directive requires the establishment of a European network of important high-quality conservation sites that will make a significant contribution to conserving the 189 habitat types and 788 species identified in Annexes I and II of the Directive. These sites are known as the Natura 2000 network and are defined in the NPPF as Habitats sites. Ramsar Sites are designated under the International Convention on Wetlands of International Importance especially as Waterfowl Habitat (the Ramsar Convention, Iran 1971 and amended by the Paris Protocol 1992). Although Ramsar Sites are not protected in law by the Birds and Habitats Directives as a matter of policy government has decreed that unless otherwise specified procedures relating to SPAs and SACs will also apply to Ramsar Sites. The Conservation of Habitats and Species Regulations 2017 consolidated the former 1994 and 2010 Regulations. Habitat Regulations Assessment is a step by step decision making process. It can be broken down into the following four stages:
• Screening • Appropriate assessment • Alternative solutions • Imperative reasons of overriding public interest and compensatory measures
This report is stage 2, the appropriate assessment. Screening of the Draft Rollesby Neighbourhood Plan (June 2019) by Great Yarmouth Borough Council concluded that it could not rule out ‘likely significant effects’ at least relating from in-combination effects resulting from increased recreation on nearby internationally protected wildlife sites associated with the new housing allocations proposed. In assessing the implications of the Rollesby Neighbourhood Plan for European sites in close proximity, it is essential to fully understand the sites in question, their interest features, current condition, sensitivities and any other on-going matters that are influencing each of the sites. Every European site has a set of interest features, which are the ecological features of which the site is designated or classified, and the features for which Member States should ensure the site is maintained or, where necessary restored. Each European site has a set of conservation objectives that set out the objectives for the site interest. This appropriate assessment will consider likely significant effects and suggest mitigation measures to enable Great Yarmouth Borough Council to conclude that Rollesby Neighbourhood Plan will not adversely affect the integrity of Habitats sites alone or in-combination, and avoid the need for the process to proceed to stage 3 (alternative solutions).
2. European Sites Natural England recommends considering all European sites within a 10-15km buffer of a plan or project, a 15km buffer has been used in the case of the Rollesby Neighbourhood Plan (RNP). There are nine European sites within 15km of the Neighbourhood Plan area. These include: Figure 1: European Sites within 15km of RNP area
Special Areas of Conservation Special Protection Areas Ramsar Sites Winterton-Horsey Dunes Broadland Broadland The Broads Outer Thames Estuary Braydon Water Haisborough, Hammond & Winterton Breydon Water Great Yarmouth & North Denes
Part of The Broads Special Area of Conservation lies within the RNP area. Figure 2: European Sites within the RNP area
Figure 3: SACs within 15km of RNP area
Figure 4: SPAs within 15km of RNP area
Figure 5: Ramsar Sites within 15km of RNP area
In accordance with the Great Yarmouth Local Plan HRA the following European sites within 15km are ruled out:
• Haisborough, Hammond and Winterton SAC (marine) • Outer Thames Estuary SPA (marine)
Refer to the Great Yarmouth HRA for reasons, sections 2.10 – 2.20:
https://www.great-yarmouth.gov.uk/CHttpHandler.ashx?id=3097&p=0 The following European sites were identified by Natural England during consultation by Great Yarmouth Borough Council on the SEA/HRA screening of RNP as having potential impact pathways. These have been taken forward to the screening assessment for likely significant effects.
• Winterton-Horsey Dunes SAC • Great Yarmouth and North Denes SPA • Breydon Water SPA/Ramsar site • Broadland SPA/Ramsar site • The Broads SAC
Site characteristics and the conservation objectives of each site are set out in Appendix A and more information can be accessed on Natural England’s website:
http://publications.naturalengland.org.uk/category/6581547796791296
3. Establishing Impact Pathways
3.1. Introduction All aspects of the Draft RNP that influence sustainable development within Rollesby parish were checked through this assessment for risks to European sites. Risks need to be identified to inform the screening for likely significant effects. European sites are at risk if there are possible means by which any aspect of a plan can, when being taken forward for implementation, pose a potential threat to the wildlife interest of the sites. This is often referred to as the impact pathway. Threats to European sites are found in the Site Improvement Plan for each site, prepared by Natural England. This HRA is informed by HRA work in Norfolk and Great Yarmouth Borough. Potential impact pathways considered for this HRA include:
• Increased recreational pressure • Air quality impacts • Water issues • Urban effects
3.2. Recreational Pressure
Impacts from recreation include habitat damage, disturbance, trampling and enrichment such as dog fouling. Birds may take off more than usual, be scared away from their feeding or roosting areas; wildlife may be chased or disturbed; large gatherings of wading birds in winter can be disturbed, which can result in them not being able to store enough energy for their long migrations; footpaths can become eroded and rerouted by people walking on sites; and vegetation can become trampled or eroded. Some interest features such as wintering waterfowl and ground-nesting birds are particularly vulnerable. Sites that are vulnerable include those with public access, those likely to draw recreation users and in relatively close proximity to development sites. Figure 6 analyses the distance of RNP allocations from the Broads sites. One allocation, for mixed use, including up to 5 homes, is just under 400m from The Broads SAC, specifically the Trinity Broads SSSI. Other allocations are within 1.2km of the Broads SAC. Local recreation for dog walking is likely to be relevant at these distances. Figure 6: Distance of allocations from the Broads sites
Site Ref Dwellings The Broads SAC Broadland SPA/Ramsar RNP01a 9 1.2 2.8 RNP01b 8 1.0 2.8 RNP01c 8 0.8 2.7 RNP01d 15 1.0 2.7 RNP02 25 0.8 2.5 RNP03 25 0.9 2.6 Mixed Use 5 0.4 2.2
A check of access routes concludes that there is limited public access on foot, with no public footpath connecting Rollesby village with Rollesby Broad or Ormesby Broad. It is reasonable to conclude localised recreational pressure, due to dog walking is likely to be limited due to this. The HRA of the Great Yarmouth Local Plan Part 2 rules out increased recreational pressure as an impact on the Broads sites – The Broads SAC and Broadland SPA/Ramsar site. This follows a report by Panter, Liley & Lowen published in 2017 that presents findings of visitor surveys undertaken at European sites across Norfolk over 2015 and 2016. The results provide an in-depth analysis of current and projected visitor patterns to the European sites. For the Great Yarmouth Borough, the analysis shows that Winterton-Horsey Dunes SAC, North Denes SPA and Breydon Water SPA/Ramsar site are predicted to be most significantly affected by increased growth within the Great Yarmouth Local Plan area. See Section 6 of the Great Yarmouth xx for further explanation. https://www.great-yarmouth.gov.uk/CHttpHandler.ashx?id=3097&p=0 In addition, recent HRAs undertaken for the Broads Local Plan and the Broads Management Plan both focus on visitor management, including boating activities. The plans provide comprehensive measures for managing tourism, and this accords with the duties of The Broads Authority. There is also a partnership of the Norfolk-wide authorities established, which is gathering evidence and looking at measures to manage recreation impacts at the Norfolk European sites, including the Broads and Breydon Water. This provides confidence that visitor pressure to these sites is going to be effectively managed.
3.3. Air Quality Air quality impacts have been ruled out by the Great Yarmouth Local Plan HRA concluding that the borough is not a focus for intensive growth and the borough does not have any currently identified air quality concerns or hold any air quality management areas (AQMAs). In accordance with this, they are ruled out for the RNP HRA.
3.4. Water quality and quantity Water issues relate to water quality and quantity. Run-off, outflow from sewage treatments and overflow from septic tanks can result in increased nutrient loads and contamination of water courses. Abstraction and land management can influence water flow and quantity, resulting in reduced water availability at certain periods or changes in the flow. Such impacts particularly relate to aquatic and wetland habitats.
3.5. Urban effects Urban effects relate to issues where development is close to the European site boundary and is an umbrella term relating to impacts such as cat predation, fly tipping and vandalism. From the distance bands and development locations set out in Figure 11, it can be seen that the
development allocation for mixed use (Policy SSA05) is within 400m of the Broads SAC, it is therefore relevant for this European site, but can be dismissed as a potential impact pathway from the others.
3.6. Impact Pathways Relevant to this HRA For the European sites being considered by this HRA the impact pathways are considered to be:
• Additional recreational pressure; • Water issues relating to water quality and quantity; and • Urban effects
Figure 7: Potential Impact Pathways
European Site Recreation Water Urbanisation Winterton-Horsey Dunes SAC Y Great Yarmouth North Denes SPA Y Breydon Water SPA/Ramsar site Y Broadland SPA/Ramsar site Y The Broads SAC Y Y
4. Screening for Likely Significant Effect
4.1. Policy Screening Figure 8 records the conclusions drawn and recommendations made on a policy by policy check of the Draft RNP (October 2019). During the screening stage of HRA text changes are recommended in the table where there is a clear opportunity to avoid impacts on European sites through policy strengthening, but only where this relates to simple clarifications or corrections. Figure 8: Policy Screening
Policy Description Likely Significant
Effects
Potential Risks
Recommendation at Screening Stage
HO1: Scale and location of housing growth
Identifies a quantum of
development to be delivered
over three phases in the gap between
the two halves of the village
No LSE – No effect because
no development would occur through the policy itself,
the development
being implemented through later Site-Specific
policies (SSA01-05)
N/A None
HO2: Housing Mix
Policy stipulating
required mix of new homes
coming forward
No LSE – does not promote development but relates to
qualitative criteria for
development
N/A None
HO3: Affordable Housing
Policy accords with NPPF,
setting requirements for affordable
housing, including
delivery of onsite
No LSE – does not stipulate any quantum
of development.
N/A None
Policy Description Likely Significant
Effects
Potential Risks
Recommendation at Screening Stage
provision and criteria for
exception sites HO4: Design Qualitative
policy setting criteria for
high quality design
No LSE – policy is qualitative and does not
promote development
N/A None
E1: Protecting and Enhancing the Environment
Qualitative policy seeking to incorporate biodiversity in
and around development
No LSE – mitigation policy for
growth that would protect European sites
N/A None
E2: Character and Appearance
Qualitative policy
safeguarding the rural
character of Rollesby, including
provision of hedgerows as
part of development
No LSE – protective policy and
some limited mitigation
through enhancement of hedgerows
N/A None
E3: Protecting dark night skies
Protective policy to limit the impact of
lighting introduced as
part of development
No LSE – protective policy to support
conservation of natural & built environment
N/A None
E4 Flooding and Drainage
Protective policy
requiring appropriate
flood risk assessment
No LSE – protective policy that
promotes use of SUDS
N/A None
CA1: Community Facilities
Policy to support the retention of
and creation of new services in
Rollesby
No LSE – development would not be
delivered through this
policy.
There may be project
specific risks should
development come
None
Policy Description Likely Significant
Effects
Potential Risks
Recommendation at Screening Stage
forward, which would need to be
picked up in a project level
HRA. CA2: Local Green Space
Protective policy
designating four local
green spaces
No LSE – supports
retention of green open
spaces, conserving the
natural environment
N/A None
CA3: Investment in Open Space
Policy requiring
contributions towards open green space in line with the Open Space
Needs Assessment
No LSE – mitigation
policy, positively steering
development effects away
from European sites
N/A None
TR1: Residential car parking standards
Policy setting requirements for parking for
new residential
development
No LSE – does not promote development
N/A None
TR2: Sustainable Transport
Policy promoting sustainable transport as part of new
development
No LSE – does not promote
development, encourages walking and
cycling in local environment
N/A None
SSA01-4: Residential Development
Site specific allocation
policies – see Section 5.2.
Contain specific
requirements for provision
LSE alone & in combination –
Allocation of 90 homes
alongside 1.42ha green
space
Risk of increased
pressure on European
sites through disturbance and habitat
deterioration
Policy and supporting text refers to green space provision, a
10% net gain in ecological value and
protection of the Broads SAC, but this should be expanded
Policy Description Likely Significant
Effects
Potential Risks
Recommendation at Screening Stage
of open green space, 10% net ecological gain
and new PROW.
to make explicit that there is the
requirement for an evidence based,
project level HRA. This will need to
assess implications arising from
increased recreation pressure, ie from dog
walking, and determine that adequate green
infrastructure will be provided to mitigate this. Supporting text for the policy should
provide details of this.
SSA05: Mixed Use Development
Site specific allocation
policies – see Section 5.2
LSE in combination – site provides
for a small number of homes and office/retail
development
Risk of increased
pressure on European
sites through disturbance and habitat
deterioration
Policy refers to at least a 10% net gain in ecological value
and assessing impacts on the
Broads SAC, but this should be expanded
to make explicit requirement for an evidenced based, project level HRA.
PR1: Plan Review
Requirement for a planned
review by 2029
No LSE – does not promote development
N/A Strengthen the supporting text to require a review of
impacts in relation to European sites
through an update of the HRA.
4.2. Screening Site Allocations
This section considers the site allocations within the draft RNP. The overall allocation of 95 new homes is significantly greater than that proposed in preparation of the Great Yarmouth Local Plan Part 2, which identifies 20 homes for Rollesby. The development is planned over three phases, with the first phase delivering 40 new homes between 2020 and 2025 and the
second phase 25 new homes between 2025 and 2030. A planned review will take place before 2029 to determine the need for an additional 25 homes, which would be delivered as phase three between 2030 and 2035. Each allocation has been mapped, see Figure 9 and 10. The number of homes to be delivered with each allocation and their distance from European sites is provided in Figure 11. The centre point of each allocation has been used to determine the distances. Figure 9: Residential Site Allocations
Figure 10: Mixed Use Site Allocation
Figure 11: Allocation Distances from European Sites (Km)
Site Ref Dwellings The Broads
SAC
Winterton-Horsey Dunes
Great Yarmouth
North Denes
Broadland SPA/Ramsar
Breydon Water
SPA/Ramsar
RNP01a 9 1.2 5.9 5.7 2.8 9.1 RNP01b 8 1.0 5.7 5.5 2.8 9.0 RNP01c 8 0.8 5.6 5.4 2.7 8.9 RNP01d 15 1.0 5.7 5.4 2.7 9.1 RNP02 25 0.8 5.4 5.2 2.5 8.7 RNP03 25 0.9 5.5 5.3 2.6 8.9 Mixed Use
5 0.4 5.2 5.1 2.2 8.4
Based on the data in Figure 11 the number of new homes within distance bands of each of the European Sites has been calculated. The distances used accord with the Great Yarmouth Local Plan Part 2 HRA.
• 400m, which captures sites close to the European site boundary, where urban effects, run-off, recreation will likely be of particular relevance. 400m is used at a range of other European sites such as the Thames Basin Heaths and Dorset Heaths to indicate a zone where there is a presumption against development
• 2,500m, highlighting allocations reasonably close to the site boundary but set further back. There may be hydrological issues and recreation may also be relevant.
• 5,000m, representing a wider zone but potentially still relevant for impacts such as recreation.
Allocations that lie outside of the distance bands may still be implicated in cumulative impacts, for example in-combination effects from other plans and programmes, including development allocated as part of the Great Yarmouth Local Plan. Figure 12: New Homes within close proximity of European Sites
European Site 400m 2.5km 5km Great Yarmouth North Denes SPA 0 0 0 Breydon Water SPA/Ramsar site 0 0 0 Broadland SPA/Ramsar site 0 30 65 The Broads SAC 5 90 0 Winterton-Horsey Dunes SAC 0 0 0
The table shows a notable increase in housing within 5km of the Broads sites, which may give rise to likely significant effects in relation to the impact pathways identified in Section 4. The RNP allocations lie just outside of the 5km threshold for the Winterton-Horsey Dunes SAC and Great Yarmouth North Denes SPA. RNP determines that the housing allocations will be delivered in three phases. The policy relating to each of these sets the requirement for provision of open green space, to be gifted to the community. A new Public Right of Way providing connectivity with existing footpaths and the recreation ground is to be delivered as part of phase 3. This and the 1.42ha of green space to be delivered as part of the allocations overall will mitigate impacts on European sites by reducing recreational pressure. Each of the Site Allocation Policies requires a 10% net ecological gain, aligning with the Government’s direction on biodiversity net gain. Securing an ecological net gain through development will help reverse biodiversity loss and biodiversity assets outside designated sites have a critical role in supporting biodiversity within designated sites, in terms of supporting processes, genetic exchange, additional habitat, buffering and climate change adaptation. Adequate protection of wider biodiversity, and proactive measures as part of development to secure biodiversity net gains will in turn increase the resilience of protected sites.
4.3. Screening Conclusions Section 4.6 identified impact pathways in relation to:
• Recreational pressure on Winterton-Horsey Dunes SAC, Great Yarmouth North Denes SPA and Breydon Water SPA/Ramsar Site
• Water effects for Broadland SPA/Ramsar site and the Broads SAC • Urbanisation with respect to the Broads SAC
This screening has identified likely significant effects may arise in relation to water and urbanisation effects on the Broads SAC and water effects for Broadland SPA/Ramsar site. Assessment of each of the residential allocations to determine their location in relation to European sites identified that Winterton-Horsey Dunes SAC, Great Yarmouth North Denes SPA are consistently over 5km from all of the allocations. Although this falls outside of the 5km zone that requires mitigation, the overall allocation of 95 new homes is significantly greater than that proposed in preparation of the Great Yarmouth Local Plan Part 2, which identifies 20 homes for Rollesby. Therefore, a strategic in-combination effect cannot be ruled out.
5. Appropriate Assessment
5.1. Introduction This section provides an appropriate assessment of the potential impacts of water quality and quantity and urban effects both of which have been screened in by the checking of impact pathways and screening for likely significant effects. Once a likely significant effect has been identified, the purpose of the appropriate assessment is to examine evidence and information in more detail to establish the nature and extent of the predicted impacts, to answer the question as to whether such impacts could lead to adverse effects on European site integrity.
5.2. Recreational Pressure The North Denes SPA (which includes the beach at Winterton-Horse Dunes SAC and SSSI) is designated for its breeding little tern colony. Most of the little tern colonies are already protected either within nature reserves or through wardening schemes. The colonies are fenced to keep human disturbance to a minimum, but this means there are only limited safe nesting areas available to the birds, which without human impacts would be expected to move around the coast. The tern colony is already under significant pressure and further development may further exacerbate problems through additional recreational pressure. Winterton-Horsey Dunes is designated as a SAC for its Atlantic decalcified fixed dunes, humid dune slacks, embryonic shifting dunes, and shifting dunes along the shoreline with Ammophila arenaria. Visitor access for recreation causes damage through trampling of vegetation and the sand dunes, and dog fouling. Although just over 5km in distance from the site allocations, the Dunes are popular and likely to attract people looking for a longer walk and wilder experience than can be found locally in Rollesby or surrounding countryside. The main effect of increased visitor pressure is likely to be trampling which will increase the area of bare ground, surface movement and loss of vegetation species diversity and cover. The mobile dunes and fixed dunes are likely to be most vulnerable. The Site Improvement Plan for Great Yarmouth Winterton Horsey, which covers Great Yarmouth North Denes SPA and Winterton-Horsey Dunes SAC identifies that the site is at carrying capacity in terms of recreational disturbance. Breeding Little terns, as well as the lichen dune grassland and dune heath are particularly sensitive. Each of the RNP allocation policies have strong policy wording in relation to the provision of adequate green infrastructure as part of the mitigation for reducing recreation pressure, ie by diverting that pressure to other sites. Over three phases of development this includes provision of an additional 1.42ha of community green space including extension to the recreation ground, and a new Public Right of Way providing connectivity with existing footpaths and the recreation ground. This will provide a viable alternative to the sensitive areas of European sites.
Additionally, development delivered as part of RNP should accord with the Great Yarmouth Natura 2000 Sites Mitigation and Monitoring Strategy which aims to protect Winterton-Horsey Dunes SAC, Breydon Water SPA/Ramsar site and North Denes SPA from recreational pressure arising from new development. This strategy applies to residential development and major tourism development within the Borough Council’s Local Planning Authority area. The allocation policies should include requirement for a project level HRA and the supporting text should refer to the Mitigation and Monitoring Strategy.
5.3. Urbanisation This impact is closely related to recreation pressure, in that they both result from increased populations within close proximity of sensitive sites. The list of urban impacts is extensive, but core impacts can be singled out:
• Increased fly-tipping – Rubbish tipping is unsightly but the principle adverse ecological effects of tipping is the introduction of invasive alien species within garden waste. Garden waste results in the introduction of invasive aliens precisely because it is ‘troublesome and over-exuberant’ garden plants that are typically thrown out. Invasive species found within the Broads SAC include Himalayan Balsam (Impatiens glandulifera), Australian Swamp Stonecrop (Crassula helmsii), Floating pennywort (Hydrocotyle ranunculoides), Giant hogweed (Heracleum mantegazzianum), Japanese knotweed (Fallopia japonica),
• Cat predation – A survey undertaken in 1997 indicated that nine million British cats brought home some 92 million prey items over a five-month period. A large proportion of domestic cats are found in urban situations, and increasing urbanisation is likely to lead to increased cat predation.
The nature of development proposed is important to consider. The mixed allocation site, located just under 400m from the edge of the Broads SAC at its nearest point, could deliver up to 5 new homes and office/retail development. Given the type of development, and small-scale level of housing, up to 5 homes, significant effects are not likely, but in mitigation a project level HRA should consider the potential impacts of urbanisation.
5.4. Water Impacts The quality of the water that feeds European sites is an important determinant of the nature of their habitats and the species they support. The Broads SAC and Broadland SPA/Ramsar site are sensitive to changes in water levels and water quality. These are a low-lying wetland complex straddling the boundaries between east Norfolk and northern Suffolk in eastern England. The Broads are a series of flooded medieval peat cuttings. They lie within the floodplains of five principal river systems, known as Broadland. The area includes the river valley systems of the Bure, Yare and Waveney and their major tributaries. The distinctive open landscape comprises a complex and interlinked mosaic of wetland habitats including open water, reedbeds, carr woodland, grazing marsh, tall herb fen, transition mire and fen meadow, forming one of the finest marshland complexes in the UK. The differing types of management of the vegetation for reed, sedge and marsh hay, coupled with variations in
hydrology and substrate, support an extremely diverse range of plant communities. The area is of international importance for a variety of wintering and breeding raptors and waterbirds associated with extensive lowland marshes. They are vulnerable to the effects of water pollution through agriculture/run-off and water abstraction. Water level management is key to the maintenance of features throughout the Broads. The Trinity Broads SSSI, which are closest to the development allocations – 0.4km at its closest point, have been subject to a large amount of monitoring and research in relation to hydrology to determine that abstraction is not having a detrimental effect on the protected wildlife. This research shows that there is usually a summer drop in water levels, which are then recharged over the winter months. A study into flushing times found that all of the water in the Trinity Broads is flushed through the system on at least an annual basis. Regular flushing of shallow lakes is important to reduce built up of nutrients and algae. Nutrient levels in the Trinity Broads are higher than recommended for shallow lakes, which can cause algal blooms and associated decline in water plants and other aquatic wildlife. These nutrients enter the broad from farmland in the surrounding catchment, and from septic tanks and occasional failures of sewerage pumping stations. It is essential that the correct water management infrastructure and operating protocols are in place to deliver the optimum hydrological regime. Water is abstracted from the Trinity Broads for public water supply and agriculture. The current regime comprises summer drawdown and winter recharge. Excessive summer drawdown may affect the rare Desmoulin’s whorl snail, the success rate of spawning fish and the favourable condition status of emergent and aquatic plant communities. Much research illustrates the delicate balance required to meet the needs of water supply whilst protecting the designated habitats and features. Any new development that will result in an increase in sewage outputs provided by the RNP has the potential to result in an adverse effect. The Water Resources Management Plan prepared by Anglian Water has been the subject of HRA, concluding that any potential impacts arising from the proposed schemes to deliver sustainable water resources over the next 25 years can be fully mitigated for and adverse effects on European sites prevented. It is recommended that the RNP allocation policies make specific reference to the need for project level HRA to assess and mitigate for any water quality risks with appropriate surface water management demonstrated as part of the proposal.
6. Conclusions & Recommendations
6.1. Summary of Findings Both a test of likely significant effects and a subsequent appropriate assessment was undertaken on the Rollesby Neighbourhood Plan. This was undertaken in the context of the overarching policy provided by the Great Yarmouth Borough Local Plan (both Part 1 and emerging Part 2) and the Local Plan for the Broads. It is evident from the screening undertaken that many of the policies already provide strong protection for the natural environment. This includes:
• Designation of Local Green Spaces • Protection of Dark Night Skies (outside of Broads Authority Executive Area) • Requirements to deliver net gains in biodiversity • Protection of landscape features including hedgerows • Use of Sustainable Drainage Systems.
RNP allocates land for up to 95 new homes within the parish over three phases over the next 15 years. The level of growth is significantly higher than that proposed within the Great Yarmouth Local Plan Part 2, which allocates for up to 20 new homes within Rollesby. The site allocation policies include provision of 1.42ha additional community green space and extension to the existing public rights of way network, which will mitigate local recreational impacts. The phased approach will result in development being delivered in a planned way and ensure that potential impacts on European sites are considered at each stage of growth. The HRA has recommendations from the screening assessment for policy wording changes, and recommendations from the appropriate assessment for strategic mitigation. These recommendations have been established at the Pre-Submission Draft Neighbourhood Plan stage.
6.2. Policy Wording Recommendations It is recommended that the site allocation policies and supporting text be strengthened in relation to: Policy SSA01-04: The Policy and supporting text refers to green space provision, a 10% net gain in ecological value and protection of the Broads SAC, but this should be expanded to make explicit that there is the requirement for an evidence based, project level HRA. This will need to assess implications arising from increased recreation pressure, ie from dog walking, and determine that adequate green infrastructure will be provided to mitigate this. Supporting text for the policy should provide details of this.
Policy SSA05: Policy refers to at least a 10% net gain in ecological value and assessing impacts on the Broads SAC, but this should be expanded to make explicit requirement for an evidenced based, project level HRA. Policy PR1: Strengthen the supporting text to require a review of impacts in relation to European sites through an update of the HRA.
6.3. Strategic Mitigation The following strategic mitigation measures are recommended:
• For recreation pressure on Winterton-Horsey Dunes SAC and Great Yarmouth North Denes SPA it is recommended that contributions are collected in accordance with the Great Yarmouth Natura 2000 Sites Mitigation and Monitoring Strategy. This aims to protect Winterton-Horsey Dunes SAC, Breydon Water SPA/Ramsar site and North Denes SPA from recreational pressure arising from new development. A levy of £110 is applied to each new dwelling to support delivery of the Strategy.
• It is recommended that the RNP allocation policies make specific reference to the
need for project level HRA to assess and mitigate for any water quality risks with appropriate surface water management demonstrated as part of the proposal.
• The planned review, to take place prior to 2029 in accordance with Policy PR1, should
involve an update of this HRA.
6.4. Conclusion It is considered that with the inclusion of the above recommendations, the Rollesby Neighbourhood Plan will not result in an adverse effect on the integrity of European sites.
Appendix A: European sites relevant to RNP HRA. Site Reason for designation, trends in key species Condition Threats and reasons for adverse
condition The Broads SAC,
Broadland SPA/Ramsar
site
Hard oligo-mesotrophic waters with Charophytes, natural eutrophic lakes with Magnopotamium or
Hydrocharition type vegetation, transition mires and quaking bogs, calcareous fens with Cladium mariscus
and species of the Caracion daravallianae, alkaline fens and alluvial forests with Alnus glutionous and Fraxinus
excelsior, Molinia meadows on calcareous, peaty or clayey-silt-laden soils. Desmoulin’swhorl snail Vertigo moulinsiana, otter Lutra lutra and fen orchid Liparis
loeselii. Breeding bittern and marsh harrier, wintering hen harrier, Bewick’s and whopper swan and wigeon
shoveler and gadwall.
Management neglect and succession, water abstraction,
drainage, sea level rise and saline incursions. Sewerage discharges and agricultural runoff. Tourism
and recreation.
Relevant component SSSIs
Burgh Common & Muckfleet
Marshes
Floristically-rich fen meadows, tall fen vegetation and drainage dykes
22% favourable; 29% unfavourable
recovering; 49% unfavourable no change.
Water pollution – agriculture / run-off
Hall Farm Fen, Hemsby
Floristically rich unimproved fen grassland with dykes unusual in supporting both acidic and calcareous plant
communities.
100% unfavourable no change.
Water abstraction
Trinity Broads Shallow inter-connecting lakes with fringing reedswamp, wet carr woodland and fen
29% favourable; 36% unfavourable
recovering; 36% unfavourable no change
Inappropriate scrub control. Water abstraction. Water pollution –
agriculture/run-off. Water pollution - discharge
Shallam Dyke Marshes, Thurne
Grazing marsh and clearwater drainage dykes 1% favourable; 3% unfavourable
recovering; 79% unfavourable no
change; 17% unfavourable declining
Drainage, inland flood defence works, water pollution –
agriculture / run-off
Upper Thurne Broads & Marshes
Open water and marginal reedswamp, species rich mixed and Cladium fen, base-poor seepage community,
grazing marsh, alder carr. Marsh harrier and bittern.
40% favourable; 2% unfavourable
recovering; 47% unfavourable no
change; 11% unfavourable declining
Water pollution – agriculture / run-off. Drainage Inappropriate css/esa
prescription. Agriculture – other. Siltation.
Site Reason for designation, trends in key species Condition Threats and reasons for
adverse condition Winterton-Horsey Dunes SAC, Great Yarmouth North
Denes SPA
Atlantic decalcified fixed dunes (Calluno-Ulicetea), Humid dune slacks, Embryonic shifting dunes, shifting
dunes along shoreline with Ammophila arenaria. Breeding litter tern (variable between years).
Declines in management, water abstraction, land
drainage, scrub encroachment.
Relevant Component SSSIs
Great Yarmouth North Denes
Full successional sequence of vegetation from pioneer to mature types; foredune, mobile dune, semi-fixed dune
and dry acid dune grassland, accreting ness (promontory). Largest breeding colony of little tern on
the foreshore.
100% favourable
Winterton-Horsey Dunes
An extensive dune supporting well developed dune heath, slacks and dune grassland. Little terns breed on
the foreshore.
30% favourable; 56% unfavourable recovering;
14% unfavourable no change.
Inappropriate coastal management
Site Reason for designation, trends in key species Condition Threats and reasons for adverse
condition Breydon Water
SPA/Ramsar site
Breeding common tern Sterna hirundo (no trends available), wintering Bewick’s swan (declining), avocet
Recurvirostra avosetta (stable) and golden plover Pluvialis apricaria (stable), ruff Philomachus pugnax,
wintering Lapwing Vanellus vanellus (SPA) (stable). At least 20,000 wintering waterfowl.
Sea-level rises, recreational disturbance
Relevant Component SSSIs
Breydon Water The only intertidal flats occurring on the east coast of Norfolk attracting large numbers of wildfowl and waders
on passage and during the winter months.
100% favourable
Halvergate Marshes
Support wintering waterfowl including Bewick’s swan, lapwing and golden plover
32% favourable; 44% unfavourable
recovering; 24% unfavourable no
change.
Inappropriate weed control. Inappropriate css/esa prescription.
Inappropriate cutting/mowing. Water abstraction. Inappropriate
ditch management. Source: Great Yarmouth Borough Council HRA of LPP2, August 2018
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