habitats regulations assessment · hra will also be required for development projects that come...

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


Effects

Potential Risks


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


Effects

Potential Risks


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


Effects

Potential Risks


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


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.



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



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

habitats regulations assessment · hra will also be required for development projects that come...

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