Interim Habitats Regulations Assessment (HRA)

Annex 3: Natural England's comments on The Greater Norwich Local Plan (GNLP) Habitats Regulations Assessment of GNLP Issues and Options Stage, dated December 2017

Natural England welcomes the production of the interim Habitats Regulations Assessment (HRA) for the GNLP Issues and Options stage, which provides a detailed and comprehensive assessment of the likely significant effects of the Local Plan on European sites. The designated sites have been identified correctly and the major issues arising from the Plan's allocations and policies identified and discussed in detail. We welcome that the assessment has considered the potential for impacts to European sites beyond the GNLP boundary, in accordance with the requirements of the Habitats Regulations.

We re-iterate below our response to Q22 in the Growth Options consultation (see Annex 1) concerning the two most significant and pressing issues that will need to be addressed and resolved:

"Recreational disturbance effects from new housing on designated sites is recognised as a major issue in many places including Norfolk. Sites affected range from County Wildlife Sites (CWS), to Sites of Special Scientific Interest (SSSI) to European and International sites such as Special Areas of Conservation (SAC), Special Areas of Protection (SPA) and Ramsar sites. Recreational disturbance may affect wildlife sites located close to development and existing settlements as well as sites located some distance away. New development will need to provide a range of avoidance and mitigation measures to address this impact. These include the provision of new well designed GI either on-site and/or off-site, with suitable and accessible green space for recreational activities, including dog walking, together with good connectivity to the surrounding PROW network, and costs towards the mitigation of impacts on designated sites.

There are significant water issues in terms of water abstraction, with increasing demand from residential and commercial development, and waste water discharges affecting water quality. Water-dependent designated sites, including the River Wensum, those in The Broads, the Norfolk Valley Fens and the Waveney Valley Fens, are affected by these issues which can arise from a single development or in combination with other developments. A detailed water cycle study will
need to be undertaken to determine where allocations should be located and what measures will be required to address water quantity and quality issues identified, which should then need to be addressed through policies and allocations in the Greater Norwich Local Plan (GNLP)."

We welcome the recognition given in the HRA to the importance of undertaking a Water Cycle Study to inform the future location of allocations and plan policies.

With regard to recreational disturbance under 4.7 Potential Mitigation of the HRA, we advise that mitigation may involve providing or contributing towards a combination of the following measures:

i. Access and visitor management measures within the SAC/SPA;
ii. Improvement of existing greenspace and recreational routes;
iii. Provision of alternative natural greenspace and recreational routes;
iv. Monitoring of the impacts of new development on European designated sites to inform the necessary mitigation requirements and future refinement of any mitigation measures.
v. Other potential mitigation measures to address air pollution impacts e.g. emission reduction measures, on site management measures.'

Reference should also be made to the provision of new on-site GI and biodiversity enhancements within development sites.

Recent research, commissioned by a group of Suffolk coastal local authorities, on the impacts of

recreational disturbance on designated sites, from residential development in their Local Plans suggests that the Zone of Influence (ZoI) for those travelling by car for regular routine greenspace use should be 13 km. The findings, by Footprint Ecology, will be published later this year in support of the local authorities consult in their Local Plans. In view of this information, we advise that the Zol for the GNLP HRA should be increased from 8 km to 13 km, unless there are valid reasons for retaining it. We recognise that the increased distance may affect the future findings and conclusions of a revised HRA.

As the HRA progresses and more information becomes available (particularly the findings of the Water Cycle Study), we look forward to commenting in further detail.

We recognise that this is an interim report and are pleased to see that a good start has been made on gathering information to inform the HRA and in setting out the key issues that may affect designated sites. At this stage we wish to flag up what we consider are the two most important issues that need to be covered.
In our view, the most critical issue that needs to be addressed is in relation to the water cycle, both with regard to water quantity and water quality, particularly in relation to the Broads Natura 2000 sites. EA classifies the area as being under "serious water stress". The seriousness of this issue is also clear from the Anglian Water 25 year Water Resources Management Plan, which shows the Norwich and the Broads as one of the most water stressed resources zones in the AW area. As a result, consideration of impacts on water dependent sites should be a priority.
The second major issue that is directly related to development and the resultant increase in population in the Norwich area, is the increased recreational impact on designated sites. Since the JCS further evidence has been gathered, principally through the Visitor Surveys at European Protected Sites report that was carried out in 2015 & 2016. We are aware that this and other evidence on visitor impacts will be considered in detail however we would like to flag up the importance of considering impacts on sites further afield than the 8km that is often used in relation to impacts on designated sites, particularly in relation to coastal sites. It is also important to recognise impacts on less visited sites, such as components of the Norfolk Valley Fens (e.g Buxton Heath), which may contain habitats and species particularly sensitive to trampling and disturbance by dogs
We look forward to commenting in more detail on these and other aspect of the as HRA is developed.

Evidence Base: Interim Habitats Regulation Assessment
Para 3.2.1 - Increased pressure on water resources (page 30)
Reference is made to a need for an additional borehole to supply potable (drinking) water. It is unclear on what basis this assumption has been made. Anglian Water has recently published a Draft Water Resource Management Plan which subject to approval by Defra is intended to replace the approved WRMP 2015. We would ask that the Habitats Regulation Assessment makes reference to the findings of this document particularly in relation to the proposals for the relevant Water Resource Zones for the Greater Norwich area.
Para 3.2.1 - Pollution impacts (page 30)
Similarly reference is made to the potential for pollution to the introduction of additional foul flows from new development in the Greater Norwich area to water recycling centres in Anglian Water's ownership. It should not be assumed that a deterioration of water quality to designated European sites will result from additional development draining to existing WRCs.
WRC permits have a variety of conditions including the permitted dry weather flow(DWF) and the chemical standard of discharge. Permits are issued by the Environment Agency and the conditions applied are site specific, set at a level to ensure sufficient water quality at the discharge point. WRCs are designed to meet the specific conditions within their permit. We regularly monitor our position against both the DWF and the standards, promoting investigation, a change in working practices and investment through our business planning process where required.
Anglian Water through our business planning process promotes investment at WRCs and/or within the sewerage catchment to ensure our water recycling infrastructure is aligned with new development and to ensure we can comply with the permits issued by the Environment Agency.
For the purposes of the Habitats Regulation Assessment it is recommended that that only the WRCs which discharge directly or indirectly to a watercourse which is of European significance should be considered as part of the assessment.
Section 3.4 - increased pressure on water resources (pages 34-36)
This section should be updated to take account of Anglian Water's Draft WRMP 2018 which is intended to replace the existing WRMP published in 2015.
Section 3.4 - pollution impacts: water pollution (pages 36)
Reference is made to the potential for pollution to the introduction of additional foul flows from new development in the Greater Norwich area to water recycling centres in Anglian Water's ownership. It should not be assumed that a deterioration of water quality to designated European sites will result from additional development draining to existing WRCs. Anglian Water through our business planning process promotes investment at WRC and/or within the sewerage catchment to ensure our water recycling infrastructure is aligned with new development.
WRC permits have a variety of conditions including the permitted dry weather flow(DWF) and the chemical standard of discharge. Permits are issued by the Environment Agency and the conditions applied are site specific, set at a level to ensure sufficient water quality at the discharge point. WRCs are designed to meet the specific conditions within their permit. We regularly monitor our position against both the DWF and the standards, promoting investigation, a change in working practices and investment through our business planning process where required.
Para 4.8 - recommendations for further study (page 46)
Reference is made to the preparation of a Water Cycle Study to assess further the water quality and impacts from additional abstraction.
Proposals for additional water abstraction and any associated sustainability reductions set out by the Environment Agency are normally considered as part of the Water Resource Management Plan process. We are also preparing a Long Term Water Recycling Plan as part of which are considering how we can continue to comply with permits issued by the EA.
Reference is made to the need for a Water Cycle Study to support the preparation of the Greater Norwich Local Plan in the Habitats Regulation Assessment Scoping report. We would welcome further discussions with the Greater Norwich Local Plan Team regarding the scope of any technical study in the context of the Draft Water Resource Management Plan and Draft Long Term Water Recycling Plan which are being prepared by Anglian Water. We would wish to agree the scope of any further technical work with the Local Plan Team to ensure it doesn't duplicate any information already set out in Anglian Water's documents.