Local Plan post adoption Strategic Environmental Assessment Statement

Strategic Environmental Assessment Statement

for the Adopted New Forest National Park Local Plan 2016 - 2036

August 2019

Contents

1. Introduction
2. Integration of environmental considerations into the Plan
3. How the environmental report has been taken into account
4. How consultation has influenced the Plan
5. Reasons for choosing the plan in light of other alternatives
6. Monitoring the significant environmental effects

1. Introduction

1.1 The Environmental Assessment of Plans and Programmes Regulations 2004 requires a Strategic Environmental Assessment (SEA) for the New Forest National Park Local Plan.

1.2 Regulation 16 (4) of the Environmental Assessment of Plans and Programmes Regulations 2004 sets out the requirements for the procedures for a SEA after the adoption of a Local Plan. It requires a ‘Statement’ to be prepared and published to include:

• how environmental considerations have been integrated into the New Forest National Park Local Plan;
• how the environmental report has been taken into account;
• how opinions expressed in response to consultations have been taken into account;
• the reasons for choosing the Local Plan as adopted, in the light of the other reasonable alternatives dealt with; and
• the measures that are to be taken to monitor the significant environmental effects of the implementation of the Local Plan.

1.3 This SEA Statement sets out the information required in accordance with these Regulations in the sections below that cover each of these specified issues.

1.4 For clarity, it is worth noting that Regulation 16 (1) and (3) of the Environmental Assessment of Plans and Programmes Regulations 2004 also require that an Environmental Report accompany the adopted Local Plan. This Environmental Report is contained within the Authority’s Sustainability Appraisal Report of the adopted Local Plan and this is published separately to this SEA Statement.

2. Integration of environmental considerations into the New Forest National Park Local Plan 2016 – 2036

2.1 A Strategic Environmental Assessment (SEA) assesses the environmental impacts of a plan being prepared. Following Government guidance, these assessments can be combined with a Sustainability Appraisal (SA), which assesses a broader range of environmental, economic and social impacts. In preparing its Local Plan, the National Park Authority has done this and has prepared a SA for the New Forest National Park Local Plan that incorporates the environmental requirements of a SEA.

2.2 The Sustainability Appraisal of the Local Plan helped to promote sustainable development through the integration of social, environmental and economic considerations into the preparation of the Local Plan. It tested the policies and objectives included in the Local Plan against a set of sustainability objectives and criteria, including those relating to environmental considerations. The Local Plan has been adapted to reflect the findings of these SA assessments and this has ensured that the final adopted Local Plan is sustainable.

SA Process and timing

2.3 The SA Report for the Submission Draft Local Plan (January 2018) sets out how the requirements of the SEA Directive have been met (in Table 1, paragraph 3.4), and outlines the methodology used to integrate environmental considerations into the Local Plan. The process followed for sustainability appraisal of the Local Plan’s preparation is summarised as follows:

2.4 The Scoping Stage of the SA involved the collection of baseline information about the National Park; identifying the international, national and local policy context; identifying key sustainability issues which may be affected by planning policies; and developing a sustainability framework including objectives and criteria for assessing the Local Plan policies. These are described in detail in Chapter 4 of the SA of the Submission draft Local Plan (Jan 2018).

2.5 An important element of environmental considerations in the New Forest are the number of international, national and local plans, policies and programmes that have been taken into account, which set the wider policy context relevant to environmental issues. Those of relevance to the development of planning policies within the National Park are listed in Appendix 2 of the SA of the Submission draft Local Plan (Jan 2018).

Key sustainability issues and likely evolution without the Submission draft Local Plan

2.6 A number of key sustainability issues for the National Park, including environmental ones, were identified during the Scoping Stage of the SA. Those which may be affected by policies in the Local Plan were listed in Chapter 4 (c) of the SA of the Submission draft Local Plan (January 2018). These are listed below, together with a summary of how these may have developed if the Local Plan policies were not put in place. The issues are loosely arranged under environmental, social and economic headings, although several cut across these categories.

2.7 The SA Framework establishes a set of sustainability objectives and criteria to measure the sustainability of environmental, economic and social effects of the Local Plan policies, which can then be compared. The framework for assessing Local Plan policies comprised 10 sustainability objectives and the decision-making criteria listed below.

3. How the environmental report has been taken into account

3.1 The environmental report is incorporated into the Sustainability Appraisal of the adopted Local Plan – August 2019 (SA). Paragraph 3.4 and Table 1 of Section 1 of this SA shows how the requirements for the environmental report under Regulation 12 of the Environmental Assessment of Plans and Programmes Regulations 2004 have been met.

3.2 The SA made a number of recommendations to either reduce or avoid identified potential adverse sustainability effects or maximise any potential positive impacts, including environmental effects and impacts. The findings of the SAs were taken into account to inform the development of the Local Plan at each stage of its progress.

3.3 The results and recommendations of the SA assessments were carefully considered and taken into account throughout the development of the Local Plan. Please see details and recommendations of measures to mitigate or avoid adverse environmental impacts in each of the Sustainability Appraisal documents listed in Section 2.2.

3.4 Whilst the majority of policies provided positive effects on the sustainability objectives, a few policies had the potential for negative impacts, and recommendations for mitigation and enhancement were made. These have resulted in amendments to the Local Plan, which combined with other policy requirements and measures contained within the Plan will ensure that potential adverse impacts from Plan policies on the SA Objectives will be mitigated.

4. How opinions raised during consultations have been taken into account

4.1 Sustainability Appraisals aim to assist the decision-making process during the development of the Plan, by providing assessments on the sustainability of proposed policies and approaches. Thus, the SA assists in the choices and policy approaches taken by those who are preparing the Plan.

4.2 In addition, those preparing the Plan need to consider the representations of those who have responded to consultations about the various stages of the Local Plan preparations and the accompanying Sustainability Appraisals.

4.3 There were consultations for the Sustainability Appraisal of the various stages of the Local Plan preparation, including:

4.4 Full public consultation was undertaken at both the Regulation 18 and Regulation 19 stages of the Local Plan. Details of these consultations and how the Authority responded to representations are outlined in the Local Plan Examination Consultation Statement, which formed part of the Core Document List (CD12) for the Examination of the Local Plan and can be found by the following link.

https://www.newforestnpa.gov.uk/app/uploads/2018/01/Consultation-Statement-May-2018.pdf

5. Reasons for choosing the plan as chosen, in light of other alternatives

5.1 A number of alternative policy approaches were considered during the preparation of the Plan including for the following issues:

• Retail development
• Affordable Housing provision within the defined villages
• Alternative sites for housing allocations
• Parking standards
• Replacement Dwellings
• Gypsies, Travellers and Travelling Showpeople
• Self-Build Housing
• Rural Exceptions Sites

5.2 The results of the sustainability assessment of the alternatives for these issues can be seen in the Draft Sustainability Report (2016) that accompanied the Regulation 18 Consultation of the Draft Local Plan. These assessments informed the choice of the final policy approaches taken in the Submission draft Local Plan and the relevant assessments can be found in Appendix 1 of this Statement.

5.3 As the settlement pattern is a key element of delivering sustainable development in the National Park, an assessment was completed to test the preferred approach with two alternative approaches, including:

1. Removing all the settlement boundaries and have a criteria-based approach for assessing applications across the National Park
2. Extending the settlement hierarchy to include other larger villages with some basic services such as Landford, Burley and Cadnam.

5.4 This assessment can be found in Appendix 5 of the SA of the Submission draft Local Plan (Jan 2018) and also in Appendix 1 of this Statement. It concludes that the Spatial Strategy (Policy SP4) is the most sustainable of the possible alternatives. The proposed settlement pattern (and the housing allocations adjacent to these) included in the Local Plan will assist in delivering most of the housing provision for the National Park, whilst also safeguarding the landscape character of the National Park by limiting the extent of development elsewhere throughout the Park.

6. Monitoring the significant environmental effects

6.1 Some of the assessments of the policies were judged to have uncertain effects on the sustainability objectives. This uncertainty derives from a number of sources, including the quality and availability of relevant data. Given that implementation will be important to the success of the Local Plan, the effects of its approaches and policies will need to be monitored during its implementation to identify any adverse impacts.

6.2 The NPA will continue to produce both a State of the Park Report and an Annual Monitoring Report to assess the condition of the National Park, measure progress towards objectives and targets and examine the effectiveness of the Local Plan policies and strategic objectives. These monitoring reports will also provide information which will allow judgement of how different policies are likely to contribute to the delivery of sustainable development (including environmental effects) and how well policies are acting as mitigation for potential adverse sustainable impacts.

6.3 By monitoring a wide range of the baseline information and trends in the State of the Park Report, it will be possible to identify any new unforeseen adverse effects that will need to be addressed. Therefore, the Authority’s monitoring arrangements will not only serve to assess the progress of delivering the Local Plan policies, but will also be appropriate to monitor the significant sustainability (including environmental) effects.

Appendix 1: Assessment of alternatives

A1. The SA of the Submission draft Local Plan (Jan 2018) summarised the consideration of alternative approaches, and its conclusion was outlined in the Non-Technical Summary Stage B as follows:

Stage B: Developing policies and assessing effects – Developing policies

A2. A range of policies have been included in the Submission draft Local Plan. For some of the planning policies, alternative policy options were considered and a number of these were highlighted in the Authority’s consultation draft Local Plan (October 2016), with representations invited on the alternative options. The range of alternatives was, however, limited – this was mostly due to the need to conform with the statutory legal purposes and duty of the National Park and the legal protection required for the large area of the National Park covered by international nature conservation legislation. In many cases there were, therefore, limited realistic alternatives for the policy direction to be followed in the National Park, and this is outlined in Section 4B(c) below. An assessment was also made of the likely evolution of the key environment, social, and economic issues in the area if the proposed Submission draft Local Plan policies were not pursued and this can be found in Paragraph 2.5 of the Sustainability Appraisal Statement above.

Section 4B (c) Appraisal of alternatives considered

• A requirement of the SA process is to identify, describe and evaluate any reasonable alternative approaches, taking into account the objectives and the geographical scope of the plan. In the case of a nationally protected landscape, the range of alternatives is limited by the need to conform to the statutory legal purposes and duty of the National Park (as originally established in the National Parks and Access to the Countryside Act 1949). Given the success of the existing Core Strategy policies in delivering these National Park purposes, it has been considered prudent to continue with the existing approach in many policy areas. This means that alternative approaches in many policy areas have not been required.
• The National Planning Policy Framework clarifies that for plan making, development in National Parks should be restricted and therefore do not have to meet objectively assessed needs. This means that some development approaches have not been considered, and this restricts the amount of possible alternatives.
• Furthermore, well over half of the land in the National Park’s planning area is covered by internationally designated nature conservation sites which have the highest level of protection under nature conservation legislation. The New Forest National Park has a higher proportion of land covered by these international designations than any other planning authority in England. The National Planning Policy Framework also clarifies that the presumption in favour of sustainable development does not apply where development requiring appropriate assessment under the Birds and Habitats Directives is being considered. The Habitats Regulations Assessment of the Local Plan concludes that prior to mitigation, the recreational impacts of new residential and visitor accommodation throughout the National Park cannot be ruled out as having a likely significant in combination effect on these designated areas. Therefore, this further NPPF restriction applies throughout the National Park and again limits the possible alternative approaches that can be considered.
• Consequently, in many cases when considering possible planning approaches for the area there are limited realistic alternatives that can be followed in the National Park.

Despite these restrictions, a number of alternatives were considered during the preparation of the Local Plan. Alternative approaches have been considered for the following issues:

• Retail development
• Affordable Housing provision within the defined villages
• Alternative sites for housing allocations
• Parking standards
• Replacement Dwellings
• Gypsies, Travellers and Travelling Showpeople
• Self Build Housing
• Rural Exceptions Sites

The results of the sustainability assessment of each of these alternatives can be seen in the Draft Sustainability Report (2016) that accompanied the Regulation 18 Consultation of the Draft Local Plan. These assessments informed the choice of the final policy approaches taken in the Submission draft Local Plan and are outlined below.

Sustainability Appraisal of draft Local Plan Policies

Assessment key: + Positive   0 Neutral   ? Uncertain   - Negative

As the settlement pattern is a key element of delivering sustainable development in the National Park, an assessment was also completed to test the preferred approach to locating new development (outlined in the Submission draft Local Plan Policy SP4: Spatial Strategy) with two alternative approaches, including:

1. Removing all the settlement boundaries and have a criteria based approach for assessing applications across the National Park
2. Extending the settlement hierarchy to include other larger villages with some basic services such as Landford, Burley and Cadnam.

This assessment can be found in Appendix 5 of the SA of the Submission Draft Local Plan (Jan 2018) and is outlined below and concludes that the approach taken in the Submission draft Local Plan Policy SP4 is the most sustainable of the possible alternatives.

Sustainability Appraisal of Alternatives for the Spatial Strategy

Assessment key: + Positive   0 Neutral   ? Uncertain   - Negative

Assessment of alternatives to Policy SP4 Spatial Strategy: Local Plan Policy SP4 – Spatial Strategy

1. The conclusion of the SA assessment of the Spatial Strategy Policy SP4 is that it scores positively for helping to deliver housing needs (SA Objective 7), improving the access and maintenance of services (SA Objective 6), supporting existing transport services (SA Objective 8), and using the most sustainable location for business development (SA Objective 9). In addition there are potential benefits in this approach for protecting the wider landscape and nature conservation elsewhere in the National Park (SA Objectives 1, 2). Overall, this approach is considered to be a more sustainable approach than Alternative (a) or Alternative (b).

2. Focusing development in the existing larger settlements of Brockenhurst, Sway, Lyndhurst and Ashurst will allow residents of new developments to access a wider range of services that are available in these locations, including shops, doctors and schools. Moreover, the increased development in these villages will support the retention of existing services and encourage the start of new ones. A more dispersed settlement pattern may not necessarily be able to support new services in smaller villages.

3. Brockenhurst, Sway and Ashurst benefit from frequent and long distance railway services and also have regular bus services. Consequently, focusing development in these locations is likely to help the amount of sustainable transport available to residents, and therefore be beneficial for SA Objective 8. A settlement pattern focusing development in the four defined villages would be likely to minimise the need to travel to work, shops, doctors and schools, and, therefore, would minimise the possible impacts of carbon emissions and climate change.

4. Focusing development in the existing four defined villages will allow residents of new developments to access a wider range of jobs and business services and will allow businesses to locate closer to customers. The existing transport facilities will support a more sustainable supply and delivery of their goods and services and locating in the four defined villages will minimise the need to travel to work. Moreover, the increased development in these villages could support the retention of existing businesses and encourage the start of new ones. A more dispersed settlement pattern would likely to mean businesses are developed in less sustainable locations, but focusing new development on the four defined villages may mean that the housing or employment and development needs of other communities may not be fully met.

5. The settlement hierarchy outlined in Policy SP4 will locate the majority of housing development within or close to the four defined villages, which will separate these houses and businesses from, and reduce the impact on, the landscape of the open countryside. The whole of the National Park is a nationally protected landscape and the National Planning Policy Framework specifically identifies National Parks as areas where development should be restricted so that the landscape can be protected. Large numbers of houses and businesses built in the open countryside could erode the reason the area was designated as a National Park.

6. A settlement pattern focused on the four defined villages would also reduce the likelihood of new housing being located close to the internationally designated nature conservation areas. These designated sites are protected by the Habitats Regulations and make up more than half of the land in the National Park. Natural England have advised that it is not appropriate to locate new housing allocations close to these designated sites. Under these circumstances, Policy SP4 is likely to be a more sustainable approach than Alternative (a) and Alternative (b).

Alternative (a)

7. The conclusion of the SA assessment of Alternative (a) is that this alternative settlement pattern would help to deliver housing needs, but could lead to possible conflicts with the protection of the landscape, nature conservation, and with the character of the built environment and cultural heritage (SA Objectives 1, 2 and 3). It also raises the potential of some negative impacts on the sustainable use of resources (SA Objective 4), and the support for local transport infrastructure, including sustainable transport (SA Objective 8). Overall, therefore, Alternative (a) is considered to be a much less sustainable approach than the spatial strategy outlined in Policy SP4.

8. It is considered that this approach would not result in a sustainable location for housing development. Dispersed and thinly scattered housing development would not help the retention of services and shops, the provision of utilities, an effective transport network, and would be likely to increase the need to travel to work, shops, doctors and schools.

9. The settlement hierarchy outlined in Policy SP4 will locate the majority of housing development within or close to the four defined villages, which will separate these houses from the landscape and nature conservation habitats of the open countryside. Alternative (a) does the opposite to this. By locating new housing and other development throughout the National Park, including areas closer to the open countryside, there is a likelihood that this will have a greater impact on the landscape. The whole of the National Park is a nationally protected landscape and the National Planning Policy Framework specifically identifies National Parks as areas where development should be restricted so that the landscape can be protected. Large numbers of houses built in the open countryside would erode the reason the area was designated as a National Park. Under these circumstances, Alternative (a) is likely to be a much less sustainable approach than the spatial strategy outlined in Policy SP4.

10. A dispersed settlement pattern would also increase the likelihood of new housing being located close to the internationally designated nature conservation areas. These designated sites are protected by the Habitats Regulations and make up more than half of the land in the National Park. Natural England have advised that it is not appropriate to locate new housing allocations close to these designated sites. Under these circumstances, Alternative (a) is likely to be a much less sustainable approach than the spatial strategy outlined in Policy SP4.

11. The approach to locating new housing anywhere throughout the National Park in Alternative (a) could lead to adverse impacts on the character of the built environment. The distinct character of New Forest villages and their close relationship with the open countryside, which is often integrated right into settlements, means that new building face a significant challenge to be sympathetically incorporated into the existing built environment. Opportunities to integrate new buildings through landscaping schemes are reduced when located close to or in the open countryside, with its very natural and historic habitats. Under these circumstances, Alternative (a) is likely to be a much less sustainable approach than the spatial strategy outlined in Policy SP4.

12. The dispersed settlement approach in Alternative (a) is likely to mean more difficulty in provision of utilities, and a much greater need to travel. Consequently there would be greater concern over the possible impacts on climate change and a less sustainable use or resources than in Policy SP4.

13. Whilst a more dispersed settlement approach is likely to mean businesses are developed in less sustainable locations, new development in smaller settlements could support local businesses and services, provide jobs and strengthen those communities. Focusing new development on the four defined villages may mean that the housing or employment and development needs of other communities may not be fully met.

Alternative (b)

14. The conclusion of the SA assessment of Alternative (b) is that this alternative settlement pattern would help to deliver housing needs, but could lead to possible conflicts with the protection of nature conservation interests (SA Objectives 2) and raises the potential of some negative impacts on the support for local transport infrastructure, including sustainable transport (SA Objective 8). There are considered to be uncertain impacts on the protection of the landscape, the character of the built environment and cultural heritage (SA Objectives 1, and 3), and the sustainable use of resources (SA Objective 4). Whilst this approach is considered to be more sustainable than Alternative (a), it is considered to be a less sustainable settlement pattern than the spatial strategy outlined in Policy SP4.

15. Extending the settlement hierarchy to include other larger villages would increase the likelihood of new housing being located close to the internationally designated nature conservation areas. These designated sites are protected by the Habitats Regulations and make up more than half of the land in the National Park. Natural England have advised that it is not appropriate to plan for new housing allocations close to these designated sites. Many of the villages which are a little smaller than the four defined villages, such as Burley, are located within close proximity of the designated nature conservation sites. Moreover, the proposed allocated housing sites in East Boldre had to be withdrawn from the Local Plan and the housing allocation in Sway was substantially reduced for this reason. Under these circumstances, Alternative (b) is likely to be a less sustainable approach than the spatial strategy outlined in Policy SP4.

16. Brockenhurst, Sway and Ashurst benefit from frequent and long distance railway services and also have regular bus services. Extending the settlement hierarchy to including smaller villages is likely to reduce the amount of sustainable transport available to residents, and therefore be detrimental for SA Objective 8. Moreover, a more dispersed population would be likely to increase the need to travel to work, shops, doctors and schools. Consequently there would be greater concern over the possible impacts on carbon emissions and climate change, and a less sustainable use or resources than in Policy SP4.

17. The SA assessment considers that the approach to locating new development in a number of smaller villages may have an adverse impact on the character of the built environment. The distinct character of New Forest villages and their close relationship with the open countryside, which is often integrated right into settlements, means that new buildings face a significant challenge to be sympathetically incorporated into the existing built environment. Opportunities to integrate a substantial amount of new buildings in smaller villages may be limited, and there is a risk that the distinct character of the villages are eroded. For instance, with no settlement boundary currently for Burley, the village is characterised by large amounts of green spaces and fingers of open countryside throughout the village. If a settlement boundary was established, the rural and Forest character of the village would likely to disappear with substantial amounts of in-filling. Under these circumstances, Alternative (b) is likely to be more sustainable than Alternative (a), but it is considered to be a less sustainable settlement pattern than the spatial strategy outlined in Policy SP4.

18. Alternative (b) may not result in a substantial impact on the landscape, but this is still a possibility. Opportunities to find sufficient building sites within the smaller villages may not be sufficient to be able to integrate new developments into the existing settlement. Therefore, there remains a risk that new development could have an impact on the open countryside and the landscape setting of the village. In these circumstances it is considered that the risk of an adverse impact on the landscape is less than Alternative (a) but is more than the spatial strategy outlined in Policy SP4.

19. Whilst a more dispersed settlement approach is likely to mean businesses are developed in less sustainable locations, new development in smaller settlements could support local businesses and services, provide jobs and strengthen those communities. Focusing new development on the four defined villages may mean that the housing or employment and development needs of other communities may not be fully met.

20. There are other sustainability issues to consider. One of the other villages considered in Alternative (b) is Cadnam, and there are areas within this village which are particularly vulnerable to surface flooding, which would limit the potential for new development.