Habitats Regulations Assessment of New Forest NPA Local Plan Reg 19

Habitats Regulations Assessment of New Forest National Park Local Plan 2016-2036

Assessment of Regulation 19 Submission Draft

Prepared by LUC

January 2018

Project Title: HRA of New Forest National Park Local Plan 2016-2036

Client: New Forest National Park Authority

Version	Date	Version Details	Prepared by	Checked by	Approved by
1.0	14 November 2017	Draft for client review	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen
2.0	17 November 2017	Draft for client review: Addition of Table A5.1 + changes to Chapter 5 re. offsite supporting habitat for Dartford warbler	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen
3.0	27 November 2017	Revised draft, responding to client comments received 23/11/17	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen
4.0	1 December 2017	Revised draft, reflecting changes made to Local Plan in response to recommendations of V3.0 HRA and revised approach to collision risk screening	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen
5.0	5 December 2017	Revised draft, reflecting changes made to Local Plan in response to recommendations of V4.0 HRA in relation to Solent water quality	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen
6.0	5 January 2018	Amended text to reference separate HRA of air pollution effects; updated reference to Solent Recreation Mitigation Strategy	Jonathan Pearson David Green	Jonathan Pearson Jeremy Owen	Jeremy Owen

HRA of New Forest NPA Local Plan_Reg 19.docm Last saved: 05/01/2018 16:49

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Contents

• 1 Introduction
• 2 The Local Plan
• 3 HRA Screening methodology
• 4 HRA Screening findings
• 5 Appropriate Assessment
• 6 Summary and conclusions
• Appendices

1 Introduction

LUC has been commissioned by New Forest National Park Authority (NFNPA’ or ‘the Authority’) to carry out a Habitats Regulations Assessment (HRA) of its Local Plan 2016-2036. This report presents the methodology and findings of that HRA.

Background to preparation of the Local Plan 2016-2036

The Government has made National Park Authorities the sole planning authorities for their areas, including responsibilities for plan-making, enforcement, development control and minerals and waste planning. The planning system is a vital tool in helping to deliver the two statutory purposes of National Parks and the related socio-economic duty.

The first set of dedicated planning policies for the whole of the New Forest National Park was adopted in December 2010 in the form of a Core Strategy and Development Management Policies Development Plan Document.

The national planning system has changed significantly in recent years and NFNPA is therefore updating its planning policies to ensure that they continue to provide a clear framework for planning decisions in the Park. Once adopted, the 'Local Plan 2016-2036' will set out the planning framework for the National Park, including the scale and location of new development and the need to conserve the local distinctiveness of the area.

Development of the Local Plan 2016-2036 started in summer 2015 and included a formal public consultation on the main issues to be addressed. NFNPA also launched a 'Call for Sites' process through which landowners and other parties were invited to put forward land which they would like to be considered for development. In October 2016 NFNPA published a Draft Local Plan for an eight-week period of public consultation. In Spring 2017 NFNPA received advice from Natural England on the issue of greenfield residential development close to the protected habitats of the National Park. This led to re-assessment of a number of the proposed Local Plan housing site allocations. Between June and July 2017, NFNPA invited feedback on potential alternative housing sites and this informed the preparation of the Regulation 19 Submission draft of the Local Plan.

The indicative timetable for the remaining stages of preparation of the Local Plan 2016-2036 is for Regulation 19 consultation on the Regulation 19 Submission draft in early 2018, submission to the Secretary of State in April 2018, Examination in Summer 2018, and Adoption in late 2018.

The requirement to undertake Habitats Regulations Assessment of development plans

The requirement to undertake HRA of development plans was confirmed by the amendments to the Habitats Regulations published for England and Wales in July 2007 and updated in 2010 and again in 2012. Therefore, when preparing its Local Plan NFNPA is required by law to carry out an HRA although consultants can undertake the HRA on its behalf. The requirement for authorities to comply with the Habitats Regulations when preparing a Local Plan is explained in the government’s online planning practice guidance.

The HRA refers to the assessment of the potential effects of a development plan on one or more European sites, including Special Protection Areas (SPAs) and Special Areas of Conservation (SACs).

• SACs are designated under the European Habitats Directive and target particular habitat types (Annex 1) and species (Annex II) (excluding birds).
• SPAs are classified in accordance with the Birds Directive for rare and vulnerable birds (Annex I) and for regularly occurring migratory species.

Potential SPAs (pSPAs), candidate SACs (cSACs), Sites of Community Importance (SCIs) and Ramsar sites should also be included in the assessment.

• Ramsar sites support internationally important wetland habitats.

For ease of reference during HRA, these designations can be collectively referred to as European sites, despite Ramsar designations being at the international level.

The overall purpose of the HRA is to conclude whether or not a proposal or policy, or whole development plan, would adversely affect the integrity of the European site in question either alone or in combination with other plans and projects. This is judged in terms of the implications of the plan for the ‘qualifying features’ for which the site was designated (SACs – Annex I and II; SPAs – Annex I birds and regularly occurring migratory; Ramsar – reasons set out in the Information Sheet).

Significantly, HRA is based on the precautionary principle meaning that where uncertainty or doubt remains, an adverse impact should be assumed.

Stages of HRA

Table 1.1 summarises the stages typically involved in carrying out an HRA, based on various guidance documents.

Stage	Task	Outcome
Stage 1: Screening (the ‘Significance Test’)	Description of the plan. Identification of potential effects on European sites. Assessing the effects on European sites (taking into account potential mitigation provided by other policies in the plan). Where effects are unlikely, prepare a ‘finding of no significant effect report’. Where effects judged likely, or lack of information to prove otherwise, proceed to Stage 2.	Where effects are unlikely, prepare a 'finding of no significant effect' report. Where effects judged likely, or lack of information, proceed to Stage 2.
Stage 2: Appropriate Assessment (the ‘Integrity Test’)	Gather information (plan and European sites). Impact prediction. Evaluation of impacts in view of conservation objectives. Where impacts considered to affect qualifying features, identify alternative options. Assess alternative options. If no alternatives exist, define and evaluate mitigation measures where necessary. Appropriate Assessment report describing the plan, European site baseline conditions, the adverse effects of the plan on the European site, how these effects will be avoided through, firstly, avoidance, and secondly, mitigation including the mechanisms and timescale for these mitigation measures. If effects remain after all alternatives and mitigation measures have been considered proceed to Stage 3.	Appropriate Assessment report and mitigation options. If effects remain, proceed to Stage 3.
Stage 3: Assessment where no alternatives exist and adverse impacts remain taking into account mitigation	Identify and demonstrate ‘imperative reasons of overriding public interest’ (IROPI). Demonstrate no alternatives exist. Identify potential compensatory measures.	This stage should be avoided if at all possible. The test of IROPI and the requirements for compensation are extremely onerous.

It is normally anticipated that an emphasis on Stages 1 and 2 of this process will, through a series of iterations, help to ensure that potential adverse effects are identified and eliminated through the inclusion of mitigation measures designed to avoid, reduce or abate effects. The need to consider alternatives could imply more onerous changes to a plan document. It is generally understood that so called ‘imperative reasons of overriding public interest’ (IROPI) are likely to be justified only very occasionally and would involve engagement with both the Government and European Commission.

In assessing the effects of the Local Plan in accordance with Regulation 102 of the Conservation of Habitats and Species Regulations 2012, there are potentially two tests to be applied by the competent authorities: a ‘Significance Test’, followed if necessary by an Appropriate Assessment which will inform the ‘Integrity Test’. The relevant sequence of questions is as follows:

1. Step 1: Under Reg. 102(1)(b), consider whether the plan is directly connected with or necessary to the management of the sites; if not proceed to Step 2.
2. Step 2: Under Reg. 102(1)(a) consider whether the plan is likely to have a significant effect on the site, either alone or in combination with other plans or projects (the ‘Significance Test’). If so proceed to Step 3.
3. Step 3: Under Reg. 102(1), make an Appropriate Assessment of the implications for the site in view of its current conservation objectives (the ‘Integrity Test’). In so doing, it is mandatory under Reg. 102(2) to consult Natural England, and optional under Reg. 102(3) to take the opinion of the general public.
4. Step 4: In accordance with Reg. 102(4), but subject to Reg. 103, give effect to the land use plan only after having ascertained that the plan will not adversely affect the integrity of the European site.

The HRA should be undertaken by the ‘competent authority’, in this case NFNPA, and LUC has been commissioned to do this on the Authority’s behalf. The HRA also requires close working with Natural England as the statutory nature conservation body in order to obtain the necessary information and agree the process, outcomes and any mitigation measures. The Environment Agency, while not a statutory consultee for HRA, is also in a strong position to provide advice and information throughout the process as it is required to undertake HRA for its existing licences and future licensing of activities. Consultation has also been undertaken with relevant, non-governmental conservation organisations, as described later in this report.

HRA work carried out previously

HRA of the adopted development plan: The adopted development plan for New Forest National Park was subject to HRA throughout its development. The final HRA documents for the adopted plan are:

• New Forest National Park Authority Core Strategy and Development Management Policies Habitat Regulations Assessment Report (Scott Wilson, January 2010).
• New Forest National Park Authority Core Strategy and Development Management Policies Habitat Regulations Assessment Report – Addendum (Scott Wilson, May 2010).

The adopted SPD on ‘Development Standards’ (September 2012) also provides relevant information in relation to avoiding significant effects on the integrity of European sites as a result of implementing the adopted Core Strategy. In addition, an HRA Screening Report was prepared by the New Forest NPA in July 2015 in relation to the National Park Management Plan 2015-2020.

This body of work relating to New Forest National Park was drawn on, as appropriate, in carrying out the HRA of the Local Plan 2016-2036.

HRA at earlier stages of the Local Plan 2016-2036: The HRA process for the Local Plan 2016-2036 began with the production in April 2016 by LUC of a non-statutory HRA Scoping Report, which was jointly prepared with New Forest District Council (NFDC) to inform the approach to HRA of both the New Forest National Park Authority (NFNPA) Local Plan and the NFDC Local Plan. The proposed approach to HRA set out in this joint scoping document was subject to consultation with Natural England, the RSPB, Hampshire and Isle of Wight Wildlife Trust (HIWWT), Dorset Wildlife Trust, Wiltshire Wildlife Trust, and NFDC during April-May 2016. Table A4.1 of Appendix 5 sets out the comments received and LUC’s responses to these.

In August 2016 LUC then prepared an HRA Discussion Document that responded to consultation comments on the HRA Scoping Report and provided initial observations on the potential for development proposals in NFNPA’s Draft Local Plan to have adverse effects on European sites, as well as commenting on mitigation available from the emerging Local Plan and from NFNPA’s existing recreation mitigation strategy. This supported further informal consultation with Natural England.

Structure of this report

This chapter has introduced the requirement to undertake HRA of the Local Plan. The remainder of the report is structured as follows:

• Chapter 2: The Local Plan – summarises the content of the Regulation 19 Submission draft of the New Forest National Park Local Plan.
• Chapter 3: HRA Screening methodology – sets out the approach used and the specific tasks undertaken during the screening stage of the HRA.
• Chapter 4: HRA Screening findings – describes the findings of the screening stage of the HRA.
• Chapter 5: Appropriate Assessment – sets out the methodology and findings of the Appropriate Assessment stage of the HRA.
• Chapter 6: Summary and conclusions – summarises the findings of the HRA of the Regulation 19 Submission draft of the Local Plan and provides its overall conclusions.

Appendices to this report contain information on the European sites scoped into the HRA (Appendix 1); recreation pressure in the New Forest (Appendix 2); other relevant plans and projects that could have effects in combination with the New Forest National Park Local Plan (Appendix 3); the detailed results of the initial screening of individual Local Plan policies and site allocations (Appendix 4); stakeholder comments received at earlier stages of the HRA process and how these have been taken into account (Appendix 5); and additional information relating to the Appropriate Assessment of loss or damage to offsite supporting habitat (Appendix 6).

2 The Local Plan

As part of its statutory planning role, NFNPA is required to prepare, monitor and review a Local Plan for the National Park. Once adopted, the Local Plan will form part of the statutory development plan (alongside any Neighbourhood Plans and the separate Minerals and Waste Local Plan) for the New Forest and is the principal guide for planning decisions within the National Park. The Local Plan focuses on the area within the National Park boundary. New Forest District Council, Wiltshire Council and Test Valley Borough Council are responsible for preparing the development plans for their respective planning areas outside the National Park.

The policies in the Local Plan include both strategic policies (prefixed with ‘SP’) and more detailed development management policies (prefixed with ‘DP’). The structure and policies of the Local Plan are summarised in Table 2.1. Outlines of relevant elements of the provisions of the individual policies are provided in the screening matrix in Appendix 4.

Chapter	Policies
Chapter 1. Introduction	Contains no policies
Chapter 2. Profile of New Forest National Park	Contains no policies
Chapter 3. Vision and objectives	Contains no policies
Chapter 4. Strategic policies and development principles	Policy SP1: Supporting sustainable development Policy DP2: General Development Principles Policy SP3: Major Development in the National Park Policy SP4: Spatial Strategy
Chapter 5. Protecting and Enhancing the Natural Environment	Policy SP5: Nature Conservation Sites of International Importance Policy SP6: The Natural Environment Policy SP7: Landscape Character Policy DP8: Safeguarding and Improving Water Resources Policy SP9: Green Infrastructure Policy DP10: Open Space Policy SP11: Climate Change Policy DP12: Flood Risk Policy DP13: Coastal Development Policy SP14: Renewable Energy Policy SP15: Tranquillity
Chapter 6. Protecting and Enhancing the Historic and Built Environment	Policy SP16: The Historic and Built Environment Policy SP17: Local Distinctiveness Policy DP18: Design Principles
Chapter 7. Vibrant Communities	Policy SP19: New residential development in the National Park Policy SP20: Specialist Housing for Older People (Use Class C2) Policy SP21: The size of new dwellings Policy SP22: Land at Whartons Lane, Ashurst Policy SP23: Land at the former Lyndhurst Park Hotel, Lyndhurst Policy SP24: Land south of Church Lane, Sway Policy SP25: Land adjacent to the former Fawley Power Station Policy SP26: Land at Calshot Village Policy SP27: Affordable Housing provision within the defined villages and on allocated sites Policy SP28: Rural Exceptions Sites Policy SP29: New Forest Commoners Dwellings Policy SP30: New Forest Estate Workers Dwellings Policy DP31: Agricultural and Forestry Workers Dwellings Policy DP32: Removal of Agricultural Occupancy Conditions Policy SP33: Gypsies, Travellers and Travelling Showpeople Policy DP34: Residential Character of the Defined Villages Policy DP35: Replacement Dwellings Policy DP36: Extensions to Dwellings Policy DP37: Outbuildings Policy SP38: Infrastructure Provision and Developer Contributions Policy SP39: Local Community Facilities Policy DP40: Change of Use from retail in the Defined Villages Policy DP41: Retail Development outside the Defined Villages
Chapter 8. A Sustainable Local Economy	Policy SP42: Business and Employment Development Policy SP43: Existing Employment Sites Policy DP44: Redevelopment of Existing Employment Sites Policy DP45: Extensions to Non Residential Buildings and Uses Policy SP46: Tourism Development Policy DP47: Holiday Parks and Camp Sites Policy SP48: The Land-based Economy Policy DP49: Re-use of Buildings outside the defined villages Policy DP50: Agricultural and Forestry Buildings Policy DP51: Recreational Horse Keeping Policy DP52: Field Shelters and Stables Policy DP53: Maneges
Chapter 9. Transport and Access	Policy SP54: Transport Infrastructure Policy SP55: Access
Chapter 10. Monitoring and Implementation	Contains no policies

3 HRA Screening methodology

HRA Screening of the Local Plan has been undertaken in line with current available guidance and good practice in order to meet the requirements of the Habitats Regulations. The tasks that have been undertaken during the screening stage of the HRA are described below.

Identification of European sites which may be affected

European sites included in the previous HRA work for the New Forest National Park: In the HRA work undertaken previously for NFNPA’s adopted Core Strategy and Development Management Policies DPD, the following eight European sites were included:

• The New Forest SAC;
• New Forest SPA;
• The New Forest Ramsar site;
• Solent Maritime SAC;
• Solent and Isle of Wight Lagoons SAC;
• Solent and Southampton Water SPA;
• Solent and Southampton Water Ramsar site;
• Mottisfont Bats SAC.

Mottisfont Bats SAC was originally scoped out of the HRA but was later included in the assessment following a consultation response from Natural England which advised that the SAC should be included in the scope of the HRA, due to the distance over which the qualifying bat species are known to commute for foraging.

Six European sites that had originally been included within the scope of the HRA for the Core Strategy were screened out at the Submission stage (River Avon SAC, Avon Valley SPA, Avon Valley Ramsar site, Dorset Heaths SAC, Dorset Heathlands SPA and Dorset Heathlands Ramsar site) for reasons explained in adopted HRA and agreed with Natural England.

European sites to be included in the HRA for the new Local Plan: Since Natural England did not object to the list of European sites considered in the HRA of the adopted Core Strategy and Development Management Policies DPD, the joint HRA Scoping Report for the NFNPA and NFDC Local Plans initially proposed that the same eight sites be included in the HRA work for NFNPA’s new Local Plan for the same reasons. This was subject to the caveat that if at any point information gathered during the HRA indicated that other European sites could be affected by either Local Plan, they would be considered in the assessment(s) as appropriate.

Further consideration of potential mechanisms for effects of the Local Plan, as documented in an internal HRA Discussion Document, and further consultation with Natural England and other stakeholder bodies indicated that the Avon Valley and Dorset Heathlands European designations should be scoped in to the HRA of the NFNPA Local Plan on a precautionary basis. This was because of the potential for loss of supporting habitat for qualifying bird populations (Avon Valley SPA and Ramsar site, Dorset Heathlands SPA), potential air quality effects due to traffic growth on roads outside of the National Park boundary (Dorset Heaths SAC and Dorset Heathlands Ramsar site), potential recreation pressure (Avon Valley SPA and Ramsar site, Dorset Heaths SAC and SPA), and potential water quality effects from treated wastewater discharges (River Avon SAC, Avon Valley SPA, Avon Valley Ramsar site). Consultation on the HRA Scoping Report also identified a need to consider the potential for the Local Plan to have adverse effects on the River Itchen SAC in relation to water supply/changes in water quantity. Finally, Solent and Dorset Coast potential SPA (pSPA) was subject to formal consultation until January 2017 on its possible designation to protect marine feeding areas used by designated birds and has also been scoped into the HRA.

The European sites that have been considered in the HRA of the Local Plan are therefore as follows:

• River Avon SAC;
• Avon Valley SPA;
• Avon Valley Ramsar site;
• Dorset Heaths SAC;
• Dorset Heathlands SPA;
• Dorset Heathlands Ramsar site;
• Mottisfont Bats SAC;
• The New Forest SAC;
• New Forest SPA;
• The New Forest Ramsar site;
• River Itchen SAC;
• Solent and Dorset Coast pSPA;
• Solent and Isle of Wight Lagoons SAC;
• Solent Maritime SAC;
• Solent and Southampton Water SPA;
• Solent and Southampton Water Ramsar site.

Locations of sites are shown on a map in the original document. Designated features and conservation objectives of the European sites, together with current pressures on and potential threats to these are described in Appendix 1. This information was drawn from the Standard Data Forms for SACs and SPAs and the Information Sheets for Ramsar Wetlands published on the JNCC website (www.jncc.defra.gov.uk), Natural England’s Site Improvement Plans, conservation objectives (SACs and SPAs) on the Natural England website, and consultation information for potential marine SPAs published by DEFRA.

Approach to HRA Screening

As required under Regulation 102 of the Conservation of Habitats and Species Regulations 2010 an assessment has been made of the ‘likely significant effects’ of the Local Plan. A risk-based approach involving the application of the precautionary principle was adopted in the screening assessment, such that a conclusion of ‘no significant effect’ was only reached where it was considered very unlikely, based on current knowledge and the information available, that a policy or site allocation would have a significant effect on the integrity of a European site.

Initial screening assessment: An initial screening assessment was undertaken to identify which components of the Local Plan have the potential to have likely significant effects on European sites, either alone or in combination with other plans or projects and the results are recorded in the table in Appendix 4. This initial screening was undertaken prior to consideration of the mitigation which may be provided by other policies in the Local Plan or by other regulatory mechanisms. Where a policy does not have the potential to result in a likely significant effect, the relevant cell was shaded green and the policy screened out from any further assessment.

To reduce repetition and aid consistency, reasons for screening out policies were categorised according to the following scheme and reference made to these ‘reason codes’ in the ‘Justification’ column of the initial screening table:

• A. General statement of policy or general aspiration;
• B. Policy listing general criteria for testing the acceptability or sustainability of proposals;
• C. Proposal referred to but not proposed by the Local Plan;
• D. Environmental protection or site safeguarding policy;
• E. Policy or proposal which steers change in such a way as to protect European sites from adverse effects;
• F. Policy that cannot lead to development or other change;
• G. Policy or proposal that could not have any conceivable effect on a site;
• H. Policy or proposal the (actual or theoretical) effects of which cannot undermine the conservation objectives of European sites (either alone or in combination with other aspects of this or other plans or projects).

Where a component of the Local Plan could potentially have a likely significant effect, the relevant cell was shaded orange and the types of effect and potentially affected European sites were highlighted. Each type of potential likely significant effect was then subject to further screening in Chapter 4, taking into account mitigation, in order to conclude whether likely significant effects could be ruled out.

Identification of other plans and projects which may have ‘in combination’ effects

Regulation 102 of the Habitats Regulations 2010 requires an ‘Appropriate Assessment’ where “a land use plan is likely to have a significant effect on a European site (either alone or in combination with other plans or projects) and is not directly connected with or necessary to the management of the site”. Therefore, as well as considering the likely effects of the Local Plan alone on European sites, it was necessary to consider whether there may be significant effects from the Local Plan in combination with other plans or projects.

The potential for ‘in combination’ effects need only be considered for those Local Plan components identified as unlikely to have a significant effect alone, but which could act in combination with other plans and projects to produce a likely significant effect. This approach accords with recent guidance on HRA.

The first stage in identifying potential in combination effects involves identifying which other plans and projects in addition to the Local Plan may affect the European sites that are the focus of the HRA.

Case law and guidance suggest that a plan or project at any of the following stages may be relevant to the in combination assessment:

• applications lodged but not yet determined;
• projects subject to periodic review e.g. annual licences, during the time that their renewal is under consideration;
• refusals subject to appeal procedures not yet determined;
• projects with consent but not yet started;
• projects started but not yet completed;
• known projects that do not need consent;
• proposals in adopted plans;
• proposals in finalised draft plans formally published or submitted for final consultation or adoption.

The review of other plans focused on Local Plans for authorities adjacent to New Forest National Park as well as Minerals Local Plans, Waste Local Plans and Local Transport Plans; the findings of any associated HRA work for those plans was also reviewed, if available.

Based on a review of the National Infrastructure Planning website and discussion with NFNPA, no other projects of significant scale that could result in in combination effects with the Local Plan were identified.

Appendix 3 presents the review of other plans and projects, outlining the components of each plan or project that could have an impact on nearby European sites and considering the findings of the accompanying HRA work, where available. Included authorities and plans are listed in Appendix 3.

While this HRA report has presented the initial screening results for each policy and site allocation individually, which is consistent with current guidance, the screening assessments also considered the potential for the effects of each Local Plan component to become significant in combination with other Local Plan components or with other plans and projects.

Mitigation

Some of the potential effects identified during the initial HRA Screening may be mitigated by other policies in the Local Plan, or by other plans or regulatory mechanisms. Such mitigation was referenced where relevant and taken into consideration in reaching the HRA conclusions. It is not appropriate for the HRA to rely solely on generic policy protection for European sites such as that provided by the first part of Local Plan Policy SP5: Nature Conservation Sites of International Importance since this does not provide sufficient certainty that the mitigation could be effectively delivered when implementing the screened in policies. This policy was therefore not relied upon in the HRA. Instead, the HRA took account of existing policies or regulatory mechanisms that directly address the identified potential effect.

Methodological points established via consultation on NFDC Local Plan Part 1: Following consultation on the joint HRA Scoping Report a number of methodological points were agreed with Natural England and other stakeholders and are summarised in the report. These include the treatment of indirect effects on supporting habitat (the HRA should be limited to considering direct loss of or damage to supporting habitat beyond European site boundaries); assumptions on supporting habitat for Avon Valley SPA; water quality and IWMS; traffic collision risk; and private sewerage screening distances (30 m rule and EA permitting within 50 m).

4 HRA Screening findings

A screening assessment was carried out to identify which components of the Local Plan have the potential to result in likely significant effects on European sites. The results of that initial screening are presented below followed by further assessment in relation to each type of potential likely significant effect identified in the initial screening.

Results of initial screening

The initial screening of each Local Plan component, prior to consideration of mitigation provided by other Local Plan policies or other policies or regulatory mechanisms, is detailed in Appendix 4.

It was found that likely significant effects, either from the policy alone or in-combination with other Local Plan policies or with other plans and projects, could be ruled out for most Local Plan components because the policies fell into one or more of the following screening categories:

• A. General statement of policy / general aspiration;
• B. Policy listing general criteria for testing the acceptability / sustainability of proposals;
• D. Environmental protection / site safeguarding policy;
• E. Policy or proposal which steers change in such a way as to protect European sites from adverse effects;
• F. Policy that cannot lead to development or other change.

Some Local Plan components, however, required further assessment including consideration of available mitigation, before a screening conclusion could be reached. The Local Plan policies for which the initial screening identified a potential for likely significant effects and the types of potential effect identified are summarised in Table 4.1 below. The following section then considers each of these types of potential likely significant effect from the screened in components of the Local Plan in more detail, identifies the European sites potentially affected, and concludes whether further evidence gathering and/or an Appropriate Assessment is required.

Screened in policy	Amount, type and location of development	Potentially significant effects
Policy SP4: Spatial Strategy	The ‘Defined Villages’ of Ashurst, Brockenhurst, Lyndhurst, and Sway are the main focus for development of housing, employment, retail and community facilities	Direct loss or physical damage to European sites Loss or damage to offsite supporting habitat Urban edge effects Changes in air quality Traffic collision risk Recreation pressure Changes in water quantity Changes in water quality
Policy SP19: New residential development in the National Park	800 dwellings comprising site allocations (300); extant planning permissions (100); windfalls (400)	As for Policy SP4
Policy SP20: Specialist Housing for Older People (Use Class C2)	Specialist housing for older people to be focussed in the Defined Villages	As for Policy SP4
Policy SP22: Land at Whartons Lane, Ashurst	60 dwellings	As for Policy SP4
Policy SP23: Land at the former Lyndhurst Park Hotel, Lyndhurst	50 dwellings + tourism use	As for Policy SP4
Policy SP24: Land south of Church Lane, Sway	40 dwellings on part of site more than 400 m from New Forest SPA	As for Policy SP4
Policy SP25: Land adjacent to the former Fawley Power Station	120 dwellings, habitat mitigation, supporting infrastructure, community facilities (including a primary school)	As for Policy SP4
Policy SP26: Land at Calshot Village	30 dwellings + cemetery use	As for Policy SP4
Policy SP33: Gypsies, Travellers and Travelling Showpeople	1 additional pitch	As for Policy SP4

The locations of the development allocations made by Policies SP22–SP26 and Policy SP33 are illustrated in Figures 4.1 to 4.5 in the original document.

Assumptions and information used in further screening

There are many uncertainties associated with assessing the potential for particular types of development to significantly affect European sites therefore, to guide the assessment process and assist consistency and transparency, a number of assumptions were made. These primarily seek to establish ‘zones of influence’ within which certain types of effect are capable of being significant or relevant significance thresholds or limits. Where possible, reference was made to relevant standards or research but in many cases it was necessary to base the assumptions on professional judgement, discussion with stakeholders and current practice in HRA. The basis for the assumptions is documented in the assumptions section of each type of effect considered below. For the spatially specific components of the Local Plan, screening for many of the potential types of likely significant effects was carried out using GIS data to determine the proximity of development locations to the scoped-in European sites; these distances were then compared to the assumed zones of influence.

Direct loss or physical damage to European sites

This HRA topic considers the potential effects of the development proposed by the Local Plan in terms of direct loss of or physical damage to designated habitats or direct mortality of designated species.

HRA Screening assumptions

It was assumed that it would not be possible to rule out likely significant effects prior to mitigation if a Local Plan policy or site allocation would result in development which overlaps with any European site.

Habitat loss/damage and mortality of designated species on site only needed to be considered in relation to the European sites that intersect with the Local Plan area, i.e.:

• River Avon SAC;
• Solent and Isle of Wight Lagoons SAC;
• Solent Maritime SAC; Solent and Southampton Water SPA and Ramsar site;
• The New Forest SAC and Ramsar site; New Forest SPA.

Any amount of development proposed by the Local Plan within the boundary of a European site was assumed to give rise to a likely significant effect therefore consideration of in combination effects at the HRA Screening stage was not required.

Potential for likely significant effects from Local Plan prior to mitigation

The allocated development sites in the Local Plan do not overlap any European sites.

Policy SP4: Spatial Strategy and Policy SP20: Specialist Housing for Older People directs most development to within the defined settlement boundaries of Ashurst, Brockenhurst, Lyndhurst, and Sway where it would also avoid European sites. While the Spatial Strategy also allows for development outside of allocated sites and the four Defined Villages (for example under Policy SP28: Rural Exception Sites), this is more appropriately assessed via project level HRA as specific proposals come forward, as described in the initial screening of spatially non-specific development policies in Appendix 4.

Mitigation provided by the Local Plan

No mitigation measures are included in the Local Plan that are specific to the policies screened in by the initial HRA Screening or to the types of potential effect identified.

Conclusions and recommendations

Likely significant effects due to direct loss or physical damage due to construction within the boundaries of European sites can be ruled out.

Loss or damage to offsite supporting habitat

This section of the HRA Screening examines the potential for direct loss of or physical damage by development to habitats that are located beyond designated site boundaries but which are relied upon by designated species populations of scoped-in European sites.

HRA Screening assumptions

It was assumed that it would not be possible to rule out likely significant effects prior to mitigation if a Local Plan policy or site allocation would result in development that:

• is used by the qualifying bird populations of Avon Valley SPA and Ramsar site; Dorset Heathlands SPA; New Forest SPA; Solent and Dorset Coast pSPA; or Solent and Southampton Water SPA and Ramsar site; or
• overlaps offsite habitat areas of importance to the qualifying bat population of Mottisfont Bats SAC. Based on the SAC’s ‘Protocol for Planning Officers’, HRA Screening assumed that likely significant effects prior to mitigation cannot be ruled out for any development within 7.5 km of the SAC which would result in loss of or damage to open water, deciduous woodland, riparian, or unimproved grassland habitats or in construction of a significant linear feature such as a new road.

Any amount of development proposed by the Local Plan within an area of potential supporting habitat was assumed to give rise to a likely significant effect, therefore consideration of in combination effects at the HRA Screening stage was not required.

Potential for likely significant effects from Local Plan prior to mitigation

Supporting habitat for qualifying birds: The Local Plan allocates a number of development sites in areas where qualifying bird species may make use of offsite habitat for foraging, roosting and loafing. The European sites’ bird populations that could potentially be affected are those that are qualifying features of Avon Valley SPA and Ramsar site, Dorset Heathlands SPA, New Forest SPA, or Solent and Southampton Water SPA and Ramsar site. In line with comments provided by Natural England and HIWWT during the consultation process, a detailed desk-based study was necessary to determine whether adverse effects on the integrity of these sites could be ruled out.

Supporting habitat for qualifying bats: The Local Plan does not allocate any development sites within 7.5 km of the Mottisfont Bats SAC. Mitigation available: No mitigation measures are included in the Local Plan that are specific to the policies screened in by the initial HRA Screening or to the types of potential effect identified.

Conclusions and recommendations

Supporting habitat for qualifying birds: Likely significant effects cannot be ruled out from the Local Plan site allocations on offsite habitat used by the qualifying bird species of the Avon Valley SPA and Ramsar site, Dorset Heathlands SPA, New Forest SPA, or Solent and Southampton Water SPA and Ramsar site. An Appropriate Assessment was therefore carried out, as described in Chapter 5.

Supporting habitat for qualifying bats: Based on the absence of proposed development within the 7.5 km zone of influence defined by the Mottisfont Bats SAC ‘Protocol for Planning Officers’, likely significant effects can be ruled out.

Urban edge effects

A variety of different types of effect are associated with increased human populations close to sensitive European sites (e.g. noise pollution, light pollution, increased numbers of predators such as foxes and crows, increased incidence of fires, etc.). This HRA topic considers the potential effects of the Local Plan relating to these ‘urban edge effects’.

HRA Screening assumptions

Based on the HRA work carried out for adopted Local Plan documents plus discussion with Natural England, the most important types of urban edge effect in the context of development in the New Forest National Park are thought to be:

• Cat predation - hunting by domestic cats;
• Increased fly-tipping - particularly risk of introduction of invasive alien species from garden waste.

It was therefore assumed that the potential for urban edge effects to be significant only exists for residential development (including gypsy and traveller sites and rural exception sites but excluding visitor accommodation/tourism use as it is unlikely that these will be associated with cats on the premises or domestic garden waste). The HRA Screening assumed that likely significant effects cannot be ruled out, prior to mitigation, if residential development will occur within 400 m of European sites with qualifying features sensitive to these types of effect. Based on their designated features and the pressures and threats facing them (see Appendix 1), these were judged to be:

• Dorset Heaths SAC and SPA (but effects on these can be ruled out as the Local Plan area is more than 400 m from the European site boundaries); and
• New Forest SAC and SPA.

A distance of 400 m was chosen because:

• New Forest SPA is located within New Forest National Park and Policy CP1 of the adopted Core Strategy for New Forest NPA, which was agreed with Natural England, states that any housing that is proposed to be located within 400 metres of the boundary of the New Forest Special Protection Area (SPA) will be required to demonstrate that adequate measures are put in place to avoid of mitigate any potential adverse effects on the ecological integrity of the SPA.
• Natural England’s view, documented in The Dorset Heathlands Planning Framework 2015–2020, is that residential development within 400 m of the Dorset Heathlands European designations is likely to have a significant adverse effect, either alone or in combination with other developments due to a variety of ‘urban effects’, including cat predation of ground nesting birds.
• Natural England confirmed at a New Forest HRA stakeholder meeting on 9/8/16 that it is happy with the use of a 400 m distance when screening for potential ‘urban edge effects from construction or occupation of buildings’ on heathland sites.

It should be noted that while the Dorset Heathlands SPA has a number of similar designated features to New Forest SPA, the New Forest SPA is considered to be more resilient and hence less likely to suffer adverse effects on its integrity as a result of the potential harmful effects of housing within 400 m of its boundary. This is because New Forest SPA provides a larger (more than three times the area) and less fragmented area of habitat than the Dorset Heathlands SPA and therefore has a much lower edge to area ratio, so that urban edge effects are likely to be much less pronounced. As a National Park the New Forest National Park also has a more developed system of habitat and visitor management than Dorset Heathlands SPA. These important differences mean that a different approach to urban edge effects is justifiable in the New Forest compared to the virtual ban on housing development within 400 m of Dorset Heathlands SPA imposed by the Dorset Heathlands Planning Framework.

Potential for likely significant effects from Local Plan prior to mitigation

In total, the Draft Local Plan (Policy SP19) provides for 800 new dwellings to be delivered in the National Park between 2016 and 2036, comprising 300 dwellings on allocated sites, 100 dwellings from the implementation of extant planning permissions, and 400 dwellings from windfall development (unidentified or unallocated sites).

Three of the Local Plan residential or mixed-use allocations are located within the 400 m zone of influence for urban edge effects on New Forest SAC and SPA, and therefore have the potential for likely significant effects on that European site. These are:

• Land at the former Lyndhurst Park Hotel, Lyndhurst (Policy SP23) – wholly within 400 m zone;
• Land south of Church Lane, Sway (Policy SP24) – strip of land along north eastern edge of site within 400 m zone; and
• Gypsies, Travellers and Travelling Showpeople (Policy SP33) – existing gypsy site at Forest View, Landford is adjacent to the New Forest SAC.

Proposals with extant planning permissions will have been subject to project level HRA if required and to the adopted Core Strategy Policy CP1 which requires that adequate measures are put in place to avoid or mitigate any potential adverse effects on the ecological integrity of the SAC and SPA so it is assumed that this development will not give rise to likely significant effects.

In addition to Local Plan allocations, some of the 400 dwellings estimated to come forwards within the plan period as windfall development are likely to be within the 400 m zone of influence for urban edge effects on New Forest SAC and SPA. This is particularly likely since Policy SP4: Spatial Strategy prioritises development in the four Defined Villages (Ashurst, Brockenhurst, Lyndhurst, and Sway), all of which are partially within the 400 m zone of influence. The housing provision to be met by windfalls equates to an average of 20 new dwellings per annum and individual windfall development proposals are therefore likely to be substantially smaller. In contrast, Local Plan allocations are used to bring forward larger scale developments with site allocations ranging in size from 30 dwellings to 120 dwellings.

Due to the expected small scale and wide distribution of individual windfall developments it was judged that these are not likely to give rise to significant urban edge effects on New Forest SAC or SPA, either individually or in combination with other windfall developments within 400 m of the New Forest SAC and SPA. This approach is also broadly consistent with the approach to ‘Urbanisation’ effects that was found to be acceptable in the HRA of the adopted NFNPA Core Strategy. In the event that a larger number of windfall dwellings were to come forward on a single site or closely related cluster of sites within 400 m of the New Forest SAC and SPA, reliance can be placed on the Habitats Regulations’ requirement for individual projects to also be subject to HRA.

Mitigation available

As noted earlier it is not considered appropriate for the HRA to rely solely on the generic protection for European sites offered by Policy SP5: Nature Conservation Sites of International Importance. It is nonetheless relevant to note that the policy states that avoidance or mitigation may not be possible in some cases due to the scale, type, or proximity of the proposed development in relation to European sites and that each case will therefore be assessed on its merits. Supporting text notes that if a larger number of windfall dwellings were to come forward on a single site or closely related cluster of sites within 400 m of the New Forest SAC and SPA, then the Authority will require the applicant to supply sufficient evidence for an Appropriate Assessment of the urban edge effects.

Policy SP5 highlights the opportunity for proposals to avoid or fully mitigate any likely significant effects on European sites by putting in place sufficient and effective measures and to secure mitigation via contributions to the Authority’s Habitat Mitigation Scheme and/or the Solent Recreation Mitigation Partnership’s Scheme. NFNPA’s revised Habitat Mitigation Scheme is, however, focussed on alleviating the potential in combination effects of recreation pressure on New Forest SAC, SPA and Ramsar site (which could arise from residential development or visitor accommodation anywhere in the Plan area) rather than urban edge effects (which could arise from residential development within 400 m of the New Forest SAC and SPA). The key elements of the revised scheme are: access management within the New Forest European designations; alternative recreation sites and routes outside the designated sites; education, awareness and promotion; monitoring and research; and in-perpetuity funding.

In LUC’s view, it is not possible to rule out the potential for urban edge effects such as cat predation or fly-tipping from residential allocations within 400 m of New Forest SAC or SPA by reliance on contributions to NFNPA’s Habitat Mitigation Scheme since it is not clear that any of the scheme elements would address these types of effect.

HRA of the Local Plan did not initially identify any policies that specifically addressed the potential urban edge effects from development of land at the former Lyndhurst Park Hotel, Lyndhurst (Policy SP23) or the additional gypsy and traveller pitch at Forest View, Landford (Policy SP33). This resulted in the Draft HRA making recommendations for additional safeguards within these policies and these have now been implemented as follows:

• Policy SP23 Land at the former Lyndhurst Park Hotel, Lyndhurst – the policy requires that development proposals incorporate measures to mitigate potential significant urban edge impacts on the adjacent protected habitats; supporting text notes that urban edge impacts to be considered include cat predation and the introduction of invasive species from fly-tipping of garden waste and that mitigation measures could include the use of legal covenants and arrangements for grounds maintenance.
• Policy SP33: Gypsies, Travellers and Travelling Showpeople - due to the proximity of the New Forest SAC, measures must be put in place to adequately mitigate the potential for the introduction of invasive species from fly tipping of garden waste.

Policy SP24 avoids the potential for likely significant urban edge effects by a stipulation that residential development on the site will be limited to the part of the site that is located more than 400 m from New Forest SPA; instead, informal recreation use is supported along the north eastern edge of the site that is within 400 m of the SPA.

Conclusions and recommendations

It was possible to rule out likely significant urban edge effects on New Forest SAC or SPA, from windfall development due to the expected small scale and wide distribution of individual windfall developments.

Specific risks were initially identified from the residential allocations within 400 m of New Forest SAC or SPA made by Policy SP23: Land at the former Lyndhurst Park Hotel, Lyndhurst and on New Forest SAC from the allocation of an additional gypsy and traveller pitch at Forest View, Landford (Policy SP33). This resulted in additional safeguards being added to these allocation policies, as described above.

Likely significant urban edge effects from the Local Plan can therefore be ruled out, either alone or in combination.

Changes in air quality

This HRA topic considers the potential effects of the Local Plan in terms of air pollution from new or more congested roads as a result of new development, resulting in toxic contamination or nutrient enrichment of habitats.

HRA Screening assumptions

Increased traffic flows as a result of the amount and broad location of development proposed by the Local Plan alone or in-combination with other drivers of traffic growth could adversely affect local air quality. This is a potentially significant issue for the HRA where roads are located close to European sites that are sensitive to air pollution (principally nitrogen deposition).

The assessment methodology in the Design Manual for Roads and Bridges (Department for Transport, 2007) states that there is a potential for likely significant effects where road corridors are within 200 m of a European site having interest features that are sensitive to changes in air quality.

Potential for likely significant effects from Local Plan prior to mitigation

Based on an examination of their interest features and their locations, scoped-in European sites that may be sensitive to changes in air quality that are within 200 m of major roads (motorways or ‘A’ roads) are:

• Dorset Heaths SAC and Dorset Heathlands Ramsar site;
• The New Forest SAC and Ramsar site; New Forest SPA;
• Solent Maritime SAC;
• Solent and Southampton Water SPA and Ramsar site.

Natural England’s Site Improvement Plans list air pollution in the form of atmospheric nitrogen deposition as a current pressure or future threat to all of these European sites.

A review of the Air Pollution Information System (APIS) website indicates that rates of Nitrogen deposition exceed critical loads for some sensitive features of Dorset Heaths SAC, The New Forest SPA, New Forest SPA; and Solent Maritime SAC.

An Air Quality Management Area (AQMA) has been designated in Lyndhurst High Street due to the presence of excessive transport related pollutants. Whilst AQMAs are designated to protect human health this nevertheless indicates the presence of existing high levels of nitrogen dioxide pollution in a location where 50 additional dwellings are allocated (Policy SP23) and which is adjacent to the New Forest European sites.

The Transport and Access section of the Local Plan states that there are high levels of commuter traffic crossing the Park, particularly from the surrounding areas. A significant proportion of the local workforce is either self-employed and work from home (about 11%) or commute to work outside the area, particularly to Southampton. Overall there is a significant net outflow of people from the National Park travelling to work in urban areas such as Southampton (providing employment for 15% of the National Park’s working population) and Bournemouth (providing employment for 8% of the National Park’s working population). The Local Plan also notes that road traffic volumes across the National Park are high, especially during the summer months, and that trends indicate a general increase each year on a number of routes.

The National Park receives an estimated 13.5 million visitor days each year, with the vast majority of both staying and day visitors using the car to reach their destination. Thus, while the amount of traffic growth associated with the small scale of development proposed by the Local Plan alone is unlikely to be significant, when this is combined with commuter and visitor traffic growth from neighbouring areas, roads within and close to the New Forest could experience a significant increase in road traffic and associated air pollution.

Mitigation available

The Local Plan resists major development within the National Park (Policy SP3) and seeks to direct most supported housing and employment development to its larger settlements, which have most services, facilities and local employment opportunities (Policy SP4), helping to reduce the need to travel. The Local Plan resists expansion of development of strategic transport infrastructure in the National Park (Policy SP54) which would include the strategic road network. It also supports appropriate improvements to more sustainable forms of transport (Policy SP55) which should help to limit road traffic growth.

Conclusions and recommendations

The development proposed by the Local Plan is small in scale and focussed on relatively sustainable locations adjacent to existing, larger settlements in New Forest National Park. This together with the support for more sustainable forms of transport and resistance to strategic transport development means it is reasonable to conclude that traffic growth and associated increases in air pollution from the Local Plan alone are unlikely to be significant. However, as acknowledged in the Local Plan, traffic flows within and across the National Park relating to visitors and commuters are large and growing.

It was therefore recommended that a more detailed examination of potential in-combination air quality effects on the Dorset Heaths, New Forest and Solent European sites listed above be carried out. In response, NFNPA and NFDC jointly commissioned third party consultants to carry out an air quality assessment and linked ecological assessment which are reported on separately and together constitute the HRA of air quality effects for both the New Forest National Park and New Forest District Local Plans; at the time of writing, these documents had not yet been finalised although draft results and conclusions are presented within them. The results and conclusions of the HRA in relation to changes in air quality are set out in those separate reports but for ease of reference their emerging draft conclusions are also summarised in the original HRA report.

Emerging findings: The draft air quality assessment concluded that it is not possible to discount the potential for significant effects in relation to increased NOx concentrations, nutrient nitrogen deposition, or increased ammonia concentrations without further analysis of the sensitivity of designated habitats to these impacts at identified locations.

The draft ecological assessment concluded as follows:

• The New Forest SAC, SPA and Ramsar site: Implementation of the NFNPA Local Plan and NFDC Local Plan in isolation is not likely to have a significant effect on the New Forest SAC, SPA and Ramsar site. In combination effects will result in exceedances for ammonia and acid deposition, although exceedance of critical loads/levels is also predicted in the absence of the Local Plans. Advice published by APIS indicates that site-specific information on the effects of ammonia and acid deposition on vegetation is limited. The ecological assessment therefore recommends that NFNPA and NFDC undertake periodic vegetation monitoring to determine the current condition of sensitive vegetation and to identify any changes that occur during the life of the two Local Plans (measured at appropriate intervals). The monitoring would need to be complemented by a mitigation strategy that sets out actions that will be implemented if required. Habitat management measures that can be used to mitigate the impact of airborne pollutants are also summarised in the ecological assessment.
• Dorset Heaths SAC and Dorset Heathlands SPA and Ramsar site: Implementation of the NFNPA Local Plan and NFDC Local Plan is not likely to have a significant effect on the Dorset Heaths SAC or the Dorset Heathlands SPA and Ramsar site. Although the resultant increase in traffic will result in localised exceedances of the screening criteria and critical levels or loads, this is likely to be mitigated in part by existing vegetation alongside roads. Where impacts do occur it is expected that they will be limited in their extent and area.
• Solent Maritime SAC: Implementation of the NFNPA Local Plan and NFDC Local Plan is not likely to have a significant effect on the Solent Maritime SAC. The modelling scenarios employed mean that this conclusion is also reached when considering the effects of the Local Plan in combination with other plans and projects.
• Solent and Southampton Water SPA and Ramsar site: Implementation of the NFNPA Local Plan and NFDC Local Plan is not likely to have a significant effect on the Solent and Southampton Water SPA and Ramsar site. The modelling scenarios employed mean that this conclusion is also reached when considering the effects of the Local Plan in combination with other plans and projects.

Traffic collision risk

Correspondence with Natural England identified a type of potential adverse effect not previously included in the joint HRA Scoping document for NFDC and NFNPA: development could result in an increase in traffic using Roger Penny Way (B3078 across the northern part of the New Forest) and roads near Hordle, making them unsafe for grazing animals and necessitating fencing along the roadsides. If fencing is needed to protect animals, changes to the grazing pattern in the New Forest could, without mitigation, lead to loss of open habitats for which New Forest SAC and Ramsar site is designated, with knock-on effects on New Forest SPA designated bird species and New Forest Ramsar site fauna reliant on those habitats. There is potential for similar problems to arise close to all road commuting routes across the New Forest where conservation grazing is important for habitat management.

HRA Screening assumptions

In the absence of any other benchmark, HRA Screening assumed that likely significant effects due to traffic collision risk cannot be ruled out where transport modelling indicates that road traffic growth from the Local Plan, alone or in-combination with other plans and projects, will exceed 8,000 AADT (the figure provided by the Design Manual for Roads and Bridges, volume 11, to indicate a scale of traffic flows on a new road that would begin to result in moderate severance of a community). This threshold was agreed with Natural England.

Potential for likely significant effects from Local Plan prior to mitigation

Hordle is some distance from the European sites of the New Forest and there is therefore limited potential for likely significant effects. In relation to Roger Penny Way, none of the development sites allocated by the Local Plan is close to this route. Small increases in traffic on Roger Penny Way may, however, result from windfall development and other routes crossing the New Forest European designations are also likely to see some traffic increases from the development proposed by the Local Plan.

While the amount of traffic growth associated with the small scale of development proposed by the Local Plan alone is unlikely to be significant, when this is combined with commuter and visitor traffic growth from neighbouring areas, roads within and close to the New Forest could experience a significant increase in road traffic.

Mitigation available

Local Plan policies will help to limit traffic growth, as described under ‘Changes in air quality’ above. It is assumed that traffic modelling represents the expected future traffic flows after the effects of these policies.

Conclusions and recommendations

The development proposed by the Local Plan is small in scale and focussed on relatively sustainable locations adjacent to existing, larger settlements in New Forest National Park. This together with the support for more sustainable forms of transport and resistance to strategic transport development means it is reasonable to conclude that traffic growth from the Local Plan alone is unlikely to be significant. However, as acknowledged in the Local Plan, traffic flows within and across the National Park relating to visitors and commuters are large and growing and there is therefore a potential for effects to be significant in combination.

At the time that the 8,000 AADT screening threshold for in combination traffic growth was agreed with Natural England it was anticipated that the air quality study would report traffic growth in a suitable format to allow identification of roads running within or alongside the New Forest European sites where traffic growth is forecast to exceed this figure. NFDC, which commissioned this joint work to inform HRA of both the New Forest District and National Park Local Plans, reports that the approach taken to traffic modelling means that these in combination traffic growth figures cannot readily be reported. The HRA has therefore assumed on a precautionary basis that in combination traffic growth may exceed 8,000 AADT and has proceeded to an Appropriate Assessment of the potential for traffic collision risk to adversely affect the integrity of the New Forest European designations.

Recreation pressure

This HRA topic considers the potential effects of the Local Plan in terms of:

• Designated species mortality or disturbance: direct mortality of ground nesting birds’ eggs or young by visitor trampling or dogs off leads; disturbance of ground nesting birds by recreational visitors and their dogs; mortality due to increased incidence of fires; mortality due to tipping/littering.
• Designated habitats loss or damage: path erosion or soil compaction by walkers, cyclists, horse riders etc.; eutrophication of soils by dog faeces; increased incidence of fires; tipping/littering.

HRA Screening assumptions

European sites scoped into the HRA which are judged to be vulnerable to recreation pressure, based on their designated features and the pressures and threats facing them (see Appendix 1) are:

• Avon Valley SPA;
• Avon Valley Ramsar site;
• Dorset Heaths SAC;
• Dorset Heathlands SPA;
• New Forest SAC;
• New Forest SPA;
• Solent Maritime SAC;
• Solent and Southampton Water SPA;
• Solent and Southampton Water Ramsar site.

The HRA therefore considered the potential for increased recreation pressure on these sites as follows.

Avon Valley SPA and Ramsar site: Dog walkers disturbing the designated population of Bewick’s Swan in areas outside public rights of way are identified by the Site Improvement Plan as a concern. It is understood that Natural England has not previously been concerned about recreational pressure on this site arising from development in the New Forest, due in part to very limited public access. The Gadwall population for which the SPA is also designated is focussed on Blashford Lakes Gravel Pits which is managed as a nature reserve so access is controlled. It also seems likely that the extensive outdoor recreation opportunities within the New Forest National Park and Solent Coast European sites exert a stronger pull on many residents of New Forest District and New Forest National Park than the Avon Valley.

The HRA therefore assumed that recreational users of the Avon Valley are overwhelmingly local and that a potential for a contribution to in combination recreational pressure on the Bewick’s Swan population only exists for any residential development or visitor accommodation within 1.0 km of Avon Valley SPA and Ramsar site.

Dorset Heaths SAC and SPA: Based on research into the behaviour of visitors to the Dorset Heaths and Natural England’s views documented in The Dorset Heathlands Planning Framework 2015–2020, the HRA assumed that prior to consideration of mitigation, all residential development or visitor accommodation within 5 km of Dorset Heaths SAC or Dorset Heathlands SPA is likely to have a likely significant effect in combination.

New Forest SAC and SPA: Prior HRA work for the NFDC Local Plan Part 2 which is also relevant to the HRA of the NFNPA Local Plan provides a detailed review of evidence on recreation pressure on New Forest SAC and SPA; key elements of this are reproduced in Appendix 2. The HRA of the NFDC Local Plan Part 2 concludes that whilst the best available evidence is inconclusive, the risk of residential development in New Forest District leading to increased visitor pressure on the New Forest European sites cannot be ruled out for development anywhere within New Forest District. Given that the National Park is surrounded by New Forest District, it is consistent to assume that such effects cannot be ruled out for development anywhere within New Forest National Park. This evidence remains valid and the HRA of the Local Plan therefore assumed that prior to mitigation, likely significant in combination effects on New Forest SAC and SPA cannot be ruled out for any residential development or visitor accommodation within New Forest National Park.

Solent Maritime SAC, Solent and Southampton Water SPA and Ramsar site: The Solent Disturbance and Mitigation Project (SDMP) has established that 75% of visitors to the Solent European sites come from within 5.6 km (as the crow flies) of Solent and Southampton Water SPA and recommends that avoidance and mitigation measures be sought for residential development within this zone of impact. The HRA therefore assumed that prior to mitigation, likely significant in combination effects on Solent Maritime SAC and Solent and Southampton Water SPA and Ramsar site cannot be ruled out for residential development or visitor accommodation within this zone.

Potential for likely significant effects from Local Plan prior to mitigation

Avon Valley SPA and Ramsar site: In line with the methodology described above, it is assumed that prior to mitigation, a potential for a contribution to in combination recreation pressure on the Bewick’s Swan population exists for any residential or visitor accommodation development within 1.0 km of Avon Valley SPA and Ramsar site. Only a few small areas of the National Park to the north of Ringwood and to the west of Bisterne fall within this distance of the Avon Valley SPA and Ramsar site. No development allocations are made to these areas and they are not identified by the spatial strategy as a focus for growth. Therefore it is judged that the Local Plan will not result in likely significant effects from recreation pressure on Avon Valley SPA and Ramsar site, either alone or in-combination.

Dorset Heaths SAC and SPA: In line with the methodology described above it is assumed that, prior to mitigation, likely significant effects in combination cannot be ruled out for any residential or visitor accommodation development within 5.0 km of Dorset Heaths SAC or SPA. Only a narrow band along the western edge of the National Park falls within this distance of the Dorset Heaths SAC or SPA. No development allocations are made to this area and it is not identified by the spatial strategy as a focus for growth therefore it is assumed that the Draft Local Plan will not result in significant recreation pressure on Dorset Heaths SAC or SPA either alone or in combination.

New Forest SAC and SPA: It is assumed that, prior to mitigation, likely significant effects in combination cannot be ruled out for any residential or visitor accommodation development within New Forest National Park. All of the 800 dwellings as well as the visitor accommodation provided for by the Local Plan are therefore assumed to contribute to recreation pressure on New Forest SAC and SPA.

Solent Maritime SAC, Solent and Southampton Water SPA and Ramsar site: It is assumed that, prior to mitigation, likely significant effects in combination cannot be ruled out for any residential or visitor accommodation development within 5.6 km of Solent Maritime SAC, Solent and Southampton Water SPA, and Solent and Southampton Water Ramsar site. The Draft Local Plan allocates the following development sites for residential or visitor accommodation within this zone of influence:

• Policy SP22 - Land at Whartons Lane, Ashurst (60 dwellings);
• Policy SP24 - Land south of Church Lane, Sway (40 dwellings);
• Policy SP25 - Land adjacent to the former Fawley Power Station (120 dwellings);
• Policy SP26 - Land at Calshot Village (30 dwellings).

Ashurst, Sway and most of Brockenhurst are within 5.6 km of the Solent designations – all forms of development including housing are directed to these Defined Villages (as well as to Lyndhurst, which is outside the 5.6 km zone) by Policy SP4: Spatial Strategy, making it likely that a significant proportion of the 400 windfall dwellings will be developed at these settlements. In addition visitor accommodation is supported at the Defined Villages by Policy SP46: Tourism Development. This development is also likely to add to recreation pressure on the Solent and Southampton Water European sites.

Mitigation available

Policy SP5: Nature Conservation Sites of International Importance refers to securing mitigation via contributions to the Authority’s Habitat Mitigation Scheme and/or the Solent Recreation Mitigation Partnership’s Scheme. NFNPA’s revised Habitat Mitigation Scheme is focused on alleviating the potential in combination effects of recreation pressure on New Forest SAC, SPA and Ramsar site. The key elements are access management, alternative recreation sites and routes, education, monitoring and in-perpetuity funding. The Solent Recreation Mitigation Strategy (Solent Recreation Mitigation Partnership) proposes measures for the Solent including coastal rangers, communications and education, encouraging responsible dog walking, codes of conduct, site-specific projects, alternative greenspaces and a partnership manager.

Policy SP9: Green Infrastructure supports creation and enhancement of green infrastructure, particularly where it increases habitat connectivity or relieves recreational pressure on internationally important nature conservation sites. It rules out provision of a new Suitable Alternative Natural Green space (SANG) within the National Park to mitigate development outside the National Park, other than in exceptional circumstances, and commits NFNPA to working with adjoining authorities and other partners to develop green infrastructure.

Conclusions and recommendations

Prior to consideration of mitigation, likely significant in combination recreation pressure effects from the Local Plan cannot be ruled out on New Forest SAC; New Forest SPA; Solent Maritime SAC; Solent and Southampton Water SPA; and Solent and Southampton Water Ramsar site.

LUC believes that it is not a realistic prospect to create new accessible natural greenspace of a scale and character that would effectively deflect all potential additional visits from the residents of new housing development away from the New Forest or Solent coast European designations, as new greenspace could not recreate the vast open character and visitor experience of the New Forest or an alternative coastal experience which draws people from such a large area. We therefore support use of the more diverse packages of measures set out in NFNPA’s revised Habitat Mitigation Scheme and in the Solent Recreation Mitigation Partnership’s scheme and believe that these are capable of providing effective mitigation of the recreation pressure that might otherwise occur as a result of the development proposed in the Local Plan in combination with that provided in New Forest District and other neighbouring authorities.

In light of the above, it is concluded that reliance can be placed on the NFNPA and Solent schemes to adequately mitigate potential recreation pressure from development within the New Forest National Park and that likely significant effects due to recreation pressure can be ruled out either alone or in combination.

Changes in water quantity

This HRA topic considers the potential likely significant effects of the Local Plan in terms of water abstraction to supply new development resulting in harmful changes to water levels or flows at European sites.

HRA Screening assumptions

It was assumed that it would not be possible to rule out likely significant effects unless the proposed level of development would not affect the water levels and flows at European sites that are vulnerable to changes in water levels and flows. These sites may be located outside of the Plan area and the 10 km buffer used in the HRA Scoping Report to establish the study area. In this regard, it was noted that Southern Water supplies the eastern half of the New Forest which falls within their ‘Hampshire South’ Water Resources Zone, much of the water supply for which comes from the River Itchen SAC and this European site was therefore added to the list of European sites scoped into the HRA, as noted above. Based on the New Forest Catchment Abstraction Management Strategy (CAMS), other European site that could potentially be affected by abstractions within the New Forest include New Forest SAC, SPA and Ramsar sites; Solent Maritime SAC; and Solent and Southampton Water SPA and Ramsar site. It was assumed that the very large, marine extent of Solent and Dorset Coast pSPA means that it is not sensitive to changes in changes in water flows in these rivers.

Potential for likely significant effects from Local Plan prior to mitigation

Regulation of water abstraction by the Environment Agency: The Environment Agency is responsible for regulating the use of water resources in England and uses the Catchment Abstraction Management Strategy (CAMS) process and abstraction licensing to do this. Where abstractions cause or potentially cause actual flows to fall short of Environmental Flow Indicators (EFIs) and result in environmental damage, the Environment Agency may change or even revoke existing abstractions to achieve a sustainable abstraction regime. The CAMS covering the New Forest reports there is one water body in which recent actual flows have fallen below the EFI and two waterbodies where fully licensed flows might fall below the EFI. The abstraction licences within these water bodies that cause these environmental issues have been identified by the CAMS and are being investigated as part of the Environment Agency’s Restoring Sustainable Abstraction (RSA) programme to better understand the impacts caused by these licences, individually or cumulatively, and to develop mitigation options with licence holders.

Water resources management by the water companies: Water companies have a statutory duty to service planned development in their area; the eastern part of the New Forest lies within Southern Water’s supply area whilst the western part lies within Sembcorp Bournemouth Water’s (SBW) supply area. Water Resources Management Plans (WRMP) set out how the water company intends to secure its water supply over a 25 year plan period to ensure that a balance between supply availability and forecast water demand is maintained and these WRMPs are subject to HRA. Investments to deliver the plans are based on five year planning cycles known as Asset Management Periods (AMP) so the water company programme for water infrastructure upgrades may constrain the rate at which residential growth can be supported.

HRA Screening of the Southern Water WRMP 2015-2040 concluded that likely significant effects could not be ruled out due to potential effects of the Candover groundwater scheme for river augmentation on the River Itchen SAC, and of the Ford Waste Water Treatment Works (WwTW) effluent transfer scheme on the Arun Valley SAC, SPA and Ramsar site. In light of legally enforceable abstraction licence conditions, a monitoring programme, and other considerations, Appropriate Assessment of the Candover scheme was able to rule out adverse effects on the integrity of the River Itchen SAC. Appropriate Assessment of the Ford WwTW effluent transfer scheme allayed water quality concerns with the water treatment process as well as potential adverse effects on flows.

SBW’s WRMP 2014-2039 states that as there is currently a surplus of supply versus demand within the SBW supply area, the SBW WRMP does not contain any proposals for the development of new water resource options. It further states that the potential effects of existing water abstraction operations on European sites have been assessed through the National Environment Programme (NEP) developed by the Environment Agency. The NEP assessment concluded that no sustainability reductions were necessary (i.e. reductions in permitted abstraction from surface or groundwater sources where abstraction has been found to be adversely affecting European sites, SSSIs, or WFD sites). The WRMP states that it was screened for potentially significant environmental effects under the Strategic Environmental Assessment (SEA) Regulations and that it was agreed, in consultation with Natural England, the Environment Agency, and English Heritage, that the WRMP was not likely to have a significant effect on the environment.

Mitigation available

Policy DP8: Safeguarding and Improving Water Resources requires that development avoids harm to the quality and yield of water resources and requires all residential development within the part of the National Park supplied by Southern Water to be designed to achieve the Government’s Optional Technical Standard for water efficiency (110 litres per person per day).

Water companies are subject to the Environment Agency’s licensing regime which regulates the amount of water that can be abstracted in order to protect the environment via the CAMS process and associated review of existing abstraction licences and granting of new ones. The ongoing operation of these controls helps to ensure that water abstractions do not have a detrimental impact on European sites.

Conclusions and recommendations

In light of the information above, likely significant effects from changes in water quantity due to the development proposed by the Local Plan alone or in combination can be ruled out.

Changes in water quality

This HRA topic considers the potential likely significant effects of the Local Plan in terms of development leading to:

• increased volumes of treated wastewater discharges, resulting in nutrient enrichment of water and potential lowering of dissolved oxygen as well as increased water velocities and levels downstream of outfalls of WwTW or off-sewage-network private septic tanks and small ‘packaged’ sewage treatment systems;
• overloading of combined sewer networks during storm events, resulting in overflows and contamination of water bodies;
• contaminated surface runoff from urban surfaces and roads.

HRA Screening assumptions

Effects relating to changes in water quality only need to be considered in relation to the European sites that are potentially vulnerable to a reduction in water quality. Based on their designated features and the pressures and threats facing them (see Appendix 1), these were judged to be:

• River Avon SAC;
• Avon Valley SPA;
• Avon Valley Ramsar site;
• Dorset Heaths SAC;
• Dorset Heathlands Ramsar site;
• The New Forest SAC;
• The New Forest Ramsar site;
• Solent and Dorset Coast pSPA;
• Solent and Isle of Wight Lagoons SAC;
• Solent Maritime SAC;
• Solent and Southampton Water SPA;
• Solent and Southampton Water Ramsar site.

Key information sources for the following assessments included representations received by NFNPA from the water companies and Environment Agency during consultation on earlier stages of the Local Plan, a guidance note on managing wastewater discharges to the Solent, and a Nutrient Management Plan for the River Avon SAC.

Treated wastewater discharges from wastewater treatment works (WwTWs): The HRA Screening assumed that it was not possible to rule out likely significant effects unless there is sufficient evidence to conclude whether the development proposed is likely to affect water quality at hydrologically connected European sites due to increased volumes of treated wastewater discharged from WwTWs serving the Plan area.

Sewer overflows: The HRA Screening assumed that it is not possible to rule out likely significant effect unless there is sufficient evidence to conclude that any sewer network capacity issues can feasibly be addressed.

Discharges from private septic tanks or small sewage treatment plants: Research commissioned by Natural England has shown that phosphorus originating from septic tank discharges can move laterally through the soil profile for a distance of 20-30 m in a variety of soil types. It therefore concluded that the Building Regulations’ legislative value of 10 m for the separation of a septic tank soakaway from a watercourse is probably insufficient to protect that waterbody from phosphorus pollution from this source, even where the local hydrology does not provide a shortcut for the delivery of septic tank discharges to water.

The HRA Screening therefore assumed that, prior to mitigation, likely significant effects on water quality cannot be ruled out where development is not likely to be connected to a public sewer and is within 30 m of a European site or a watercourse draining to a European site.

Contaminated surface runoff: The HRA Screening assumed that it is not possible to rule out likely significant effects unless there is sufficient evidence to conclude whether the development proposed is likely to result in an increase in contaminated surface water runoff in proximity to vulnerable European sites. In the absence of guidance and for consistency with the treatment of septic tank soakaways (above), a zone of influence of 30 m from a European site or a watercourse draining to a European site was used.

Potential for likely significant effects from Local Plan prior to mitigation

Evidence from NFNPA consultation with Southern Water and the Environment Agency: The Environment Agency referred NFNPA to Southern Water as the sewerage undertaker to ensure that foul water arising from the proposed developments could be accommodated; Southern Water did not raise any issues in relation to the capacity of its WwTWs to accommodate the development proposed in the National Park.

The Environment Agency also suggested that NFNPA determines whether there are any opportunities in the Sway and Lyndhurst drainage catchments to reduce diffuse pollution, thereby increasing the headroom of WwTWs in these catchments to discharge to water bodies which, under the Water Framework Directive, are currently failing to meet Good status in relation to nutrient levels. Policy SP4: Spatial Strategy directs development to both Sway and Lyndhurst as Defined Villages and allocations are made to these settlements (Policy SP23: Land at the former Lyndhurst Park Hotel, Lyndhurst; Policy SP24: Land south of Church Lane, Sway). Such development would be likely to add to the volume of discharges from the WwTWs serving these settlements and hence to nutrient levels in the receiving waters.

Sway is assumed to be served by the WwTW on Flexford Lane, for which the receiving water appears to be a stream called Avon Water that drains to the Solent at Keyhaven. Lyndhurst is assumed to be served by the WwTW at Dunces Arch Inclosure off the A35 Southampton Road. The receiving water appears to be a headwater stream of the Beaulieu River that drains to the Solent to the west of Lepe. Both waters drain to parts of the Solent forming part of Solent Maritime SAC, Solent and Southampton Water SPA and Ramsar site, and Solent and Dorset Coast pSPA. The designated features of these European designations are sensitive to water quality effects. While not mentioned in the consultation responses, it appears that development in the other two Defined Villages identified by Policy SP4: Spatial Strategy, Ashurst and Brockenhurst, would also be likely to be served by WwTWs that are hydrologically connected to these same Solent European sites.

Southern Water’s representations on the Draft Local Plan identified limited capacity in those parts of the sewerage network in closest proximity to the development allocations at Wharton’s Lane, Ashurst and South of Church Lane, Sway. The representation notes that Southern Water has limited powers to prevent new connections to the sewerage network, even when capacity is insufficient, and therefore recommends inclusion in the Local Plan allocation policies a requirement for development proposals to ‘provide a connection to the nearest point of adequate capacity in the sewerage network, as advised by the service provider’. The representation also requests generic support in the policy on Infrastructure Provision and Developer Contributions for new and improved utility infrastructure to meet identified community needs. No WwTW capacity issues were raised in Southern Water’s representations on alternative housing sites.

Evidence on water quality issues in Southampton Water and the Solent European sites: Natural England and the Environment Agency have produced a guidance note on the challenges in the Solent area in managing nutrients and sewage discharges to the marine environment whilst meeting the need for growth. This states that elevated nitrogen levels are contributing to the growth of opportunistic green seaweed mats in many parts of the Solent area and that these mats smother estuarine habitats and restrict the growth, distribution and variety of food available for wetland birds; although much of this nitrogen is from agriculture, a smaller but still substantial proportion is from wastewater discharges; there is currently little certainty that future development of the scale proposed in the Partnership for Urban South Hampshire (PUSH) area can ensure no adverse effect on the integrity of the Solent’s European designations without mitigation; while various actions to reduce nutrient inputs to the Solent have already been taken, further reductions are required from both agricultural and development growth sources and Natural England and the Environment Agency are keen to work with the PUSH authorities and water companies to develop a strategic solution.

PUSH has commissioned an Integrated Water Management Strategy (IWMS) to investigate whether the combined housing growth planned in the PUSH area can be accommodated whilst protecting the water environment. The IWMS concludes that there are not many water quality issues for nitrate from WwTW and that in total nitrate loading from WwTWs only account for 3–18% of the loading to designated areas. However, Natural England has stated that some areas are unfavourable due to current nitrate loading from WwTWs and sewer networks and that any future housing growth could exacerbate water quality issues. The IWMS recommends a phased action plan of improvements in the PUSH area to support planned housing growth to 2036, comprising upgrades to WwTWs and sewer networks as well as catchment solutions in the form of targeted agri-environment schemes.

Representations on the Draft Local Plan and Alternative Housing Allocations do not explicitly address the issue of nutrient enrichment of the Solent and Southampton Water European sites from WwTW discharges despite this having been identified as an issue by Natural England and the Environment Agency.

While the relatively small scale of development proposed by the NFNPA Local Plan is judged unlikely, on its own, to result in significant adverse water quality effects on the Solent European, the information above indicates a potential for likely significant effects in combination with development in the PUSH area whose WwTWs are also hydrologically connected to the Solent and Southampton Water.

Evidence of potential water quality effects on the River Avon/Avon Valley European sites: River Avon SAC and Avon Valley SPA and Ramsar site are known to be sensitive to and already suffering from elevated phosphorus levels. The South West river basin management plan cites poor water quality, particularly diffuse sources of phosphorus, nitrate and sediment from rural areas. A Nutrient Management Plan has been published to facilitate reduction and management of phosphorus levels in the River Avon SAC. Parallel HRA work by LUC on the New Forest District Local Plan Part 1 has identified the potential for likely significant water quality effects, in combination, on the European designations of the River Avon, giving rise to the need for additional assessment, which is ongoing. This work for New Forest District has identified that one or more of the STWs draining to the River Avon appear to have a catchment which also serves the National Park, for example Burley is served by Ringwood STW. However, Policy SP4: Spatial Strategy of NFNPA’s Local Plan does not focus growth in the western parts of the National Park that drain to the River Avon and none of the site allocations are in this area. Based on the spatial distribution of planned growth and the relatively small scale of growth proposed by the Local Plan as a whole, likely significant water quality effects in relation to WwTW discharges to the River Avon European designations are ruled out from the NFNPA Local Plan alone or in combination.

Discharges from private septic tanks or small sewage treatment plants or contaminated surface water runoff: In line with the screening methodology described above, the Local Plan site allocations were reviewed to determine whether any of them was within 30 m of a European site or a watercourse draining to a European site, as set out in Table 4.2 (in original document). This indicated potential for allocations made by Policies SP23 (Lyndhurst Park Hotel), SP25 (Fawley Power Station), and SP33 (Forest View, Landford) to have water quality effects in the form of discharges from private septic tanks or small sewage treatment plants or contaminated surface water runoff. Such effects could also arise in relation to the unallocated residential development provided for by Policy SP19: New residential development in the National Park (400 windfall dwellings; rural exception sites; housing for New Forest Commoners; housing for estate workers; tied agricultural dwellings) and by Policy SP20: Specialist Housing for Older People.

Mitigation available

Policy DP8: Safeguarding and Improving Water Resources states that development will not be permitted if it would risk harm to the quality of water resources, including abstraction sites, groundwater, rivers, streams and still waters. Following recommendations made by the Draft HRA Report, additional safeguards were added to this policy requiring development to either implement appropriate Sustainable Drainage Systems (SuDS) or demonstrate that surface water run-off from the development will not adversely affect any European nature conservation sites. In addition, a commitment was added in the supporting text to Policy DP8 to support the Environment Agency, Southern Water and Natural England in the development of any strategic solution to reducing nutrient inputs to the Solent from wastewater discharges.

In line with the recommendations made by Southern Water during consultation on the draft Local Plan, Policy SP22: Land at Whartons Lane, Ashurst and Policy SP24: Land south of Church Lane, Sway both require that development proposals provide a connection to the nearest point of adequate capacity in the sewerage network.

Policy SP38: Infrastructure Provision and Developer Contributions requires development proposals to make provision for the infrastructure necessary to ensure that the development is acceptable in planning terms. NFNPA has also incorporated the support for utility infrastructure requested by Southern Water in its comments on the Draft Local Plan.

The volume and quality of treated wastewater discharges from WwTWs to receiving water courses is subject to regulation by the Environment Agency via the grant and review of environmental permits. This Environmental permitting regime operated by the Environment Agency should ensure that any development requiring variation in the discharge consent for a WRC does not result in deterioration in downstream water quality as a result of that variation.

Any new discharge to the ground from a septic tank or small sewage treatment plant within 50 m of a European site requires a permit from the Environment Agency. Granting of such a permit would take into account the requirements of the Habitats Regulations.

Conclusions and recommendations

Treated wastewater discharges from wastewater treatment works (WwTWs): The PUSH IWMS provides relevant information on in combination water quality issues in the Solent and Southampton Water. This study, together with the Natural England and the Environment Agency guidance note, indicates that there is a eutrophication problem in the European sites of the Solent and Southampton Water to which WwTW discharges contribute. There is a potential for the housing growth proposed by the Local Plan to have significant effects in combination with that proposed by New Forest District Council and the other PUSH authorities on Solent and Isle of Wight Lagoons SAC, Solent Maritime SAC, Solent and Dorset Coast pSPA, Solent and Southampton Water SPA, and Solent and Southampton Water Ramsar site.

In recognition of the potential for the NFNPA Local Plan to contribute to these effects, the Local Plan includes a commitment to support the Environment Agency, Southern Water and Natural England in the development of any strategic solution to reducing nutrient inputs to the Solent from wastewater discharges. In light of the fact that the majority of the nitrogen inputs to the Southampton Water and Solent European sites are from agriculture rather than WwTW discharges and that the scale of growth proposed in New Forest National Park over the 20 year Local Plan period is very small (40 dwellings per annum) relative to the total growth planned in the PUSH area (approximately 20,000 dwellings per annum), it is judged that this commitment provides sufficient certainty that the contribution of NFNPA’s Local Plan to nutrient enrichment of the Southampton Water and Solent European sites will be negligible and that likely significant effects from treated wastewater discharges associated with the growth proposed by the Local Plan can be ruled out.

Sewer overflows: NFNPA’s consultation with Southern Water identified capacity issues in the closest part of the sewerage network to development allocations at Wharton’s Lane, Ashurst and South of Church Lane, Sway. In response to this, NFNPA has amended the corresponding Local Plan allocation policies (SP22, SP24) to require that development proposals provide a connection to the nearest point of adequate capacity in the sewerage network and has also added generic support for the provision of utility infrastructure to Policy SP38. The potential risk of sewer overflows from connection of other development provided for by the Local Plan to the sewerage network, including 400 windfall dwellings, is judged to be adequately mitigated by the requirement in Policy SP38 for development proposals to make provision for the infrastructure necessary to ensure that the development is acceptable in planning terms. It is therefore concluded that likely significant effects on water quality from sewer overflows either alone or in-combination can be ruled out.

Discharges from private septic tanks or small sewage treatment plants: Generic protection for water quality is provided by Policy DP8 and a generic requirement for developers to provide necessary infrastructure is provided by Policy DP38. It is judged that these policies adequately mitigate the risk to water quality from unallocated development provided for by the Local Plan as a result of potential discharges from private septic tanks or small sewage treatment plants. It is judged that the specific risk identified from the allocations within 30 m of European sites (Policies SP23, SP25 and SP33) requires more specific mitigation but that this is provided by the fact that any new discharge to the ground from a septic tank or small sewage treatment plant within 50 m of a European site requires a permit from the Environment Agency.

Contaminated surface water runoff: Generic protection for water quality is provided by Policy DP8 and a generic requirement for developers to provide necessary infrastructure is provided by Policy DP38. It was judged that these policies adequately mitigate the risk to water quality from unallocated development provided for by the Local Plan as a result of contaminated surface water runoff. However, it was judged that the specific risks identified from the allocations within 30 m of European sites (Policies SP23, SP25 and SP33) required more specific mitigation. This resulted in additional safeguards being added to Policy DP8.

Overall conclusion: Likely significant effects on water quality due to treated wastewater discharges, sewer overflows, private sewage discharges, or contaminated surface runoff can be ruled out either alone or in combination, subject to the mitigation and policy safeguards described above and in the Local Plan.

5 Appropriate Assessment

As described in the HRA Screening in Chapter 4, a need for Appropriate Assessment was identified in relation to the following two types of likely significant effect:

• Loss or damage to offsite supporting habitat;
• Traffic collision risk.

This chapter considers each of these types of likely significant effects in turn and concludes whether adverse effects on the integrity of European sites can be ruled out.

Loss or damage to offsite supporting habitat for qualifying bird populations

The Local Plan allocates a number of development sites in areas where certain qualifying SPA and Ramsar bird species may make use of offsite habitat for foraging, roosting and loafing. The screening stage was unable to rule out the potential for likely significant effects on the Avon Valley SPA and Ramsar site, Dorset Heathlands SPA, New Forest SPA, and Solent and Southampton Water SPA and Ramsar site, as a result of the loss of offsite habitat. As a result, Appropriate Assessment was undertaken to determine whether the loss of offsite habitat would result in adverse effects on the integrity of any of these European sites.

Approach

In response to comments provided by Natural England and HIWWT during the consultation process, the Appropriate Assessment commenced with a detailed desk-based study to identify potential impacts from proposed site allocations on offsite habitat used by the qualifying bird species of the European sites. For each of the proposed development allocations, sites were reviewed using aerial imagery to determine their potential suitability for supporting SPA species. This included identifying broad habitat types present, current land usage, shape and size of site, degree of openness, and information regarding the context of the site within the wider landscape, including in terms of habitat connectivity and proximity to habitats of known importance for SPA birds. This review also considered the presence of potential adverse factors such as proximity of sources of disturbance and/or habitat features likely to reduce the potential for SPA bird species, such as the effect of prominent edge features in reducing the openness typically preferred by foraging waders and wildfowl.

Hampshire Biodiversity Information Centre (HBIC) Desk Study Reports were then reviewed, if required, to identify whether records of relevant bird species have been recorded within the site, or in close proximity. Where necessary, the habitat types affected were cross-checked against the habitat preferences identified for specific bird species. Where habitats of potential importance for specific bird species are likely to be affected, a more detailed assessment was undertaken which used the following additional information sources to identify whether such habitats are likely to be important for the bird species:

• Brent goose/wader strategy data for the Solent (available from Solent Forum);
• various Natural England/New Forest Authority Bird Survey reports (e.g. for nightjar);
• HBIC bird records and GIS files.

Assessment of importance of allocated sites for SPA/Ramsar birds

To determine the potential importance of each site allocation to provide supporting offsite habitat it was necessary to establish which habitat types have the potential to be of importance for each of the bird species for which the SPA and Ramsar sites are designated. Known habitat preferences for each species were taken from Birds of the Western Palearctic and further refined in light of local preferences via consultation with Natural England officers and HIWWT.

Bird habitat preferences were then cross referenced against the habitat types present within each allocation (taking into account any of the factors listed above) to determine the suitability of offsite parcels for SPA and Ramsar bird species.

The detailed assessment of habitat suitability for each site allocation is shown in Table A5.1 in Appendix 6 and is summarised below and in Table 5.1 in the original document. In summary:

• SP22 Land at Whartons Lane, Ashurst – site comprises horse grazed pasture and given its relatively small size, distance from European sites, proximity of the urban edge of Ashurst and presence of negative edge factors (woodland/tree lines reducing openness), grassland is considered unsuitable for SPA/Ramsar species. Tree lines may provide foraging habitat for nightjar but development would be expected to minimise lighting impacts through standard planning processes.
• SP23 Land at the Former Lyndhurst Park Hotel, Lyndhurst – former hotel building, mature gardens and woodland in southern part. Despite woodland, surrounding urban area, small site, disturbance and lighting, and isolation mean site is of negligible value for foraging SPA species including woodland-reliant species.
• SP24 Land South of Church Lane, Sway – horse grazed pasture; proximity to urban edge and edge factors make grassland unsuitable for SPA/Ramsar species. Tree lines provide suitable habitat for foraging nightjar but project level development would be expected to minimise lighting impacts.
• SP25 Land Adjacent to the Former Fawley Power Station Site – comprises tall grasslands and dense scrub; acid grassland, dense scrub and reedbed present; small areas of scrub succeeding to woodland and degraded saltmarsh. Habitats generally of low importance for waders/wildfowl/wetland/heathland/woodland species. Rough grasslands and dense scrub may provide opportunities for hunting/roosting hen harrier and merlin; scrub and reedbed may support Dartford warbler. Site is over 3.5 km from New Forest SPA and presence of Dartford warbler is likely additional to SPA population. On a precautionary basis, mitigation is recommended (site-specific bird surveys) and has been added to Policy SP25.
• SP26 Land at Calshot Village - rough grassland, scrub and scattered trees; linear shape and proximity to housing mean unlikely to be used by hen harrier, merlin or Dartford warbler; unlikely to be utilised by foraging woodland species for Nightjar due to distance and isolation from New Forest SPA; considered unsuitable for SPA/Ramsar bird species.
• SP33 Gypsy Site at Forest View, Landford – small field of horse grazed pasture plus hard standing and building; small size and habitats mean negligible importance for SPA/Ramsar birds.

Bird species	Season to which qualifying species relate	Broad habitat types of potential importance	Potential for reliance on habitats within sites allocated by New Forest Local Plan
Avon Valley SPA – Bewick's swan	Winter	Arable; grazed pasture	No – key habitat types not present within, or affected by site allocations
Avon Valley SPA – Gadwall	Winter	Riparian; open water	No – key habitat types not affected
Avon Valley Ramsar – Northern pintail	Winter	Open water; coastal wetlands	No – key habitat types not affected
Avon Valley Ramsar – Black-tailed godwit	Winter	Coastal wetlands; wet grasslands; grazed pasture; arable	No – Policy SP25 supports development of extensive grasslands adjacent to Solent and Southampton Water SPA/Ramsar but the rank nature of the grassland sward and presence of scattered and dense scrub represent habitat conditions of low suitability for this species.
Dorset Heathlands SPA – Dartford warbler	Summer (breeding)	Heathland, open scrub habitats, occasionally reed bed	Yes – SP25 supports extensive areas of dense scrub and this species has been recorded breeding and overwintering in the Tom Tiddlers SINC which encompasses the site.
Dorset Heathlands SPA – Nightjar	Summer (breeding)	Heathland and open woodlands (foraging habitats also include tree lines, hedgerows, grazed pasture, meadows)	No – nightjar forage several km from their heathland nest sites; while treelines and mature trees occur within Policies SP22, SP24, SP26 and SP33, the majority of these allocations comprise habitats of low suitability for foraging nightjar.
Dorset Heathlands SPA – Woodlark	Summer (breeding)	Heathland; open woodlands; arable (winter)	No – habitats present are low suitability or small in area and unlikely important for offsite foraging.
Dorset Heathlands SPA – Hen harrier (winter)	Winter	Arable farmland, rough pastures, heathland, coastal sand-dunes and marshy areas; wide open areas for seizing prey	Yes – wide ranging during winter and typically reliant on coastal, river floodplains and heathland habitats. Extensive areas of rough grassland and scrub within SP25 have potential to contribute but would not be expected to be important alone in maintaining populations.
Dorset Heathlands SPA – Merlin (winter)	Winter	Various open habitats including heathland; coastal wetlands; arable; grasslands	Yes - wide ranging during winter and typically reliant on open habitats. Extensive areas of rough grassland within SP25 have potential to contribute but would not be expected to be important alone in maintaining populations.
New Forest SPA – Dartford warbler, nightjar, woodlark	Summer (breeding)	See Dorset Heathlands SPA above	Yes – Dartford warbler. No – other species. As per Dorset Heathlands SPA above.
Solent and Southampton Water SPA – Common tern, Little tern, Mediterranean gull, Roseate tern, Sandwich tern	Summer (breeding)	Open water; riparian; coastal wetland	No – key habitat types not affected
Solent and Southampton Water SPA – wintering assemblage (Black-tailed godwit etc.)	Winter	See above for wader/wildfowl habitats	No – key habitat types not affected (notably SP25 grassland and scrub considered of low suitability for these waders)

Summary and mitigation requirements: None of the strategic site allocations was concluded to be likely to be important in maintaining populations of SPA/Ramsar birds for the reasons outlined above and in Table A5.1 in Appendix 6. However, in order to provide the necessary level of certainty that the loss of habitat associated with SP25 (Land adjacent to the former Fawley Power Station Site) will not result in adverse effects on the integrity of the Dorset Heathlands SPA/Ramsar and New Forest SPA on account of the effect of loss of offsite habitat for hen harrier, merlin and Dartford warbler, the following mitigation was recommended for inclusion within the Local Plan:

• Site allocation Policy SP25 should include a requirement to undertake site-specific bird surveys to confirm the status of SPA/Ramsar species at the site, particularly merlin, hen harrier and Dartford warbler, to inform appropriate mitigation requirements as part of site specific development and masterplanning.

This recommendation has been accepted by NFNPA and the mitigation included within the allocation Policy SP25.

It is considered acceptable to defer this further HRA work to the project/development management stage because site SP25 is considered unlikely on its own to be of importance in maintaining SPA/Ramsar bird populations, and the proposals for ecological restoration and enhancement within the wider landscape provide sufficient confidence that any impact identified would be expected to be capable of being mitigated for on-site or in the vicinity, if required.

Example guidance to proposers (to be incorporated in supporting text to the allocation policy):

Project level development for Land Adjacent to the Former Fawley Power Station Site will be required to provide an assessment of impacts on SPA/Ramsar bird species, particularly hen harrier, merlin, and Dartford warbler. This assessment should incorporate a suitable level of data collection and/or bird surveying to determine the individual and cumulative importance of the site for SPA/Ramsar species. Where the assessment identifies the potential for adverse effects on integrity resulting from the offsite habitat loss, appropriate and timely measures must be taken to mitigate such impacts. Such mitigation is likely to be in the form of on-site habitat, managed specifically for the affected bird species and/or contributions towards the provision of strategic mitigation sites in the vicinity. All such measures must be in place and operational prior to the relevant impact(s), and must be maintained for the duration of the impact(s).

Conclusion of Appropriate Assessment of loss of offsite habitat

The detailed desk study and review of site information indicated that with the exception of Policy SP25, the sites are of negligible importance for SPA/Ramsar species. Site SP25 provides suitable habitat for merlin, hen harrier and Dartford warbler, but given behaviour of these species, the limited extent of suitable habitat, and the numbers of birds the site is likely to be capable of supporting, it is considered unlikely to be important in contributing to the maintenance of SPA/Ramsar populations for these species. Therefore, the mitigation measures provided above were recommended on a precautionary basis to provide the necessary level of certainty. The mitigation has now been incorporated in Policy SP25. In light of the desk study findings and the fact that the recommended mitigation has been incorporated in Policy SP25, adverse effects on the integrity of European sites as a result of loss of offsite habitat will be avoided, assuming that policy requirements are implemented as part of any site specific development proposals.

Traffic collision risk

Background: Rights exercised by commoners of the New Forest include the right to graze ponies, cattle, donkeys, sheep, and pigs on the Forest. Many of these animals are semi-wild and their browsing and grazing suppresses the growth of brambles, gorse and other coarse vegetation, helping to maintain the designated open habitats of New Forest SAC and Ramsar site.

During consultation, Natural England raised a concern that development could result in an increase in traffic across the New Forest, making roads unsafe for grazing animals and necessitating fencing along the roadsides. If fencing is needed to protect animals, changes to the grazing pattern in the New Forest could, without mitigation, lead to loss of open habitats for which New Forest SAC and Ramsar site is designated, with knock-on effects on New Forest SPA designated bird species and New Forest Ramsar site fauna reliant on those habitats. While the amount of traffic growth associated with the small scale of development proposed by the NFNPA Local Plan alone is unlikely to be significant, when this is combined with commuter and visitor traffic growth from neighbouring areas, roads within and close to the New Forest could experience a significant increase in road traffic.

Is traffic growth likely to result in increased collisions with grazing animals? The Verderers of the New Forest monitor and report on the numbers of commoners’ livestock present in the New Forest and the number of these killed in road traffic accidents. Figure 5.1 in the original document shows the proportion of commoners’ livestock killed in road traffic accidents in each year since 1956. While road traffic across the New Forest has grown significantly over the past years the proportion of New Forest commoners’ stock being killed in road traffic accidents has shown a steady decline. This decline is thought to be a result of various management measures including: fencing of major roads in earlier decades, reducing speed limits, enforcement of speed limits, a Higher Level Stewardship scheme funding reflective pony and cattle collars, warning signs, educational materials, press coverage of animal accident statistics, a reward for information leading to prosecution of hit-and-run drivers, a hotline to report traffic accidents, and a multi-agency Animal Accident Reduction Group.

NFNPA monitors animal accident statistics collected by the Verderers and reports these through its State of the Park Reports. This will allow it to identify any reversal in the trend of long term reduction in traffic collision risk associated with development proposed by the Local Plan in combination with other plans and projects and take corrective action.

Would an increase in traffic collisions with grazing animals be likely to be managed by fencing?

Fencing of major roads historically reduced collisions, but since completion of major road fencing the traffic collision ratio has continued to fall steadily due to active management by stakeholders. Given the suite of measures available and active monitoring, it should be possible to address any reversal without additional fencing. Any new fencing next to a highway, if over 1 metre in height, would require planning permission, providing an opportunity for project level HRA to assess potential effects on the New Forest European sites.

Conclusion of Appropriate Assessment of traffic collision risk

The review of information has shown that road traffic growth does not inevitably lead to an increase in the risk of grazing animals being killed in collisions with road traffic. A suite of measures is being employed to successfully manage the risk of road traffic collisions with grazing stock in the New Forest, resulting in a declining trend in the risk of animal accidents. NFNPA monitors accident statistics which allows it to respond to any reversal of this trend. Since the roads presenting the highest collision risk have already been fenced and there is a broad range of other measures available with the potential to successfully manage risk, it should be possible to address any reversal without additional fencing. Any new fencing next to a highway would require planning permission, giving further project level HRA opportunity. In light of these findings it is concluded that adverse effects on the integrity of New Forest European sites as a result of loss of traffic collision risk will be avoided.

6 Summary and conclusions

Summary

The HRA at this stage has assessed the effects from the Regulation 19 Submission draft of the New Forest National Park Local Plan on European sites and to provide recommendations on how these could be ruled out by inclusion of appropriate safeguards within the emerging policies. In some cases it has also recommended that additional information be gathered to support a full assessment of the likely effects of the Local Plan. Table 6.1 summarises the findings of the HRA and the recommendations for policy changes or further assessment in relation to the types of effect not yet ruled out.

Effect type	HRA finding	Recommendation
Direct loss or physical damage to European sites	Likely significant effects ruled out.	None required.
Loss or damage to offsite supporting habitat	Screening was unable to rule out likely significant effects on the Avon Valley SPA and Ramsar site, Dorset Heathlands SPA, New Forest SPA, and Solent and Southampton Water SPA and Ramsar site, as a result of the loss of offsite habitat. Appropriate Assessment concluded that adverse effects on the integrity of European sites as a result of loss of offsite habitat will be avoided as mitigation recommended by the Draft HRA has now been included in the Local Plan.	None required.
Urban edge effects	Likely significant effects ruled out.	None required.
Changes in air quality	Initial screening unable to rule out likely significant air quality effects in combination on a number of European sites. Air quality assessment and linked ecological assessment carried out by third party consultants.	See ecological assessment carried out by third party consultants.
Traffic collision risk	Unable to rule out likely significant traffic collision risk effects in combination on the New Forest SAC, SPA and Ramsar sites on a precautionary basis due to absence of suitable traffic growth forecast. Appropriate Assessment concluded that adverse effects on the integrity of European sites as a result of traffic collision risk will be avoided.	None required.
Recreation pressure	Likely significant effects ruled out.	None required.
Changes in water quantity	Likely significant effects ruled out.	None required.
Changes in water quality	Likely significant effects ruled out.	None required.

Conclusions

This report sets out the results and conclusions of the HRA of the NFNPA Regulation 19 Submission draft Local Plan except in relation to changes in air quality. For the effect types considered in this report, it is concluded that the Regulation 19 Submission draft of the Local Plan will not adversely affect the integrity of any European site, either alone or in combination with other plans and projects.

A separate air quality assessment and linked ecological assessment reported on separately and together constitute the HRA of air quality effects for both the New Forest National Park and New Forest District Local Plans. At the time of writing, these documents had not yet been finalised but emerging results indicate a requirement for vegetation monitoring complemented by a mitigation strategy in relation to the potential effects of changes in air quality on The New Forest SAC, SPA and Ramsar site. The separate reports should be consulted for a full understanding of this element of the HRA.

Appendix 1 – European sites information

This Appendix contains relevant information about the following European sites:

• River Avon SAC;
• Avon Valley SPA;
• Avon Valley Ramsar site;
• Dorset Heaths SAC;
• Dorset Heathlands SPA;
• Dorset Heathlands Ramsar site;
• Mottisfont Bats SAC;
• The New Forest SAC;
• New Forest SPA;
• The New Forest Ramsar site;
• River Itchen SAC;
• Solent and Dorset Coast pSPA;
• Solent and Isle of Wight Lagoons SAC;
• Solent Maritime SAC;
• Solent and Southampton Water SPA;
• Solent and Southampton Water Ramsar site.

River Avon SAC

Site area: 416.57 ha

Overview: The River Avon SAC is one of the richest chalk rivers in Europe. Important for fish, invertebrates such as Desmoulin’s whorl snail and riverine plant communities.

Qualifying Features include river habitat H3260 and species such as Desmoulin's whorl snail, sea lamprey, brook lamprey, Atlantic salmon, bullhead.

Pressures include physical modification, siltation, water pollution (elevated phosphate), water abstraction, changes in species distributions, invasive species, hydrological changes, inappropriate weed control, habitat fragmentation.

Conservation objectives: Maintain or restore extent, structure and function of habitats and species.

Avon Valley SPA & Ramsar

Site area SPA: 1351.1 ha; Ramsar: 1385.1 ha

Overview: Wide river valley with unimproved wet grassland. Importance for wintering wildfowl Bewick's Swan and Gadwall. Ramsar includes diverse habitats of chalk river floodplain including fen, mire, lowland wet grassland and woodland.

Pressures: Water pollution (elevated phosphorus), disturbance from public access/dog walkers, vegetation succession, drainage, siltation, invasive species, recreational/tourism disturbance, water level management, etc.

Dorset Heaths SAC, Dorset Heathlands SPA and Ramsar

Overview: Extensive lowland heathland area in southern England with a wide range of heathland habitats, fens, mires and species of conservation concern including nightjar, woodlark, Dartford warbler, hen harrier and merlin. Pressures include inappropriate scrub control, public access/disturbance (dogs, tipping), undergrazing or overgrazing, drainage, water pollution, invasive species, habitat fragmentation, wildfire, and air pollution (nitrogen deposition).

Mottisfont Bats SAC

Site area: 196.55 ha

Overview: Woodland supporting an important population of Barbastelle bat (Barbastella barbastellus). Pressures include forestry management not geared to bat conservation, lack of information on offsite commuting/foraging areas. Conservation objectives focus on maintaining habitats and populations.

The New Forest SAC, SPA and Ramsar

Site area SAC: 29,213.57 ha; SPA: 27,968.96 ha; Ramsar: 28,002.81 ha

Overview: Large complex mosaic of habitats including wet and dry heaths, bogs, mires, grasslands, pasture woodlands, ponds and streams. Among the most important wildlife sites in the UK. Importance of commoning for maintaining habitats. Pressures include reduction in commoning/grazing, recreation impacts, historic drainage, plantation/exotic species, loss of traditional management, water pollution from unconnected properties, air pollution (nitrogen deposition), parking/verge damage, invasive species, inappropriate cutting/mowing and more. Conservation objectives aim to maintain or restore site integrity and favourable condition of qualifying habitats and species.

River Itchen SAC

Site area: 303.98 ha

Overview: Classic chalk river with rich aquatic flora and fauna. Linked to Southampton Water and the Solent. Qualifying features include Ranunculion vegetation, Southern damselfly, bullhead, white-clawed crayfish, brook lamprey, Atlantic salmon, and otter. Pressures include water pollution, physical modification, siltation, overgrazing, water abstraction, inappropriate weed control, hydrological changes, invasive species, and others.

Solent and Dorset Coast pSPA

Site area: 89,078.02 ha

Overview: Proposed marine SPA for foraging terns (Common, Sandwich, Little). Map and boundaries under consultation at time of drafting.

Solent and Isle of Wight Lagoons SAC

Site area: 37.93 ha

Overview: Coastal lagoons (Keyhaven–Pennington, Farlington Marshes, Bembridge Harbour, Gilkicker). Qualifying feature H1150 Coastal lagoons. Pressures include hydrological changes, inappropriate weed control (algaecide), coastal squeeze, invasive species, air pollution (nitrogen deposition).

Solent Maritime SAC, Solent and Southampton Water SPA & Ramsar

Solent Maritime SAC site area: 11,243.12 ha. Solent and Southampton Water SPA: 5,401.12 ha. Ramsar: 5,346.44 ha.

Overview: Complex estuarine system supporting mudflats, saltmarsh, lagoons, eelgrass, and important bird populations. Qualifying features include estuaries, mudflats, sandbanks, Spartina swards, salt-meadows, coastal lagoons and a range of species. Pressures include public access/disturbance, coastal squeeze, water pollution and eutrophication (nitrogen), fisheries, invasive species, hydrological changes, extraction, and climate change. Conservation objectives focus on maintaining the extent and structure/function of habitats and populations of qualifying species.

Appendix 2 – Evidence on recreation pressure in the New Forest

Summary of key studies and findings (sources include Tourism South East visitor survey 2004–05; PROGRESS project; monitoring of car park seasonal closures; Liley et al. studies on changing patterns of visitor numbers; and other conservation literature). Key findings highlighted:

• High levels of local resident visitation (many visit weekly) and high reliance on cars for access to the Park.
• Recreation patterns spread year-round.
• Evidence on direct impacts of recreation on SPA Annex I bird species is mixed and inconclusive; densities of indicator species (nightjar, woodlark, Dartford warbler) are lower than in other heathland areas; precautionary approach recommended.
• Mitigation measures trialled include seasonal car park closures, provision of alternative recreation sites, information boards, ranger presence and targeted access management. Long-term monitoring of outcomes is required and evidence of efficacy is limited.

Appendix 3 – Review of other relevant plans and projects

Summary of plans and HRAs considered from Bournemouth, Christchurch and East Dorset, Isle of Wight, New Forest District Council, Poole, Southampton, Test Valley, Wiltshire and county-level plans including Hampshire county plans, Minerals and Waste plans and Local Transport Plans. The review considers potential for in-combination effects and the mitigation measures identified in each plan’s HRA. Where relevant, mitigation commitments and monitoring requirements are noted.

Appendix 4 – Initial screening matrix for the Regulation 19 Submission draft Local Plan

Detailed screening matrix is provided listing each Local Plan element, interim screening conclusion (prior to mitigation), justification (reference to screening codes A–H), potentially significant effects and European sites potentially affected. Policies screened out include many strategic and development management criteria (general aspirations, environmental protection), while policies screened in and subject to further assessment include SP4 (Spatial Strategy), SP19 (New residential development), SP20 (Specialist housing), SP22–SP26 allocations and SP33 (Gypsy site). The matrix provides the justification for screening decisions used in Chapter 4.

Appendix 5 – Consultation responses

Table of consultee responses to the joint New Forest Local Plans HRA Scoping document (Natural England, Hampshire and Isle of Wight Wildlife Trust, New Forest NPA, etc.), summarised with LUC responses. Key points include confirmation to include Mottisfont Bats SAC, inclusion of Solent pSPA, River Itchen SAC scope in relation to water supply, and treatment of private sewerage (30 m screening) in line with Natural England commissioned research and Environment Agency permitting rules for discharges within 50 m of European sites.

Appendix 6 – Additional information for the Appropriate Assessment

Additional information and Table A5.1: Suitability of allocated sites for hen harrier and merlin designated populations (site-by-site assessment using HBIC data, SOLENT Wader and Brent Goose Strategy, SINC and other designations). The table summarises satellite imagery review, habitat suitability, species records, non-statutory/ statutory designations and conclusions on whether further site level survey is required. In brief, SP25 (Fawley adjacent) contains suitable habitat features for merlin/hen harrier and Dartford warbler and requires site-level surveys; SP22, SP23, SP24, SP26, SP33 were judged to be of low suitability / negligible importance for SPA birds.