Broxbourne Borough Council Pre-Submission Core Strategy Habitat Regulations Assessment

Final Report July 2010

Prepared for

Broxbourne Borough Council

Broxbourne Borough Council Core Strategy

Revision Schedule

Habitat Regulations Assessment July 2010

Rev Date Details Prepared by Reviewed by Approved by

01 08/07/10 Draft Report Emily Cook Dr. James Riley Dr. James Riley Assistant Ecologist Principal Biodiversity Principal Biodiversity Specialist Specialist

02 19/07/10 Final Report Emily Cook Dr. James Riley Dr. James Riley Assistant Ecologist Principal Biodiversity Principal Biodiversity Specialist Specialist

This document has been prepared in accordance with the scope of Scott Wilson's appointment with its client and is subject to the terms of that appointment. It is addressed to and for the sole and confidential use and reliance of Scott Wilson's client. Scott Wilson accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared and provided. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior Scott Wilson written permission of the Company Secretary of Scott Wilson Ltd. Any advice, opinions, or recommendations within this document should be read and relied upon only in the Scott House context of the document as a whole. The contents of this document do not provide legal Alençon Link or tax advice or opinion. Basingstoke © Scott Wilson Ltd 2010 Hampshire RG21 7PP

Tel 01256 310200 Fax 01256 310201

www.scottwilson.com

Broxbourne Borough Council Core Strategy

Table of Contents

1 Introduction ...... 5 1.1 Scope of the Project ...... 5 1.2 Current Legislation ...... 5 1.3 European Court of Justice Ruling...... 6 1.4 Scope of the Project ...... 7 1.5 This report ...... 7 2 Methodology ...... 8 2.1 Introduction...... 8 2.2 HRA Task 1 - Likely Significant Effects (LSE)...... 9 2.3 Appropriate Assessment and Mitigation...... 9 2.4 Confirming other plans and projects that may act in combination...... 10 3 Pathways of impact...... 13 3.1 Introduction...... 13 3.2 Urbanisation ...... 13 3.3 Recreational pressure ...... 14 3.4 Atmospheric pollution ...... 16 3.5 Water abstraction ...... 19 3.6 Water Quality...... 20 3.7 Summary of Screening...... 21 4 Wormley-Hoddesdonpark Woods SAC ...... 23 4.1 Introduction...... 23 4.2 Features of European Interest...... 23 4.3 Condition Assessment...... 23 4.4 Key Environmental Conditions ...... 24 4.5 Potential Effects of the Plan ...... 24 4.6 Summary ...... 29 5 Epping Forest SAC...... 30 5.1 Introduction...... 30 5.2 Features of European Interest...... 30 5.3 Condition Assessment...... 30 5.4 Key Environmental Conditions ...... 30 5.5 Potential Effects of the Plan ...... 31 5.6 Summary ...... 35

3 Broxbourne Borough Council Core Strategy

6 Lee Valley SPA / Ramsar ...... 36 6.1 Introduction...... 36 6.2 Features of European Interest...... 37 6.3 Condition Assessment...... 38 6.4 Key Environmental Conditions ...... 38 6.5 Potential Effects of the Plan ...... 39 6.6 Summary ...... 48 7 Overall conclusions ...... 49 Appendix 1: ‘Tiering’ in Habitat Regulations Assessment...... 50 Appendix 2 –Core Strategy Screening Summary...... 51

4 Broxbourne Borough Council Core Strategy

1 Introduction

1.1 Scope of the Project

1.1.1 Scott Wilson Ltd was appointed in June 2010 by Broxbourne Borough Council (“the Council”) to assist the Council in undertaking a Habitat Regulations Assessment of the Broxbourne Core Strategy (pre-submission version of 5th July 2010). The objective of the assessment was to identify any areas of the Core Strategy that had the potential to cause an adverse effect on Natura 2000 or European sites (Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Ramsar sites), either in isolation or in combination with other plans and projects, and to devise appropriate mitigation strategies where such effects were identified.

1.1.2 Once the final version of the Core Strategy has been produced this Assessment will be revised in order to verify that its recommendations have been acted upon and that its conclusions and recommendations are still appropriate. The purpose of this document is therefore that it will inform any necessary amendments to the final version of the Core Strategy.

1.1.3 Currently, the Local Development Framework (LDF) is at an early stage of development. The core LDF documents will ultimately consist of:

• The Core Strategy.

1.1.4 This current HRA report covers the Core Strategy only. As the subsequent DPD’s are produced, the assessment will be refreshed and updated. The LDF will supercede the current Local Plan (site allocations and generic development control policies adopted in 2005 and relevant to at least 2011) and Hertfordshire Structure Plan (adopted 1998, relevant to 2011), which is the strategic planning framework for the protection of the environment, major transport priorities, and the scale, pattern and broad location of new development including provision for new housing and major economic development across Hertfordshire. The Core Strategy states that the Council (from the recommendations of the Strategic Housing Market Assessment) considers there to be a need to build 3,840 dwellings by 2026, at a rate of 240 per year, to meet housing need within the borough without placing excessive pressure on the borough to accommodate new development. 1.2 Current Legislation

1.2.1 The need for Appropriate Assessment is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British law by Regulation 102 of the Conservation of Habitats and Species Regulations 2010. The ultimate aim of the Directive is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates to habitats and species, not the European sites themselves, although the sites have a significant role in delivering favourable conservation status.

1.2.2 The Habitats Directive applies the precautionary principle to protected areas (Special Areas of Conservation, SACs and Special Protection Areas, SPAs, collectively known as European sites and which comprise the Natura 2000 pan-European network). Plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. This is in contrast to the SEA Directive which does not

5 Broxbourne Borough Council Core Strategy

prescribe how plan or programme proponents should respond to the findings of an environmental assessment; merely that the assessment findings (as documented in the ‘environmental report’) should be ‘taken into account’ during preparation of the plan or programme. In the case of the Habitats Directive, plans and projects may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead. In such cases, compensation would be necessary to ensure the overall integrity of the site network.

1.2.3 In order to ascertain whether or not site integrity will be affected, an Appropriate Assessment should be undertaken of the plan or project in question:

Box 1. The legislative basis for Appropriate Assessment

Habitats Directive 1992

Article 6 (3) states that:

“Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives.”

Conservation of Habitats and Species Regulations 2010

Regulation 102 states that:

“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)….the plan- making authority for that plan must, before the plan is given effect, make an appropriate assessment of the implications for the site in view of that site’s conservation objectives.… … The plan-making authority ….must give effect to the land use plan only after having ascertained that it will not adversely affect the integrity of the European site”.

1.3 European Court of Justice Ruling

1.3.1 In October 2005, the European Court of Justice ruled that the UK had failed to correctly transpose the provisions of Articles 6(3) and (4) of Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora – the Habitats Directive – into national law. Specifically, the UK had failed to ensure that land use plans are subject to Appropriate Assessment where the development that they propose might have a significant effect on a Natura 2000 site.

1.3.2 Following the European Court ruling, the former Office of the Deputy Prime Minister (ODPM; now CLG) indicated that the regulations implementing the Habitats Directive in the UK would be amended to ensure that HRA explicitly applies to land use plans. Planning Policy Statement (PPS) 9 states that Ramsar sites (wetlands of international importance) should receive the same protection as designated SACs and SPAs.

1.3.3 Over the years the phrase ‘Habitat Regulations Assessment’ (HRA) has come into wide currency to describe the overall process set out in the Conservation (Natural Habitats &c) Regulations from screening through to IROPI. This has arisen in order to distinguish the process from the individual stage described in the law as an ‘appropriate assessment’.

6 Broxbourne Borough Council Core Strategy

Throughout this report we use the term Habitat Regulations Assessment for the overall process and restrict the use of Appropriate Assessment to the specific stage of that name. 1.4 Scope of the Project

1.4.1 The version of the Core Strategy that was assessed was the pre-submission Broxbourne Core Strategy of 5th July 2010.

1.4.2 There is no pre-defined guidance that dictates the physical scope of an HRA of a Core Strategy Therefore, in considering the physical scope of the assessment, we were guided primarily by the identified impact pathways rather than by arbitrary ‘zones’. Current guidance suggests that the following European sites be included in the scope of assessment:

• All sites within the Broxbourne Borough boundary; and • Other sites shown to be linked to development within the Borough boundary through a known ‘pathway’ (discussed below)

1.4.3 Briefly defined, pathways are routes by which a change in activity within the Core Strategy area can lead to an effect upon a European site. In terms of the second category of European site listed above, CLG guidance states that the AA should be ‘proportionate to the geographical scope of the [plan policy]’ and that ‘an AA need not be done in any more detail, or using more resources, than is useful for its purpose’ (CLG, 2006, p.6).

1.4.4 There are two European sites that lie wholly or partly within the borough of Broxbourne – Wormley Hoddesdonpark Woods SAC and the Lee Valley SPA and Ramsar site. European sites also lie in adjoining boroughs and the potential for longer range and indirect effects upon these sites has been considered at least in screening (Table 1). Figure 1 shows the location of the European sites in relation to Broxbourne Borough.

Table 1: European sites considered at the screening stage of the Habitats Regulations Assessment Site Minimum distance from Broxbourne Borough Wornley Hoddesdonpark Woods SAC Partially within the borough Lee Valley SPA/ Ramsar Partially within the borough Epping Forest SAC 3.5 km

1.5 This report

1.5.1 Chapter 2 of this report explains the process by which the HRA has been carried out. Chapter 3 explores the relevant pathways of impact and summarises the screening assessment of preferred policies. Chapters 4 to 6 are organised on the basis of one chapter per European site. Each chapter begins with a consideration of the interest features and ecological condition of the site and environmental process essential to maintain site integrity. An assessment of the Core Strategy in respect of each European site is then carried out and avoidance and mitigation strategies proposed where necessary. The key findings are summarised in Chapter 7: Conclusions.

7 Broxbourne Borough Council Core Strategy

2 Methodology

2.1 Introduction

2.1.1 The methodology adopted is in compliance with emerging Government guidance1.

2.1.2 The HRA has been carried out in the absence of formal Government guidance. Communities and Local Government released a consultation paper on Appropriate Assessment of Plans in 20062. As yet, no further formal guidance has emerged.

2.1.3 Figure 2 below outlines the stages of HRA according to current draft CLG guidance. The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no significant adverse effects remain.

Evidence Gathering – collecting information on relevant European sites, their conservation objectives and characteristics and other plans or projects.

HRA Task 1: Likely significant effects (‘screening’) – identifying whether a plan is ‘likely to have a significant effect’ on a European site

HRA Task 2: Ascertaining the effect on site integrity – assessing the effects of the plan on the conservation objectives of any European sites ‘screened in’ during AA Task 1

HRA Task 3: Mitigation measures and alternative solutions – where adverse effects are identified at AA Task 2, the plan should be altered until adverse effects are cancelled out fully

Figure 2 - Four-Stage Approach to Habitat Regulations Assessment Source: CLG, 2006

1 Planning for the Protection of European Sites: Appropriate Assessment. Under The Conservation (Natural Habitats, &c) (Amendment) (England and Wales) Regulations 2006 Guidance for Regional Spatial Strategies and Local Development Documents. 2 CLG (2006) Planning for the Protection of European Sites, Consultation Paper

8 Broxbourne Borough Council Core Strategy

2.2 HRA Task 1 - Likely Significant Effects (LSE)

2.2.1 The first stage of any Habitat Regulations Assessment is a Likely Significant Effect (LSE) test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:

2.2.2 ”Is the Plan, either alone or in combination with other relevant projects and plans, likely to result in a significant effect upon European sites?”

2.2.3 The objective is to ‘screen out’ those plans and projects that can, without any detailed appraisal, be said to be unlikely to result in significant adverse effects upon European sites, usually because there is no mechanism for an adverse interaction with European sites.

2.2.4 In this case, the plan as a whole has been evaluated in detail within the context of existing knowledge of the various ways in which development can impact on European sites, accumulated from carrying out HRA’s across the country at all geographical scales (from individual projects through to Regional Spatial Strategies). If it cannot be concluded with confidence that adverse effects are unlikely, we have deferred to the precautionary principle and assumed that they require investigation in the Appropriate Assessment. The previous draft of the Core Strategy was subject to a full Appropriate Assessment, which was consulted upon with Natural England. As such, part of the consideration of how much of the Core Strategy can be ‘screened out’ in this iteration relates to the extent to which previous recommendations have been incorporated.

2.3 Appropriate Assessment and Mitigation

2.3.1 With regard to those European sites where it is considered not possible to ‘screen out’ the Core Strategy without detailed appraisal, it is necessary to progress to the later ‘Appropriate Assessment’ stage to explore the adverse effects and devise mitigation.

2.3.2 The steps involved are detailed in Box 3.

Box 3. The steps involved in the Appropriate Assessment exercise undertaken for the Broxbourne Core Strategy

1. Explore the reasons for the European designation of these sites.

2. Explore the environmental conditions required to maintain the integrity of the selected sites and become familiar with the current trends in these environmental processes.

3. Gain a full understanding of the plan and its policies and consider each policy within the context of the environmental processes – would the policy lead to an impact on any identified process?

4. Decide if the identified impact is likely to lead to an adverse effect.

5. Identify other plans and projects that might affect these sites in combination with the Plan and decide whether there any adverse effects that might not result from the Plan in isolation will do so “in combination”.

6. Develop measures to avoid the effect entirely, or if not possible, to mitigate the impact sufficiently that its effect on the European site is rendered effectively inconsequential.

9 Broxbourne Borough Council Core Strategy

2.3.3 In evaluating significance, Scott Wilson have relied on our professional judgement as well as stakeholder consultation. We believe that we are in an excellent position to provide such judgement given our previous experience in undertaking HRA of plans in the East of England, South East and North West at RSS, LDF and Area Action Plan levels.

2.3.4 The level of detail concerning developments that will be permitted under land use plans will never be sufficient to make a detailed quantification of adverse effects. Therefore, we have again taken a precautionary approach (in the absence of more precise data) assuming as the default position that if an adverse effect cannot be confidently ruled out, avoidance or mitigation measures must be provided. This is in line with CLG guidance that the level of detail of the assessment, whilst meeting the relevant requirements of the Habitats Regulations, should be ‘appropriate’ to the level of plan or project that it addresses (see Appendix 1 for a summary of this ‘tiering’ of assessment).

2.3.5 When undertaking this part of the assessment it is essential to bear in mind the principal intention behind the legislation i.e. to ensure that those projects or plans which in themselves have minor impacts are not simply dismissed on that basis, but are evaluated for any cumulative contribution they may make to an overall significant effect. In practice, in combination assessment is therefore of greatest relevance when the plan would otherwise be screened out because its individual contribution is inconsequential.

2.4 Confirming other plans and projects that may act in combination

2.4.1 It is clearly neither practical nor necessary to assess the ‘in combination’ effects of the Core Strategy within the context of all other plans and projects within the East of England. In practice therefore, in combination assessment is of greatest relevance when the plan would otherwise be screened out because its individual contribution is inconsequential. For the purposes of this assessment, we have determined that, due to the nature of the identified impacts, the key other plans and projects relate to the additional housing, transportation and commercial/industrial allocations proposed for other neighbouring authorities over the lifetime of the Core Strategy. The draft updated East of England Plan (March 2010) provides a good introduction to proposals for areas surrounding Broxbourne Borough (Table 2). Although the East of England plan has since been abandoned, it still provides the best summary of the currently anticipated levels of housing within authorities surrounding Broxbourne. However it must be noted that Broxbourne’s Core Strategy indicates a target of 240 homes per annum or 3,840 homes to 2026.

Table 2. Housing levels to be delivered across Hertfordshire, and west Essex over the plan period (March 2010) Local Authority Annual housing average Total housing from 2011 to 2031 Hertfordshire 3,570 71,300 Broxbourne 240 5,040 Dacorum 310 6,100 East Hertfordshire 550 11,000 Hertsmere 250 5,000 North Hertfordshire 790 15,800 St. Albans 350 7,000 Stevenage 320 6,400 Three Rivers 200 4,000

10 Broxbourne Borough Council Core Strategy

Watford 260 5,100 Welwyn Hatfield 290 5,800 Essex - - Epping Forest 160 3,200 Harlow 800 16,000

2.4.2 There are other plans and projects that are often relevant to the ‘in combination’ assessment, most notably Thames Water’s Draft Water Resource Management Plan (September 2009), the Environment Agency’s River London Catchment Abstraction Management Strategy and the Rye Meads Water Cycle Study (2009). These have all been taken into account in this assessment.

2.4.3 The Regional Spatial Strategy for the East of England provides a good introduction to proposals for Hertfordshire as a whole, and surrounding counties.

2.4.4 The Hertfordshire Waste Development Framework is also of some relevance, since this may well contribute to increased vehicle movements on the road network within Broxbourne (and thereby contribute to air quality impacts). The Hertfordshire Local Transport Plans to 2011 will also be important in determining vehicle movements on the highways network in the short term. However, the major impact is likely to be that of housing and commercial development within the surrounding districts as set out in Local Development Frameworks and these have therefore been the main focus of cumulative ‘in combination’ effects with regard to this HRA. In this context, we have also consulted the Draft Replacement London Plan (2009) and the London Plan (2004).

2.4.5 However, the major impact is likely to be that of housing, employment and retail development within the surrounding boroughs as set out in Local Development Frameworks and these have therefore been the main focus of cumulative ‘in combination’ effects with regard to this HRA. Reference has also been made to the Lee Valley Regional Park Authority Park Development Framework, although it is at an early stage of development

2.4.6 In relation to recreational pressure, the following documents have been consulted for their plans and projects that may affect European sites in combination with development in Broxbourne: Lee Valley Regional Park Authority Site management Plan 2006-2011; Epping Forest Management Plan 2004-2010; Hoddesdonpark Wood Management Plan 2009-2014; Wormley Wood and Nut Wood Management Plan 2008-2013.

2.4.7 Table 3 summarises documents that we have reviewed to inform our assessment:

Table 3. Documents reviewed in order to inform this assessment Document Relevant contents Broxbourne Borough Broxbourne Core Strategy • Document under assessment. Council (2010) Thames Water Draft Water Resource • Sets out the proposed (September 2009) Management Plan approach to providing water resources in the future Environment Agency The London Catchment • Sets out the Environment (2006) Abstraction Management Plan Agency’s position regarding future abstraction within the London Catchment Environment Agency Stage 3 Appropriate • Understanding of existing (various) Assessments: Review of conditions at European sites Consents Hertfordshire County Hertfordshire Waste • Vehicle movements within Council Development Framework Broxbourne

11 Broxbourne Borough Council Core Strategy

Document Relevant contents Lee Valley Park Lee Valley Regional Park • Visions and objectives for the Authority Development park. Framework – Consultation Draft Environment Agency Water Resources Strategy • Sets out the Environment (2009) Regional Action Plan for the Agency’s plans for sustainable Thames Region management of water resources in the Thames region. Hyder Consultancy Rye Meads Water Cycle • Water resources (October 2009) Study APIS The UK Air Pollution • Air quality data at European Information System site. (www.apis.ac.uk); Natural England Nature on the Map and its • SSSI condition assessments links to SSSI citations and the JNCC website (www.natureonthemap.org.uk)

EERA The East of England Regional • Housing figures for Spatial Strategy HRA (2006); Broxbourne borough and for The East of England Regional surrounding boroughs. Spatial Strategy: Proposed • Other local proposals. Changes and Further • General development context Proposed Changes HRA for East England. (2007); Draft Revision to the East of England Regional Spatial Strategy: HRA (to be published in 2010).

Environment Agency The Impact of Housing and • Water resources (March 2009) Water Efficiency Policies on Water Supplies to the East of England – Evidence for the Review of the East of England Plan – RSS14 Entec/ Environment Impacts of Growth on Water • Sewage treatment capacity Agency/ Anglian Water Quality in the East of England: 2009 Interim Report to support the RSS Review’

12 Broxbourne Borough Council Core Strategy

3 Pathways of impact

3.1 Introduction

3.1.1 In carrying out an HRA it is important to determine the various ways in which land use plans can impact on European sites by following the pathways along which development can be connected with European sites, in some cases many kilometres distant. Briefly defined, pathways are routes by which a change in activity associated with a development can lead to an effect upon a European site. 3.2 Urbanisation

3.2.1 This impact is closely related to recreational pressure, in that they both result from increased populations within close proximity to sensitive sites. Urbanisation is considered separately as the detail of the impacts is distinct from the trampling, disturbance and dog- fouling that results specifically from recreational activity. The list of urbanisation impacts can be extensive, but core impacts can be singled out:

• Increased fly-tipping - Rubbish tipping is unsightly but the principle adverse ecological effect of tipping is the introduction of invasive alien species with garden waste. Garden waste results in the introduction of invasive aliens precisely because it is the ‘troublesome and over-exuberant’ garden plants that are typically thrown out3. Alien species may also be introduced deliberately or may be bird-sown from local gardens. • Cat predation - A survey performed in 1997 indicated that nine million British cats brought home 92 million prey items over a five-month period4. A large proportion of domestic cats are found in urban situations, and increasing urbanisation is likely to lead to increased cat predation.

3.2.2 The most detailed consideration of the link between relative proximity of development to European sites and damage to interest features has been carried out with regard to the Thames Basin Heaths SPA.

3.2.3 After extensive research, Natural England and its partners produced a ‘Delivery Plan’ which made recommendations for accommodating development while also protecting the interest features of the European site. This included the recommendation of implementing a series of zones within which varying constraints would be placed upon development. While the zones relating to recreational pressure expanded to 5km (as this was determined from visitor surveys to be the principal recreational catchment for this European site), that concerning other aspects of urbanisation (particularly predation of the chicks of ground-nesting birds by domestic cats) was determined at 400m from the SPA boundary. The delivery plan concluded that the adverse effects of any development located within 400m of the SPA boundary could not be mitigated since this was the range within cats could be expected to roam as a matter of routine and there was no realistic way of restricting their movements, and as such, no new housing should be located within this zone.

3.2.4 No exact correlation can be made between the incidence of fly-tipping and deliberate arson and the specific proximity of large-scale human settlement, since it does depend on

3 Gilbert, O. & Bevan, D. 1997. The effect of urbanisation on ancient woodlands. British Wildlife 8: 213-218. 4 Woods, M. et al. 2003. Predation of wildlife by domestic cats Felis catus in Great Britain. Mammal Review 33, 2 174-188

13 Broxbourne Borough Council Core Strategy

circumstances. However, it is reasonable to conclude that the incidence will be highest when human settlement is very near (for the purposes of this assessment we have as a precaution defined ‘very near’ as being within 500m rather than immediately adjacent). While this is not an empirically derived distance, it does enable urbanisation effects to be assessed at this high level. These impacts would need to be evaluated in more detail when individual site proposals and masterplans were developed.

3.2.5 It was therefore concluded that adverse effects from the Core Strategy on European sites as a result of urbanisation could not be described as inherently unlikely and required further investigation at the Appropriate Assessment stage. 3.3 Recreational pressure

3.3.1 All types of terrestrial European site, including woodlands, can be affected by trampling, which in turn causes soil compaction and erosion. Motorcycle scrambling and off-road vehicle use can cause more serious erosion, as well as disturbance to sensitive species.

3.3.2 There have been several papers published that empirically demonstrate that damage to vegetation in woodlands and other habitats can be caused by vehicles, walkers, horses and cyclists:

• Wilson & Seney (1994)5 examined the degree of track erosion caused by hikers, motorcycles, horses and cyclists from 108 plots along tracks in the Gallatin National Forest, Montana. Although the results proved difficult to interpret, it was concluded that horses and hikers disturbed more sediment on wet tracks, and therefore caused more erosion, than motorcycles and bicycles. • Cole et al (1995a, b)6 conducted experimental off-track trampling in 18 closed forest, dwarf scrub and meadow & grassland communities (each tramped between 0 – 500 times) over five mountain regions in the US. Vegetation cover was assessed two weeks and one year after trampling, and an inverse relationship with trampling intensity was discovered, although this relationship was weaker after one year than two weeks indicating some recovery of the vegetation. Differences in plant morphological characteristics were found to explain more variation in response between different vegetation types than soil and topographic factors. Low-growing, mat-forming grasses regained their cover best after two weeks and were considered most resistant to trampling, while tall forbs (non-woody vascular plants other than grasses, sedges, rushes and ferns) were considered least resistant. Cover of hemicryptophytes and geophytes (plants with buds below the soil surface) was heavily reduced after two weeks, but had recovered well after one year and as such these were considered most resilient to trampling. Chamaephytes (plants with buds above the soil surface) were least resilient to trampling. It was concluded that these would be the least tolerant of a regular cycle of disturbance. • Cole (1995c)7 conducted a follow-up study (in 4 vegetation types) in which shoe type (trainers or walking boots) and trampler weight were varied. Although immediate

5 Wilson, J.P. & J.P. Seney. 1994. Erosional impact of hikers, horses, motorcycles and off road bicycles on mountain trails in Montana. Mountain Research and Development 14:77-88 6 Cole, D.N. 1995a. Experimental trampling of vegetation. I. Relationship between trampling intensity and vegetation response. Journal of Applied Ecology 32: 203-214 Cole, D.N. 1995b. Experimental trampling of vegetation. II. Predictors of resistance and resilience. Journal of Applied Ecology 32: 215-224 7 Cole, D.N. 1995c. Recreational trampling experiments: effects of trampler weight and shoe type. Research Note INT-RN-425. U.S. Forest Service, Intermountain Research Station, Utah.

14 Broxbourne Borough Council Core Strategy

damage was greater with walking boots, there was no significant difference after one year. Heavier tramplers caused a greater reduction in vegetation height than lighter tramplers, but there was no difference in effect on cover. • Cole & Spildie (1998)8 experimentally compared the effects of off-track trampling by hiker and horse (at two intensities – 25 and 150 passes) in two woodland vegetation types (one with an erect forb understorey and one with a low shrub understorey). Horse traffic was found to cause the largest reduction in vegetation cover. The forb- dominated vegetation suffered greatest disturbance, but recovered rapidly. Higher trampling intensities caused more disturbance.

3.3.3 Many wetland sites, and particularly the Lee Valley, are extensively used for recreational activity by people from a wide-ranging catchment that includes the whole of Hertfordshire and also draw visitors from further afield. Activities of walkers (particularly dog walkers) and water-borne recreation can, if carried out in winter, have a significant disturbing effect upon wintering waterfowl thus increasing energetic expenditure (as birds have to take flight more frequently) and competition on the less disturbed parts of the wetland9.

3.3.4 Analysis of the latest England Day Visits Survey10 indicates that people typically travel:

• 10.8 miles (17.2 km) to visit a countryside site for the day; • 11.3 miles (18.1 km) to visit a woodland site for the day; and • 16 miles (25.5 km) to visit a coastal site for the day.

3.3.5 In all cases, more journeys were made by car than on foot. It should be noted that these are generalised figures; individual European sites may draw the majority of their visitors from a much smaller catchment (e.g. Thames Basin Heaths SPA, which draws 96% of its visitors from within 5 km11) or a much larger one (e.g. the New Forest SAC, for which 55% of visitors are holidaymakers rather than locals12). Although we have tried to obtain visitor survey and recreational catchment data relating to Wormley Hoddesdonpark Woods SAC, we have been unable to obtain any quantitative data. However, we have obtained detailed information for Epping Forest SAC and some information relating to the Lee Valley SPA.

3.3.6 In the absence of more precise visitor surveys for the European sites considered in this assessment, we take the England Day Visits data as broadly ‘typical’ of the distances that residents may travel to visit European sites, this means that all of those sites within these distances could be affected by trampling or (in the case of the Lee Valley SPA) disturbance of sensitive wildlife as a result of the population increase in Broxbourne associated with delivery of 3,840 new homes in the borough during the lifetime of the plan to 2026.

8 Cole, D.N., Spildie, D.R. 1998. Hiker, horse and llama trampling effects on native vegetation in Montana, USA. Journal of Environmental Management 53: 61-71 9 West, A.D., et al. 2002. Predicting the impacts of disturbance on shorebird mortality using a behaviour-based model. Biological Conservation 106:3, 319-328 10 Various. 2006. England Leisure Visits: the Results of the 2005 Survey. Countryside Agency (now Natural England) 11 Liley, D. et al. 2005. Visitor access patterns on the Thames Basin Heaths. English Nature Research Report, English Nature, Peterborough 12 Forestry Commission. 2005. New Forest Visitor Survey.

15 Broxbourne Borough Council Core Strategy

3.3.7 It was therefore concluded that adverse effects from the Core Strategy on European sites as a result of recreational pressure could not be described as inherently unlikely. These therefore require further investigation at the Appropriate Assessment stage.

3.4 Atmospheric pollution

3.4.1 Current levels of understanding of air quality effects on semi-natural habitats are not adequate to allow a rigorous assessment of the likelihood of significant effects on the integrity of key European sites.

Table 4. Main sources and effects of air pollutants on habitats and species Pollutant Source Effects on habitats and species

Acid SO2, NOx and ammonia all contribute to acid Can affect habitats and species through deposition deposition. Although future trends in S both wet (acid rain) and dry deposition. emissions and subsequent deposition to Some sites will be more at risk than others terrestrial and aquatic ecosystems will depending on soil type, bed rock geology, continue to decline, it is likely that increased N weathering rate and buffering capacity. emissions may cancel out any gains produced by reduced S levels. Ammonia Ammonia is released following decomposition Adverse effects are as a result of nitrogen (NH3) and volatilisation of animal wastes. It is a deposition leading to eutrophication. As naturally occurring trace gas, but levels have emissions mostly occur at ground level in increased considerably with expansion in the rural environment and NH3 is rapidly numbers of agricultural livestock. Ammonia deposited, some of the most acute problems reacts with acid pollutants such as the of NH3 deposition are for small relict nature products of SO2 and NOX emissions to reserves located in intensive agricultural produce fine ammonium (NH4+)- containing landscapes. aerosol which may be transferred much longer distances (can therefore be a significant trans- boundary issue.) Nitrogen Nitrogen oxides are mostly produced in Deposition of nitrogen compounds (nitrates oxides combustion processes. About one quarter of (NO3), nitrogen dioxide (NO2) and nitric acid NOx the UK’s emissions are from power stations, (HNO3)) can lead to both soil and freshwater one-half from motor vehicles, and the rest from acidification. In addition, NOx can cause other industrial and domestic combustion eutrophication of soils and water. This alters processes. the species composition of plant communities and can eliminate sensitive species. Nitrogen (N) The pollutants that contribute to nitrogen Species-rich plant communities with deposition deposition derive mainly from NOX and NH3 relatively high proportions of slow-growing emissions. These pollutants cause acidification perennial species and bryophytes are most (see also acid deposition) as well as at risk from N eutrophication, due to its eutrophication. promotion of competitive and invasive species which can respond readily to elevated levels of N. N deposition can also increase the risk of damage from abiotic factors, e.g. drought and frost. Ozone (O3) A secondary pollutant generated by Concentrations of O3 above 40 ppb can be photochemical reactions from NOx and volatile toxic to humans and wildlife, and can affect organic compounds (VOCs). These are buildings. Increased ozone concentrations mainly released by the combustion of fossil may lead to a reduction in growth of fuels. The increase in combustion of fossil agricultural crops, decreased forest fuels in the UK has led to a large increase in production and altered species composition background ozone concentration, leading to an in semi-natural plant communities. increased number of days when levels across the region are above 40ppb. Reducing ozone pollution is believed to require action at international level to reduce levels of the precursors that form ozone.

16 Broxbourne Borough Council Core Strategy

Pollutant Source Effects on habitats and species

Sulphur Main sources of SO2 emissions are electricity Wet and dry deposition of SO2 acidifies soils Dioxide generation, industry and domestic fuel and freshwater, and alters the species SO2 combustion. May also arise from shipping and composition of plant and associated animal increased atmospheric concentrations in busy communities. The significance of impacts ports. Total SO2 emissions have decreased depends on levels of deposition and the substantially in the UK since the 1980s. buffering capacity of soils.

3.4.2 The main pollutants of concern for European sites are oxides of nitrogen (NOx), ammonia

(NH3) and sulphur dioxide (SO2). NOx can have a directly toxic effect upon vegetation. In addition, greater NOx or ammonia concentrations within the atmosphere will lead to greater rates of nitrogen deposition to soils. An increase in the deposition of nitrogen from the atmosphere to soils is generally regarded to lead to an increase in soil fertility, which can have a serious deleterious effect on the quality of semi-natural, nitrogen-limited terrestrial habitats.

3.4.3 Sulphur dioxide emissions are overwhelmingly influenced by the output of power stations and industrial processes that require the combustion of coal and oil. Ammonia emissions are dominated by agriculture, with some chemical processes also making notable

contributions. As such, it is unlikely that material increases in SO2 or NH3 emissions will be associated with Local Development Frameworks. NOx emissions, however, are dominated by the output of vehicle exhausts (more than half of all emissions). Within a ‘typical’ housing development, by far the largest contribution to NOx (92%) will be made by the associated road traffic. Other sources, although relevant, are of minor importance (8%) in comparison13. Emissions of NOx could therefore be reasonably expected to increase as a result of greater vehicle use as an indirect effect of the LDF.

3.4.4 According to the World Health Organisation, the critical NOx concentration (critical threshold) for the protection of vegetation is 30 µgm-3; the threshold for sulphur dioxide is 20 µgm-3. In addition, ecological studies have determined ‘critical loads’14 of atmospheric

nitrogen deposition (that is, NOx combined with ammonia NH3)..

3.4.5 The National Expert Group on Transboundary Air Pollution (2001)15 concluded that:

• In 1997, critical loads for acidification were exceeded in 71% of UK ecosystems. This was expected to decline to 47% by 2010.

• Reductions in SO2 concentrations over the last three decades have virtually eliminated the direct impact of sulphur on vegetation. • By 2010, deposited nitrogen was expected to be the major contributor to acidification, replacing the reductions in SO2. • Current nitrogen deposition is probably already changing species composition in many nutrient-poor habitats, and these changes may not readily be reversed. • The effects of nitrogen deposition are likely to remain significant beyond 2010. • Current ozone concentrations threaten crops and forest production nationally. The effects of ozone deposition are likely to remain significant beyond 2010.

13 Proportions calculated based upon data presented in Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 14 The critical load is the rate of deposition beyond which research indicates that adverse effects can reasonably be expected to occur 15 National Expert Group on Transboundary Air Pollution (2001) Transboundary Air Pollution: Acidification, Eutrophication and Ground-Level Ozone in the UK.

17 Broxbourne Borough Council Core Strategy

• Reduced inputs of acidity and nitrogen from the atmosphere may provide the conditions in which chemical and biological recovery from previous air pollution impacts can begin, but the timescales of these processes are very long relative to the timescales of reductions in emissions.

3.4.6 Grice et al1617 do however suggest that air quality in the UK will improve significantly over the next 15 years due primarily to reduced emissions from road transport and power stations.

Local air pollution

3.4.7 According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”18.

Figure 3. Traffic contribution to concentrations of pollutants at different distances from a road (Source: DfT)

3.4.8 This is therefore the distance that has been used throughout this HRA in order to determine whether European sites are likely to be significantly affected by development under the Core Strategy. Given that sites detailed in Table 5 that lie within 200m of major roads that may be regularly used by vehicle journeys arising from Broxbourne as a result of the increased population, it was concluded that air quality should be included within the scope of this assessment. The location of these roads in relation to the European sites is shown in Figure 1.

Table 5. Major roads within 200 m of the three European sites considered in detail within this assessment Site Major Roads in Close Proximity Wornley Hoddesdonpark Woods None within 200m SAC

16 Grice, S., T. Bush, J. Stedman, K. Vincent, A. Kent, J. Targa and M. Hobson (2006) Baseline Projections of Air Quality in the UK for the 2006 Review of the Air Quality Strategy, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland. 17 Grice, S., J. Stedman, T. Murrells and M. Hobson (2007) Updated Projections of Air Quality in the UK for Base Case and Additional Measures for the Air Quality Strategy for England, Scotland, Wales and Northern Ireland 2007, report to the Department for Environment, Food and Rural Affairs, Welsh Assembly Government, the Scottish Executive and the Department of the Environment for Northern Ireland. 18 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf

18 Broxbourne Borough Council Core Strategy

Lee Valley SPA/ Ramsar None within 200m Epping Forest SAC M25, A1400, A104, A121, A114

Diffuse air pollution

3.4.9 In addition to the contribution to local air quality issues, development can also contribute cumulatively to an overall deterioration in background air quality across an entire region. In July 2006, when this issue was raised by Runnymede Borough Council in the South East, Natural England advised that their Local Development Framework ‘can only be concerned with locally emitted and short range locally acting pollutants’ as this is the only scale which falls within a local authority remit. It is understood that this guidance was not intended to set a precedent, but it inevitably does so since (as far as we are aware) it is the only formal guidance that has been issued to a Local Authority from any Natural England office on this issue.

3.4.10 In the light of this, diffuse air quality issues will not therefore be considered further within this HRA. 3.5 Water abstraction

3.5.1 The East of England is generally an area of high water stress. Much of England has experienced low rainfall for most of the last few years, including dry winters. The East of England is the driest region in the country receiving only two thirds of the average UK annual rainfall. Expected climate change trends for the East are for drier summers, wetter winters, and more extreme events. If the current climate trends continue, it may be impractical in the longer term to preserve wetland habitats characteristic of our former climate but in the short and medium term, it is clear that strenuous efforts to reduce the risk of water stress in European wetland sites should be a priority. The potential for severe water stress is evidenced by Figure 4.

19 Broxbourne Borough Council Core Strategy

Figure 4. Areas of water stress within England. It can be seen from this map that Hertfordshire and Broxbourne Borough are classified as being an area of serious water stress (coded red).19

3.5.2 Development within Broxbourne Borough over the plan period will increase water demand. There is a risk that increased abstraction will lower water levels within watercourses that are designated as or which feed European sites, thereby reducing freshwater inputs. This could potentially lead to increased salinity of saltmarshes, increased sedimentation of the river channel due to reduced flows and a reduction in the freshwater available to SPA birds for drinking and bathing20.

3.5.3 Since the River Lee and its associated reservoirs form a major component of the water resource for Broxbourne, it was therefore concluded that adverse effects from the Core Strategy on European sites as a result of increased abstraction from sensitive surface and groundwater sources could not be described as inherently unlikely. These therefore require further investigation at the Appropriate Assessment stage. 3.6 Water Quality

3.6.1 Increased amounts of housing or business development can lead to reduced water quality of rivers and estuarine environments. Sewage and industrial effluent discharges can contribute to increased nutrients on European sites leading to unfavourable conditions. In addition, diffuse pollution, partly from urban run-off has been identified during an Environment Agency Review of Consents process, as being a major factor in causing unfavourable condition of European sites.

3.6.2 The quality of the water that feeds European sites is an important determinant of the nature of their habitats and the species they support. Poor water quality can have a range of environmental impacts:

19 Figure adapted from Environment Agency. 2007. Identifying Areas of Water Stress. http://publications.environment-agency.gov.uk/pdf/GEHO0107BLUT-e-e.pdf 20 Ravenscroft, N.O.M. and Beardalb, C.H. 2003. The importance of freshwater flows over estuarine mudflats for wintering waders and wildfowl. Biological Conservation, 113:1, 89-97

20 Broxbourne Borough Council Core Strategy

• At high levels, toxic chemicals and metals can result in immediate death of aquatic life, and can have detrimental effects even at lower levels, including increased vulnerability to disease and changes in wildlife behaviour. • Eutrophication, the enrichment of plant nutrients in water, increases plant growth and consequently results in oxygen depletion. Algal blooms, which commonly result from eutrophication, increase turbidity and decrease light penetration. The decomposition of organic wastes that often accompanies eutrophication deoxygenates water further, augmenting the oxygen depleting effects of eutrophication. In the marine environment, nitrogen is the limiting plant nutrient and so eutrophication is associated with discharges containing available nitrogen. • Some pesticides, industrial chemicals, and components of sewage effluent are suspected to interfere with the functioning of the endocrine system, possibly having negative effects on the reproduction and development of aquatic life.

3.6.3 For sewage treatment works close to capacity, further development may increase the risk of effluent escape into aquatic environments. In many urban areas, sewage treatment and surface water drainage systems are combined, and therefore a predicted increase in flood and storm events could increase pollution risk.

3.6.4 Given that the key sewage treatment works for Broxbourne discharge to the River Lee, it was concluded that adverse effects from the Core Strategy on European sites as a result of deteriorating water quality could not be described as inherently unlikely. These therefore require further investigation at the Appropriate Assessment stage.

3.7 Summary of Screening

3.7.1 The overall conclusion of the Likely Significant Effect stage was therefore that adverse effects on European sites from the Core Strategy could not be described as inherently unlikely and further investigation was required at the Appropriate Assessment stage. That more detailed assessment is the subject of the remainder of this document. Each European site considered in the assessment is accorded its own chapter.

3.7.2 All consultation draft policies within the Core Strategy were screened for potential conflicts within European sites. The majority of the draft policies could be ‘screened out’ as there was no potential for any of these policy options to result in adverse effects on European sites. The full screening table for the draft policies is contained within Appendix 2.

3.7.3 The following draft policies were deemed to require consideration as they may lead to adverse effects on European sites generally because they promote and determine the location or scale of development (particularly housing and commercial development):

• CS1 - Sustainable Neighbourhoods; • CS2 - Housing Development; • CS3 - Housing Mix; • CS4 – Travelling Community • CS5 - Employment; • CS6 - Retail and Town Centres; and • CS7 -Greater Brookfield.

21 Broxbourne Borough Council Core Strategy

3.7.4 It should be noted that only policies that have the potential for negative impact on European sites are screened in for assessment. Those policies that might have a beneficial effect are referred to where appropriate in the following chapters, but have not been actually assessed. This is due to the fact that HRA is only concerned with adverse effects.

22 Broxbourne Borough Council Core Strategy

4 Wormley-Hoddesdonpark Woods SAC

4.1 Introduction

4.1.1 The Wormley-Hoddesdonpark Woods SAC consists of two SSSI’s – Wormley- Hoddesdonpark Wood North SSSI and Wormley-Hoddesdonpark Wood South SSSI which cover the majority of the SAC area.

4.1.2 A series of discreet woodland blocks lying mainly on acid gravel deposits over the London Clay, these woods have developed from ancient wood-pasture and heaths, and retain many large oak and hornbeam pollards along the boundaries. More basic conditions arise from prevalence of boulder clays to the north of the site. This range of geological conditions and the variety of past management regimes has resulted in a varied woodland structure, wide habitat diversity and a correspondingly rich flora. Despite extensive clearance and replanting with conifers the remaining semi-natural woodland is of national importance as an example of lowland south-east sessile oak/hornbeam type with the pedunculate oak/hornbeam variant also present. Small ponds and streams are important habitats for bryophyte species dependent on shady, wet and acidic conditions.

4.1.3 Nationally the woods are regarded as the best remaining example of the south-east Sessile Oak-Hornbeam woods with associated flora and fauna. The Pedunculate Oak-Hornbeam variant is also represented, adding variety to the site. 4.2 Features of European Interest

4.2.1 Wormley Hoddesdonpark Woods SAC has large stands of almost pure hornbeam Carpinus betulus (former coppice), with sessile oak Quercus petraea standards. Areas dominated by bluebell Hyacinthoides non-scripta do occur, but elsewhere there are stands of great wood- rush Luzula sylvatica with carpets of the mosses Dicranum majus and Leucobryum glaucum. Locally, a bryophyte community more typical of continental Europe occurs, including the mosses Dicranum montanum, D. flagellare and D. tauricum. Approximately 70% of the site is a National Nature Reserve. The site is designated as an SAC for its:

• Sub-Atlantic and medio-European oak or oak-hornbeam forests of the Carpinion betuli

4.3 Condition Assessment

4.3.1 During the most recent Condition Assessment process, some areas of the northern woods were noted to be recovering from unauthorised ‘war games’ and four-wheel drive vehicle usage. However, the tone of the comments is that these are exceptional circumstances, although an area of the site is of status ‘unfavourable no change’ due to the presence of fly tipping and absence of active management. 98.65% of the site was in “favourable” condition. One part of the south woods was noted as being subject to an ongoing problem of abandoned cars, although this compartment was nonetheless judged to be in favourable condition indicating that the car dumping, while undesirable, is not perhaps yet at the level that results in a net adverse effect on the interest features of the site. 75% of the site was in favourable condition. Unfavourable areas of the site were suffering from the effects of car dumping and a requirement for further active management.

23 Broxbourne Borough Council Core Strategy

4.4 Key Environmental Conditions

4.4.1 The key environmental conditions that support the features of European interest are:

• Minimal air pollution – nitrogen deposition may cause reduction in diversity, sulphur deposition can cause acidification; • Balanced hydrological regime - Meandering high-quality streams run eastward along the shallow valleys (Wormleybury Brook and Spital Brook). There are several ponds, especially in Westfield Grove; • Absence of direct fertilisation; and • Well-drained soils.

4.5 Potential Effects of the Plan

Urbanisation

Adverse effects of the Core Strategy

4.5.1 The nearest current urban area is Broxbourne town itself, which lies over 600 m east of the SAC (specifically Wormley Hoddesdonpark Wood North SSSI). Hoddesdon lies only slightly further away. The site is already recorded as being subject to a number of impacts that are associated with the close proximity of large urban development – car dumping, fly tipping etc. and, despite the fact that the urban development is situated more than 500m distant, this is the most likely source of such activities. While the condition assessment seems to indicate that these activities are not at this stage having a significant adverse effect on the site as a whole, clearly an increase in the urban population may bring with it an increase in such activities and these may result in an adverse effect.

4.5.2 The draft policy ‘CS2 - Housing Development’ focuses on urban sites, Greater Brookfield, small ‘edge of urban area’ sites and large greenbelt sites. One area highlighted in the background text is the ‘West of Hoddesdon’ area of search (urban edge of Hoddesdon and the A10) with the potential for up to 1,000 dwellings during the plan period, along with 790 dwellings within the Hoddesdon Urban SHLAA site. The Broxbourne Urban SHLAA site will gain 380 dwellings during the plan period. If one takes the average Broxbourne occupancy of 2.3 people per dwelling, the 1,790 houses in Hoddesdon would result in a population increase of 20.3%21. For Broxbourne the 380 dwellings would result in a population increase of 6.6%22. While this is small in itself it would have a cumulative impact when considered within the context of the urbanisation effects being delivered by the existing development. As such, and since Habitat Regulations Assessment must take the precautionary approach of assuming there is an adverse effect unless it can be demonstrated otherwise, it is not possible to conclude with confidence that increased housing within the Broxbourne town/Hoddesdon/A10 corridor will not lead to an adverse effect upon the SAC, when considered as a cumulative pressure with the existing development.

21 The 2001 population of Hoddesdon was approximately 20,250 people. 22 The 2001 population of Broxbourne was approximately 13,300 people

24 Broxbourne Borough Council Core Strategy

Mitigating aspects of the Core Strategy

4.5.3 Various policies will provide a measure of direct control over the ‘urbanisation’ issue:

• CS1 -Sustainable Neighbourhoods – this policy includes the statement that ’development will…provide …. habitats for wildlife.’ • CS2 -Housing Development – this policy states that ‘allocating and phasing small edge of urban area sites…in response to…local environmental capacity’ and ‘allocating and phasing large green belt sites…based on…local environmental capacity’ and ‘masterplans for Greater Brookfield and large greenbelt sites…should address a full range of issues which are likely to inform a major development proposal including….landscape impacts, wildlife and biodiversity.’ • CS4 – Travelling Communities – this policy states that ‘sites should not be on…important protected sites.’ • Environment – ‘Conserve and enhance…. all sites in and adjoining the borough which are protected by the planning system for their landscape, wildlife, scientific and/or archaeological value will be conserved and enhanced in accordance with national and local objectives.’

4.5.4 However, the statements in the first three policies are oblique and would require further clarification in order to ensure that they could prevent adverse effects upon the SAC. The fourth policy does include a specific reference to conserve sites protected by the planning system, which includes SACs. However, in practice this is a statement of the legal position rather than a description of active measures to be implemented by the Council. In addition to this passive measure it is therefore advised that a more active measure is required.

Additional measures recommended

4.5.5 It is inevitable that the main existing urban locations within the borough should be the focus of development (and ultimately this is more desirable and logical than dispersing the housing across the rural parts of the borough). Therefore it is inevitable that it cannot be sensibly located a long way from the SAC (which would be the easiest way to avoid an effect). In order to be sure that the development around West Hoddesdon and within Hoddesdon and Broxbourne urban areas will not lead to adverse effects upon Wormley Hoddesdonpark Woods SAC as a result of increase ‘urbanisation’ impacts, some further clarity is required within the Core Strategy.

The Council should make a specific commitment to assist with the installation of measures (e.g. fencing and other measures to prevent cars entering the woods and/or increased surveillance23) to control any increase in ‘urbanisation’ and anti-social behaviour impacts upon Wormley Hoddesdonpark Woods SAC that might result from new development in the borough. The ‘Planning Conditions policy would seem the appropriate place for such a reference.

4.5.6 If this additional proactive measure was incorporated it would be possible to conclude that the Core Strategy is unlikely to have an adverse effect on Wormley Hoddesdonpark Woods SAC as a result of urbanisation.

23 Precise details of measures to be implemented and actual scale of any contribution would need to be agreed with Natural England and relevant landowners

25 Broxbourne Borough Council Core Strategy

Recreational Pressure

Adverse effects of the Core Strategy

4.5.7 We have only been able to obtain a limited amount of data with regards to the recreational use of Wormley-Hoddesdonpark Woods SAC, namely from the Woodland Trust’s management plan for Wormley Wood and Nut Wood (part of the Broxbourne NNR, which overlaps in part with the SAC). The management plan states that wood is ‘well used for quiet and informal recreation, primarily by locals, visitors from nearby towns and those enjoying a longer walk through the countryside.’

4.5.8 Therefore, if, in the absence of specific data regarding the recreational catchment of Wormley Hoddesdonpark Woods SAC, we take as a proxy the England Day Visits data as broadly ‘typical’ of the distances that residents may travel to visit large woodland sites (i.e. 18km), it is clear that Wormley Hoddesdonpark Woods SAC will form a significant recreational resource for the borough. If we assume 2.2 people per household, then even if only 10% of the additional population regularly visited the site, this would still constitute an additional 1,144 recreational visitors from Broxbourne alone. While this is ultimately positive, recreation must be controlled and directed to avoid an adverse effect and clearly this would be made more difficult through the construction of up to 3,840 new homes within the borough. Moreover, these additional homes must be considered within the context of a further approximately 71,300 new homes that will be delivered elsewhere in Hertfordshire during the same period some of which may also be making a contribution to increased recreational pressure on the SAC.

4.5.9 That said, there are clearly defined footpaths within the woodlands to which the majority of recreational users adhere. Moreover, wet conditions can make these footpaths difficult to navigate thereby further reducing recreational usage of the woods to a level below that which might otherwise be expected for such a prominent feature. The most recent Natural England condition assessment recorded that recreational activity on the site is fairly well controlled. However, that control could be at risk if recreational use increases rapidly.

4.5.10 It should be noted that there is an inherent conflict between Government policy to increase public access to the natural environment (as embodied in the CRoW Act) and the requirements of European site management which often require visitor numbers to be controlled. However, ultimately, the legal requirements of the Conservation (Natural Habitats &c) Regulations should override national policy where such a conflict exists unless the policy is considered to represent an Imperative Reason of Overriding Interest as defined in the Regulations.

Mitigating aspects of the Core Strategy

4.5.11 Various policies will provide opportunities to control recreational pressure and/or deliver additional green space or greater access to existing green space:

• CS1 -Sustainable Neighbourhoods – this policy includes the statement that ’development will…provide …. habitats for wildlife.’ • CS2 - Housing development – ‘The Council working in partnership with developers, landowners, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including ….open spaces…. landscape impacts, wildlife and biodiversity.’

26 Broxbourne Borough Council Core Strategy

• CS8 - Environment – ‘The following green corridors will be protected and enhanced to help link open spaces in towns with surrounding countryside: the Lee Valley Regional Park, the New River green chain, Spital Brook valley between Barclay Park and Hoddesdonpark Wood, Rags Brook valley between Rosedale and Cheshunt Common, Wormley playing fields and Theobalds Brook from Cedars Park into Theobalds Park.’ ‘All sites in and adjoining the borough which are protected by the planning system for their landscape, wildlife, scientific and /or archaeological value will be conserved and enhanced in accordance with national guidance and local objectives.’ ‘Seek to maintain and increase the quantity and accessibility of open space throughout the borough in accordance with the following standards.’

Space per 1,000 residents Accessibility Parks and Gardens 0.28 hectares 15 min walk Natural and Semi-Natural 1.26 hectares 15 min walk Space Amenity Greenspace 0.46 hectares 10 min walk Provision for Children 0.04 hectares 10 min walk Teenage Provision 0.02 hectares 15 min walk Allotments 0.2 hectares 15 min walk Outdoor Sports Facilities 1.88 hectares 15 min walk i.e. sports pitches, tennis courts Outdoor Sports Facilities i.e. golf courses, swimming 1.88 hectares 20 min drive pools

• Planning conditions – ‘The Council will seek planning contributions from new development in accordance with national guidance and to help fund policy objectives set out in the Core Strategy, the Sustainable Community Strategy and other planning documents such as town centre strategies and development briefs. The Council will prepare an Infrastructure Schedule covering the items listed below to map existing provision, identify any areas of surplus or deficit and plan for future needs. This will be combined with viability appraisal work to inform a Planning Obligations SPD…..Open space, sports facilities and green infrastructure’

4.5.12 Due to the limitations of the assessment tools and data available at this time (and in particular the inability to quantify the number of residents of each allocated site that will be making use of the European sites in question and what proportion of the total cumulative load this represents), coupled with the need for any standards within the Core Strategy to be generally applicable (it not being possible to devise a unique policy or standard for each allocated site), it is not possible for the Core Strategy to specify an exact quantity of alternative natural greenspace that will need to be provided for individual developments in order to absorb recreational visitors to such an extent that they will not materially contribute towards recreational pressure on the European sites in question.

4.5.13 Natural England's more general Accessible Natural Greenspace Standards (ANGSt) provide a set of benchmarks for ensuring access to places of wildlife interest and were specifically developed to provide size and distance criteria to provide natural spaces that will contribute most towards sustainable use of recreational resources. While the criteria were not developed with the specific intention of mitigating for adverse impacts on

27 Broxbourne Borough Council Core Strategy

European sites, they were intended to specify a level of semi-natural greenspace provision that would meet the needs of a development’s population.

4.5.14 In many cases natural greenspace provision to the ANG Standard should therefore serve to minimise the need for recreational resources further afield (i.e. European sites) to receive an unsustainably large influx of visitors provided that they are delivered within a timescale linked to that of the development and will fulfil a function similar to that of the European site in question (i.e. dog walking and appreciation of nature rather than more formal recreational activities). For these reasons, we have selected the Natural England ANG standards as the criterion for semi-natural greenspace provision that the Core Strategy should require developments to meet in order to ensure that sufficient recreational space is provided to minimise adverse effects on the identified European sites.

4.5.15 The stipulation that new natural and semi-natural greenspace will be provided at a rate of over 1 ha/1000 population does fit with our core recommendation from the HRA of the preferred options Core Strategy regarding the ANG Standard.

4.5.16 In addition, the Environment policy does provide a mechanism for providing open space by seeking minimum areas close to residents, although this is not stringent or detailed enough in itself to ensure that no adverse effects would occur at the SAC. Further detail is required regarding the phasing of delivery of such greenspace for us to be able to state with confidence that adverse effects would not occur.

Additional measures recommended

4.5.17 The following further criteria should be set out in order to ensure that additional greenspace delivered as part of or associated with new housing developments meet the necessary requirements to minimise adverse effects. While it is accepted that detailed information on these aspects is perhaps not appropriate to a Core Strategy, a commitment should at least be given in the Core Strategy that such details will be developed for an SPD or similar. The Planning Conditions policy currently goes some way towards the measures below in stating that the Council will seek ‘planning contributions’, and that the ‘annually updated Infrastructure Schedule covering the items listed below to map existing provision, identify and areas of surplus or deficit and plan for future needs’ and that this will ‘inform future planning application decisions’ however at present the text is not explicit enough with regards to the phasing of green space in parallel to the occupation of developments.

The Council should include the following measures into either the Core Strategy (The ‘Planning Conditions’ and ‘Environment’ policies would seem the appropriate places for such a reference) or into a relevant SPD cross-referenced in the Core Strategy (The Planning Contributions SPD would seem an appropriate place). These are modified from the Natural England Accessible Natural Greenspace Standard (ANGSt): • Delivery of greenspace would need to be phased in parallel to occupation of the developments it was intended to serve and would need to serve a similar recreational function to Wormley Hoddesdonpark Woods, from which it is intended to draw recreational users (i.e. dog-walking and appreciation of nature). However, that does not mean that it would have to be woodland (since this would be impractical, taking decades to mature), species-rich grassland for example could be acceptable. Existing natural greenspace could be included within the allocation provided that a visitor study could demonstrate that it did not already meet its maximum recreational capacity.

28 Broxbourne Borough Council Core Strategy

4.5.18 It is considered that incorporation of this additional detail would be sufficient to mitigate any adverse effect as a result of the increased population within the recreational catchment of the SAC.

Atmospheric Pollution

4.5.19 It can be seen from Table 6 that the SAC exceeds the critical threshold for nitrogen load. It can also be seen that the NOx and sulphur dioxide atmospheric levels do not currently appear to be a problem for the site.

Table 6. Critical nitrogen loads, actual rates of nitrogen deposition, NOx concentrations24 and sulphur dioxide concentrations for the Wormley-Hoddesdonpark Woods SAC. Red shading indicates exceedance of thresholds. 25 Site Grid Most Minimum Actual Actual NOx Actual SO2 reference nitrogen critical nitrogen concentration concentration sensitive loads (Kg deposition26 (µgm-3) (µgm-3) habitat N/ha/yr) (Kg N/ha/yr) Wormley- TL Oak 20 32.5 20.1 1.6 Hoddesdonpark 320059 woodland Woods SAC

4.5.20 Although the SAC lies close to the A10, there is no point at which it lies within 200 m. Therefore traffic movements on the A10 (the nearest major road) are unlikely to be contributing to significant local nitrogen deposition effects within the SAC. White Stubbs Lane, Pembridge Lane and Lord Street all lie close to the SAC, but these lanes are narrow and winding, and are unlikely to see substantial increased vehicle use compared to the A10. Using these criteria, development under the Core Strategy will therefore not lead to an adverse effect on the SAC as a result of deteriorating local atmospheric nitrogen deposition.

4.6 Summary

4.6.1 As the Core Strategy currently stands, it is not possible to conclude that the development that it will deliver will not lead to an adverse effect upon Wormley Hoddesdonpark Woods SAC as a result of both increased urbanisation and recreational pressure, although relatively minor amendments will achieve this.

24 Calculated as NO2 25 APIS provides a critical load range – on a precautionary basis, this assessment uses the lowest figure in that range 26 To a resolution of 5 km

29 Broxbourne Borough Council Core Strategy

5 Epping Forest SAC

5.1 Introduction

5.1.1 Epping Forest SAC covers over 1,600 ha of Essex and the London Borough of Waltham Forest, with 70% of the site consisting of broadleaved deciduous woodland. Epping Forest is one of only a few remaining large-scale examples of ancient wood-pasture in lowland Britain and has retained habitats of high nature conservation value including ancient semi-natural woodland, old grassland plains and scattered wetland. The semi- natural woodland is particularly extensive, forming one of the largest coherent blocks in the country. Most is characterised by groves of over-mature pollards and these exemplify all three of the main wood-pasture types found in Britain: beech-oak, hornbeam-oak and mixed oak. The Forest plains are also a major feature and contain a variety of unimproved acid grasslands, which have become uncommon elsewhere in Essex and the London area. In addition, Epping Forest supports a nationally outstanding assemblage of invertebrates, a major amphibian interest and an exceptional breeding bird community. 5.2 Features of European Interest

5.2.1 The site is designated as an SAC for its:

• Atlantic acidophilous beech forest; • Stag beetle, for which this is one of only four known outstanding localities in the UK. Stag beetles spend the majority of their life (up to 5 years) as larvae and during this period live in decaying wood at or below ground level. Adult beetles start to emerge in May and have generally mated and died by the end of August. It is not known whether adult stag beetles eat anything at all, although some entomologists have suggested that they may consume tree sap. • European dry heaths; and • Northern Atlantic wet heaths. 5.3 Condition Assessment

5.3.1 Deteriorating air quality and under-grazing are the two key pressures that currently affect the site. While recreational pressure is a considerable impact in some areas, these are localised; however, funding of management on the SAC is governed largely by donation and contributions from the Corporation of London and it is likely that the ability to adequately manage recreation on the SAC will come under increasing pressure as the population of northeast London, Epping Forest and east Hertfordshire increases. 5.4 Key Environmental Conditions

5.4.1 The following key environmental conditions have been identified for the maintenance of the interest features of Epping Forest SAC:

• Controlled recreational activity; • Good air quality; • Maintenance of grazing regimes;

30 Broxbourne Borough Council Core Strategy

• Unpolluted water; • Absence of nutrient enrichment; • Absence of non-native species. 5.5 Potential Effects of the Plan

Urbanisation

5.5.1 Given that the SAC is situated 4 km from Broxbourne at its closest ‘urbanisation’ effects are highly unlikely to occur as a result of development within the borough.

Recreational Pressure

Adverse effects of the Core Strategy

5.5.2 The Corporation of London have published the results of the Epping Forest Visitor Survey 200627. All the urban areas within Broxbourne lie within 2 to 10 miles of Epping Forest. According to the Epping Forest visitor survey data approximately 29% of visitors to the site come from within this band. It is not possible to determine what proportion of Broxbourne’s residents travel to visit Epping Forest for recreational purposes based upon these data.

5.5.3 In the absence of any other data the precautionary principle must be used and it must be concluded that, when the 3,840 homes to be delivered in Broxbourne are considered in combination with the houses to be delivered within those other boroughs that surround the SAC28 (15,200 from Waltham Forest and Redbridge under the London Plan 2001- 2021 targets and 6,600 across Epping and Brentwood between 2011 and 2031 under the East of England Plan), and assuming a Broxbourne Borough average of 2.3 residents per house, an ‘in combination’ adverse effect upon the SAC will result.

Mitigating aspects of the Core Strategy

5.5.4 Various policies will provide opportunities to control recreational pressure and/or deliver additional green space or greater access to existing green space:

• CS1 -Sustainable Neighbourhoods – this policy includes the statement that ’development will…provide …. habitats for wildlife.’ • CS2 - Housing development – ‘The Council working in partnership with developers, landowners, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including ….open spaces…. landscape impacts, wildlife and biodiversity.’ • CS8 - Environment – ‘The following green corridors will be protected and enhanced to help link open spaces in towns with surrounding countryside: the Lee Valley Regional Park, the New River green chain, Spital Brook valley between Barclay Park and Hoddesdonpark Wood, Rags Brook valley between Rosedale and Cheshunt Common, Wormley playing fields and Theobalds Brook from Cedars Park into Theobalds Park.’

27 Corporation of London, 2006. Epping Forest Visitor Survey 2006 Analysis. Unpublished report 28 Epping Forest District, Brentwood District and the London Boroughs of Waltham Forest and Redbridge

31 Broxbourne Borough Council Core Strategy

‘All sites in and adjoining the borough which are protected by the planning system for their landscape, wildlife, scientific and /or archaeological value will be conserved and enhanced in accordance with national guidance and local objectives.’ ‘Seek to maintain and increase the quantity and accessibility of open space throughout the borough in accordance with the following standards.’

Space per 1,000 residents Accessibility Parks and Gardens 0.28 hectares 15 min walk Natural and Semi-Natural 1.26 hectares 15 min walk Space Amenity Greenspace 0.46 hectares 10 min walk Provision for Children 0.04 hectares 10 min walk Teenage Provision 0.02 hectares 15 min walk Allotments 0.2 hectares 15 min walk Outdoor Sports Facilities 1.88 hectares 15 min walk i.e. sports pitches, tennis courts Outdoor Sports Facilities i.e. golf courses, swimming 1.88 hectares 20 min drive pools

• CS10 - Planning conditions – ‘The Council will seek planning contributions from new development in accordance with national guidance and to help fund policy objectives set out in the Core Strategy, the Sustainable Community Strategy and other planning documents such as town centre strategies and development briefs.’ The Council will prepare an Infrastructure Schedule covering the items listed below to map existing provision, identify any areas of surplus or deficit and plan for future needs. This will be combined with viability appraisal work to inform a Planning Obligations SPD…..Open space, sports facilities and green infrastructure’

5.5.5 Due to the limitations of the assessment tools and data available at this time (and in particular the inability to quantify the number of residents of each allocated site that will be making use of the European sites in question and what proportion of the total cumulative load this represents), coupled with the need for any standards within the Core Strategy to be generally applicable (it not being possible to devise a unique policy or standard for each allocated site), it is not possible for the Core Strategy to specify an exact quantity of alternative natural greenspace that will need to be provided for individual developments in order to absorb recreational visitors to such an extent that they will not materially contribute towards recreational pressure on the European sites in question.

5.5.6 Natural England's more general Accessible Natural Greenspace Standards (ANGSt) provide a set of benchmarks for ensuring access to places of wildlife interest and were specifically developed to provide size and distance criteria to provide natural spaces that will contribute most towards sustainable use of recreational resources. While the criteria were not developed with the specific intention of mitigating for adverse impacts on European sites, they were intended to specify a level of semi-natural greenspace provision that would meet the needs of a development’s population.

5.5.7 In many cases natural greenspace provision to the ANG Standard should therefore serve to minimise the need for recreational resources further afield (i.e. European sites) to receive an unsustainably large influx of visitors provided that they are delivered within a timescale

32 Broxbourne Borough Council Core Strategy

linked to that of the development and will fulfil a function similar to that of the European site in question (i.e. dog walking and appreciation of nature rather than more formal recreational activities). For these reasons, we have selected the Natural England ANG standards as the criterion for semi-natural greenspace provision that the Core Strategy should require developments to meet in order to ensure that sufficient recreational space is provided to minimise adverse effects on the identified European sites.

5.5.8 The stipulation that new natural and semi-natural greenspace will be provided at a rate of over 1 ha/1000 population does fit with our core recommendation from the HRA of the preferred options Core Strategy regarding the ANG Standard.

5.5.9 In addition, the Environment policy does provide a mechanism for providing open space by seeking minimum areas close to residents, although this is not stringent or detailed enough in itself to ensure that no adverse effects would occur at the SAC. Further detail is required regarding the phasing of delivery of such greenspace for us to be able to state with confidence that adverse effects would not occur.

Additional measures recommended

5.5.10 The following further criteria should be set out in order to ensure that additional greenspace delivered as part of or associated with new housing developments meet the necessary requirements to minimise adverse effects. While it is accepted that detailed information on these aspects is perhaps not appropriate to a Core Strategy, a commitment should at least be given in the Core Strategy that such details will be developed for an SPD or similar. The Planning Conditions policy currently goes some way towards the measures below in stating that the Council will seek ‘planning contributions’, and that the ‘annually updated Infrastructure Schedule covering the items listed below to map existing provision, identify and areas of surplus or deficit and plan for future needs’ and that this will ‘inform future planning application decisions’ however at present the text is not explicit enough with regards to the phasing of green space in parallel to the occupation of developments.

The Council should include the following measures into either the Core Strategy (The ‘Planning Conditions’ and ‘Environment’ policies would seem the appropriate places for such references) or into a relevant SPD cross-referenced in the Core Strategy (The Planning Contributions SPD would seem an appropriate place). These are modified from the Natural England Accessible Natural Greenspace Standard (ANGSt): • Delivery of the greenspace would need to be phased in parallel to occupation of the developments it was intended to serve and would need to serve a similar recreational function to Epping Forest, from which it is intended to draw recreational users (i.e. dog- walking and appreciation of nature). However, that does not mean that it would have to be woodland (since this would be impractical, taking decades to mature), species-rich grassland for example could be acceptable. Existing natural greenspace could be included within the allocation provided that a visitor study could demonstrate that it did not already meet its maximum recreational capacity.

5.5.11 Coupled with the fact the Epping Forest Conservators have a detailed management strategy for the site, which includes careful management and licensing of many recreational activities, these measures would be sufficient to mitigate any adverse effect as a result of the increased population within the recreational catchment of the SAC.

33 Broxbourne Borough Council Core Strategy

Atmospheric Pollution

Adverse affects of the Core Strategy

5.5.12 It can be seen from Table 7 that the SAC exceeds the critical threshold for NOx and its critical nitrogen load. It can also be seen that sulphur dioxide atmospheric levels do not currently appear to be a problem for the site.

Table 7. Critical nitrogen loads, actual rates of nitrogen deposition, NOx concentrations29 and sulphur dioxide concentrations for Epping Forest SAC. Red shading indicates exceedance of thresholds. Site Grid Most Minimum Actual Actual Actual SO2 reference nitrogen 30 critical nitrogen NOx concentrat sensitive loads (Kg deposition concentrat ion (µgm-3) habitat N/ha/yr) 31 ion (µgm-3) (Kg N/ha/yr) Epping Forest TQ425985 Oak 10 32.2 33.7 1.7 SAC woodland

5.5.13 Epping Forest SAC lies within 200 m of several major roads of key strategic importance for the London/East Hertfordshire/West Essex area (M25, A1400, A104, A121 and A114 among others). Given the strategically important role of these roads, it is reasonable to conclude that a net increase of the population of Broxbourne borough will also mean a net increase (when considered cumulatively with other developments in the area) in the numbers of people using these major roads as a result of the 3,840 new homes that will be developed and the increased retail and employment floorspace, coupled with increased jobs within the borough (predicted to be a 3,500 increase by 2026).

Mitigating aspects of the Core Strategy

5.5.14 Various policies will provide opportunities to minimise the contribution of new development to deteriorating air quality as much as possible:

• CS1 - Sustainable neighbourhoods – this policy includes the statement that ‘development proposals will reduce the need to travel, improve public transport, walking and cycling opportunities and be accessible to all members of the community.’ • CS2 - Housing development - this policy includes the statement that the Council when ‘working in partnership with landowners, developers, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large greenbelt sites……should address the full range of issues…including road access, public transport, walking and cycling.’ • CS5 - Employment – this policy includes the statement that ‘The Council will work in partnership with landowners, developers, utility providers, other stakeholders and the local community to prepare a comprehensive masterplan…….This should address a full range of issue likely to inform a major development proposal including road access, public transport, walking and cycling……….All employment proposals should

29 Calculated as NO2 30 APIS provides a critical load range – on a precautionary basis, this assessment uses the lowest figure in that range 31 To a resolution of 5 km

34 Broxbourne Borough Council Core Strategy

seek to……..reduce out-commuting, minimise vehicle trips and achieve better access by public transport, walking and cycling.’ ‘All employment proposals should seek to….reduce out-commuting, minimise vehicle trips and achieve better access by public transport, walking and cycling. • Greater Brookfield – relating to this area the policy makes the following statement ‘A new link road must be provided from the western arm of the A10 Turnford roundabout and a new access lane from the A10 Turnford roundabout onto the southbound lane of the A10 to help resolve existing traffuc problems……..A strong emphasis willbe placed on attracting workers and shoppers by public transport, walking and cycling. This must improve bus services to the centre. This should include funding for new services where appropriate. There must be good connectivity between new and existing shopping facilities’

• CS9 - Infrastructure – this policy includes the statement ‘To bring forward infrastructure and services that are needed to support housing, employment and retail development the Council will…….work with local highways authority to find ways for development to connect to the existing road network and to prepare an A10 Route Management Strategy to ensure that the A10 and other roads and junctions can accommodate future traffic levels. The Council will also work with the Highways Agency to consider the role of the M25 and Junction 25. Developers should submit transport assessments to demonstrate that development proposals can be accommodated work with local highways authority to find ways for development to connect to the existing road network and to prepare an A10 Route Management Strategy to ensure that the A10 and other roads and junctions can accommodate future traffic levels. The Council will also work with the Highways Agency to consider the role of the M25 and Junction 25. Developers should submit transport assessments to demonstrate that development proposals can be accommodated

• CS10 - Planning Conditions – including the areas of transport infrastructure and public transport, walking and cycling, this policy states that ‘The Council will seek planning contributions from new development in accordance with national guidance and local policies to help fund policy objectives set out in the Core Strategy, the Sustainable Community Strategy and other planning documents such as town centre strategies and development briefs.’

5.5.15 The aforementioned roads are major strategic routes and it will never be possible to deter people from using them, particularly since Epping Forest lies outside the control of Broxbourne Council. The most that any local authority can reasonably be expected to do in such a situation is to introduce a series of strong policies that will discourage car use as much as possible and encourage use of sustainable transport. Whilst Broxbourne Council’s policies go as far as they could reasonably be expected to in a Core Strategy to promote sustainable transport modes, they could go further to discourage car use, although this has been addressed in relation to discouraging new employment development related car use. 5.6 Summary

5.6.1 As the Core Strategy currently stands, it is not possible to conclude that the development that it will deliver will not lead to an adverse effect upon Epping Forest SAC as a result of increased recreational pressure. However, a further commitment regarding the phasing of delivery of such greenspace would enable such a conclusion to be drawn and these should be integrated into the final Core Strategy.

35 Broxbourne Borough Council Core Strategy

6 Lee Valley SPA / Ramsar

6.1 Introduction

6.1.1 The Lee Valley comprises a series of embanked water supply reservoirs, sewage treatment lagoons and former gravel pits along approximately 24 km of the valley. These waterbodies support internationally important numbers of wintering gadwall and shoveler, while the reedbeds support a small but internationally important population of bittern.

6.1.2 The Lee Valley SPA/Ramsar consists of four Sites of Special Scientific Interest, of which Turnford and Cheshunt Pits SSSI, Rye Meads SSSI and Amwell Quarry SSSI all lie within Broxbourne borough on the Hertfordshire/Essex border. Walthamstow Reservoirs SSSI lies within London Borough of Waltham Forest. The Special Protection Area is managed by the Lee Valley Regional Park Authority and by Thames Water.

Turnford and Cheshunt Pits SSSI

6.1.3 The Turnford and Cheshunt Pits SSSI includes ten former gravel pits in the Lee Valley Regional Park. The pits range in age from North Metropolitan Pit, which is among the oldest pits in the Lee Valley to Hooks Marsh Lake, which was not excavated until the 1970s, and cover a span of over 40 years. Because of the profusion of pits and islands, several of the pits have extensive shorelines; North Metropolitan Pit alone having an estimated shoreline of about 4 miles (7.2km). Also included in the site are all the associated areas of marsh, grassland, ruderal herbs, scrub and woodland; part of the Small River Lee; and a further water body, Hall Marsh Scrape, which was constructed specifically for use by waterfowl.

6.1.4 The pits are of national importance for wintering gadwall Anas strepera; (regularly supporting some 2.9% of the UK population) and for wintering shoveler Anas clypeata (about 1.3% of the UK population). The site is of regional importance for wintering Coot Fulica atra and is locally important for wintering snipe Gallinago gallinago and bittern Botaurus stellaris.

Rye Meads SSSI

6.1.5 The Rye Meads meadows are the last substantial remnants of ancient flood-meadows on the rich alluvial soils of the Lee Valley. The site supports one of the largest areas of tall fen vegetation in the county and provides a valuable habitat for locally uncommon plants and for birds. This habitat has been reduced in extent significantly, both locally and nationally, by drainage and agricultural improvements, and it is now a rare habitat in Hertfordshire.

6.1.6 The site is important for breeding and wintering birds. In hard weather the lagoons support concentrations of Tufted Duck Aythya fuligula, Shoveler Anas clypeata and Gadwall Anas strepera of national importance. The tall fen areas are used by wintering birds, notably Snipe Gallinago gallinago, Water Rail Rallus aquaticus, Bittern Botaurus stellaris and Bearded Tit Panurus biarmicus, the last three species occurring here at their highest concentrations in the London basin.

36 Broxbourne Borough Council Core Strategy

Amwell Quarry SSSI

6.1.7 Amwell Quarry is a former gravel pit site in the Lee Valley near Ware, which supports nationally important numbers of wintering wildfowl, along with outstanding assemblages of breeding birds and of dragonflies and damselflies. The site includes two waterbodies, Great Hardmead Lake and Hollycross Lake, which were excavated between 1973 and 1990, and a variety of associated wetland, grassland and woodland habitats. Amwell Quarry is of national importance for wintering gadwall Anas strepera for wintering shoveler Anas clypeata. The site also regularly supports individual wintering bittern Botaurus stellaris. The lakes and their marginal habitats also support an outstanding assemblage of breeding birds.

6.1.8 The lagoons support the region's largest colony of Common Tern Sterna hirundo which breed very successfully on floating rafts. The lagoon banks hold a nationally important breeding concentration of tufted ducks and duckling survival is high compared to other sites in the Lee Valley.

Walthamstow Reservoirs SSSI

6.1.9 The Walthamstow Reservoirs contain one of the country’s major heronries and a particularly large concentration of breeding wildfowl. They are also an important gathering area for moulting tufted duck and in winter attract nationally significant populations of wildfowl and other wetland birds. They were mainly constructed in the latter half of the nineteenth century and comprise ten relatively small, shallow, water storage basins. Several of the reservoirs are fringed by sloping earth banks and these, together with the presence of wooded islands, form distinctive habitat features. The reservoirs serve an active part in Thames Water’s strategic water supply infrastructure.

6.1.10 During the winter months the reservoirs are a favoured area for a variety of wetland birds and in particular, large numbers of wildfowl. The populations of shoveler and tufted duck consistently reach levels of national significance, while great crested grebe, pochard and coot also occur in important numbers. The shores of the reservoirs and the banks of the Coppermill Stream are of added interest for fringes of fenland vegetation containing species that are uncommon in Greater London. 6.2 Features of European Interest

6.2.1 The site was designated as being of European importance for the following interest features:

• Bittern Botaurus stellaris, 6 individuals representing at least 6.0% of the wintering population in Great Britain (5 year peak mean, 1992/3-1995/6) • Gadwall Anas strepera, 515 individuals representing at least 1.7% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Shoveler Anas clypeata, 748 individuals representing at least 1.9% of the wintering Northwestern/Central Europe population (5 year peak mean 1991/2 - 1995/6)

6.2.2 The birds that winter on many Special Protection Areas/Ramsar sites (the Lee Valley being no exception) are not confined to the boundaries of the SPA, but in fact utilise areas of ‘supporting habitat’ located outside the boundaries and sometimes many kilometres distant.

37 Broxbourne Borough Council Core Strategy

Features of International Interest: Ramsar Criteria

6.2.3 The Lee Valley Ramsar site qualifies on two of the nine Ramsar criteria.

Table 8. Criteria under which the Lee Valley qualifies as a Ramsar site Ramsar Description of Criterion Thames Estuary & Marshes criterion 2 A wetland should be considered The site supports the nationally scarce plant species internationally important if it supports whorled water-milfoil Myriophyllum verticillatum and vulnerable, endangered, or critically the rare or vulnerable invertebrate Micronecta endangered species or threatened minutissima (a water-boatman). ecological communities. 6 A wetland should be considered Species with peak counts in spring/autumn: internationally important if it regularly supports 1% of the individuals in a • Shoveler Anas clypeata, 287 population of one species or subspecies individuals, representing an average of of waterbird. 1.9% of the GB population (5 year peak mean 1998/9-2002/3)

Species with peak counts in winter:

• Gadwall Anas strepera, 445 individuals, representing an average of 2.6% of the GB population (5 year peak mean 1998/9- 2002/3)

6.3 Condition Assessment

6.3.1 During the most recent condition assessment process, Turnford and Cheshunt Pits SSSI, Amwell Quarry SSSI and Rye Meads SSSI were judged to be in 100% favourable condition.

6.4 Key Environmental Conditions

6.4.1 The following key environmental conditions were identified for this site:

• Minimal disturbance • Maintenance of grazing / mowing regimes • Consistent freshwater flows and volumes • Consistent water quality • Good air quality • Unpolluted water • Absence of nutrient enrichment • Absence of non-native species • The maintenance of adequate supporting habitat outside the boundaries of the European site

6.4.2 It is understood that most of the off-site supporting habitat for gadwall and shoveler relates to nearby water bodies (i.e. within approximately 2 km). It is understood that

38 Broxbourne Borough Council Core Strategy

bittern does not significantly utilise habitat outside the boundaries of the SPA/Ramsar site. 6.5 Potential Effects of the Plan

Urbanisation

Adverse effects of the Core Strategy

6.5.1 The current pattern of urban development in Broxbourne is that it follows the River Lee, with Hoddesdon and Cheshunt adjacent. As such, the land immediately west of the SPA/Ramsar (i.e. within Broxbourne) is already heavily built-up such that it is unlikely that there would be much room for additional development between Hoddesdon and Rye Meads SSSI or Turnford and Turnford & Cheshunt Pits SSSI. Nonetheless, due to the extremely close proximity, any development either on greenfield land or previously developed land to the east of the Waltham Cross to Hoddesdon corridor would be likely to contribute to increased urbanisation effects on the SPA/Ramsar.

6.5.2 The supporting text of the Core Strategy indicates that all potential growth locations currently under consideration lie to the west of the Waltham Cross to Hoddesdon corridor and as such will be situated no closer to the Lee Valley SPA/Ramsar than is currently the case. In addition, the Lee Valley Regional Park is highlighted as a strategic green corridor in the ‘Environment’ policy for protection and enhancement, implying that there are no plans for development there. As such it can be concluded that no material increase in ‘urbanisation’ effects on the Lee Valley SPA/Ramsar will occur as a result of development under the Core Strategy.

Recreational Pressure

Adverse effects of the Core Strategy

6.5.3 Human activity can affect birds either directly (e.g. through causing them to flee) or indirectly (e.g. through damaging their habitat). The most obvious direct effect is that of immediate mortality such as death by shooting, but human activity can also lead to behavioural changes (e.g. alterations in feeding behaviour, avoidance of certain areas etc.) and physiological changes (e.g. an increase in heart rate) that, although less noticeable, may ultimately result in major population-level effects by altering the balance between immigration/birth and emigration/death.32

6.5.4 Recreational activity will often result in a flight response (flying, diving, swimming or running) from the animal that is being disturbed. This carries an energetic cost that requires a greater food intake. Relatively little detailed research has been conducted concerning the energetic cost to wildlife of disturbance, but such evidence as exists indicates a significant negative effect.

6.5.5 Few studies could be sourced that identified sensitivity of gadwall to recreational disturbance. The potential for disturbance may be less in winter than in summer, in that there are often a smaller number of recreational users. However, winter activity can still cause important disturbance, especially as birds are particularly vulnerable at this time of year due to food shortages. Several empirical studies have, through correlative analysis,

32 Riley, J. 2003. Review of Recreational Disturbance Research on Selected Wildlife in Scotland. Scottish Natural Heritage.

39 Broxbourne Borough Council Core Strategy

demonstrated that out-of-season recreational activity can result in quantifiable disturbance:

• Tuite et al33 found that during periods of high recreational activity, bird numbers at Llangorse Lake decreased by 30% as the morning progressed, matching the increase in recreational activity towards midday. During periods of low recreational activity, however, no change in numbers was observed as the morning progressed. In addition, all species were found to spend less time in their ‘preferred zones’ (the areas of the lake used most in the absence of recreational activity) as recreational intensity increased. • Underhill et al34 counted waterfowl and all disturbance events on 54 water bodies within the South West London Water bodies Special Protection Area and clearly correlated disturbance with a decrease in bird numbers at weekends in smaller sites and with the movement of birds within larger sites from disturbed to less disturbed areas. • Evans & Warrington35 found that on Sundays total water bird numbers (including shoveler and gadwall) were 19% higher on Stocker’s Lake LNR in Hertfordshire, and attributed this to observed greater recreational activity on surrounding water bodies at weekends relative to week days. However, recreational activity was not quantified in detail nor were individual recreational activities evaluated separately. • Tuite et al36 used a large (379 site), long-term (10-year) dataset (September – March species counts) to correlate seasonal changes in wildfowl abundance with the presence of various recreational activities. They found that shoveler was one of the most sensitive species to disturbance. The greatest impact on winter wildfowl numbers was associated with sailing/windsurfing and rowing.

6.5.6 Disturbing activities are on a continuum. The most disturbing activities are likely to be those that involve irregular, infrequent, unpredictable loud noise events, movement or vibration of long duration. Birds are least likely to be disturbed by activities that involve regular, frequent, predictable, quiet patterns of sound or movement or minimal vibration. The further any activity is from the birds, the less likely it is to result in disturbance.

6.5.7 The key factors that influence a species response to a disturbance are numerous, but the three key factors are species sensitivity, proximity of disturbance sources and timing/duration of the potentially disturbing activity.

Sensitivity of species

6.5.8 The distance at which a species takes flight when approached by a disturbing stimulus is known as the ‘tolerance distance’ (also called the ‘escape flight distance’) and differs between species to the same stimulus and within a species to different stimuli. No data could be sourced on the tolerance distances of gadwall. However, distances for shoveler

33 Tuite, C. H., Owen, M. & Paynter, D. 1983. Interaction between wildfowl and recreation at Llangorse Lake and Talybont Reservoir, South Wales. Wildfowl 34: 48-63 34 Underhill, M.C. et al. 1993. Use of Waterbodies in South West London by Waterfowl. An Investigation of the Factors Affecting Distribution, Abundance and Community Structure. Report to Thames Water Utilities Ltd. and English Nature. Wetlands Advisory Service, Slimbridge 35 Evans, D.M. & Warrington, S. 1997. The effects of recreational disturbance on wintering waterbirds on a mature gravel pitlake near London. International Journal of Environmental Studies 53: 167-182 36 Tuite, C.H., Hanson, P.R. & Owen, M. 1984. Some ecological factors affecting winter wildfowl distribution on inland waters in England and Wales and the influence of water-based recreation. Journal of Applied Ecology 21: 41-62

40 Broxbourne Borough Council Core Strategy

have been recorded. These are given in Table 9, which compiles ‘tolerance distances’ from across the literature.

Table 9. Tolerance distances of 21 water bird species to various forms of recreational disturbance, as described in the literature. All distances are in metres. Single figures are mean distances; when means are not published, ranges are given. 1 Tydeman (1978), 2 Keller (1989), 3 Van der Meer (1985), 4 Wolff et al (1982), 5 Blankestijn et al (1986), 6 Cook (1980).37 Type of disturbance

Species Rowing boats/kayak Sailing boats Walking Little grebe 60 – 100 1

Great crested grebe 50 – 100 2 20 – 400 1 Mute swan 3 – 30 1 Teal 0 – 400 1 Mallard 10 – 100 1 Shoveler 200 – 400 1 Pochard 60 – 400 1 Tufted duck 60 – 400 1 Goldeneye 100 – 400 1 Smew 0 – 400 1 Moorhen 100 – 400 1 Coot 5 – 50 1 Curlew 211 3; 339 4; 213 5 Shelduck 148 3; 250 4 Grey plover 124 3 Ringed plover 121 3 Bar-tailed godwit 107 3; 219 4 Brent goose 105 3 Oystercatcher 85 3; 136 4; 82 5 Dunlin 71 3; 163 2 Dunnock 9.2 6

6.5.9 Although gadwall and shoveler are considered to be sensitive to increased disturbance, this sensitivity is always relative to the levels of disturbance to which the birds in a given location are adapted. The birds that use the Lee Valley SPA and Ramsar site are already

37 Tydeman, C.F. 1978. Gravel Pits as conservation areas for breeding bird communities. PhD thesis. Bedford College Keller, V. 1989. Variations in the response of Great Crested Grebes Podiceps cristatus to human disturbance - a sign of adaptation? Biological Conservation 49:31-45 Van der Meer, J. 1985. De verstoring van vogels op de slikken van de Oosterschelde. Report 85.09 Deltadienst Milieu en Inrichting, Middelburg. 37 pp. Wolf, W.J., Reijenders, P.J.H. & Smit, C.J. 1982. The effects of recreation on the Wadden Sea ecosystem: many questions but few answers. In: G. Luck & H. Michaelis (Eds.), Schriftenreihe M.E.L.F., Reihe A: Agnew. Wissensch 275: 85-107 Blankestijn, S. et al. 1986. Seizoensverbreding in de recreatie en verstoring van Wulp en Scholkester op hoogwatervluchplaatsen op Terschelling. Report Projectgroep Wadden, L.H. Wageningen. 261pp. Cooke, A.S. 1980. Observation on how close certain passerine species will tolerate an approaching human in rural and suburban areas. Biological Conservation 18: 85-88

41 Broxbourne Borough Council Core Strategy

within an essentially urban situation with high-rise housing surrounding the site, and a busy road (the A508) passing through the centre of the designated area.

Proximity of sources of potential disturbance

6.5.10 No built areas will be situated closer to the site than is currently the case as a result of the Core Strategy. However, Turnford & Cheshunt Pits SSSI is managed as a country park by the Lee Valley Regional Park Authority and part of Rye Meads SSSI constitutes the Rye House Marsh RSPB reserve, such that both have existing recreational access close to the areas utilised by wintering birds.

Timing of disturbance

6.5.11 Waterfowl such as shoveler and gadwall are often highly active at night, and are therefore potentially at greater risk of disturbance during these periods. However, nocturnal recreational activity is unlikely to occur as a result of the housing to be delivered under the Core Strategy, largely because nocturnal recreation tends to be associated with illuminated areas and there will be no lighting situated closer to the site than is currently the case. The most sensitive season for wintering bird populations (such as those in the Lee Valley SPA/Ramsar) is September-March.

6.5.12 The only information we have been able to obtain concerning recreational catchments for the Lee Valley Regional Park are the following:

• A statement that “The Lee Valley Regional Park is a resource for everyone who lives and works in the London, Hertfordshire and Essex region. It also attracts visitors from around the UK and even internationally”38; and • The Lee Valley Regional Park Authority Visitor Tracking Study for the year April 2006 to March 2007, as reported in the Recreation Technical Report produced for the East of England Regional Spatial Strategy39, shows that 60% of visitors to the National Park were ‘local’. It was also noted that for Rye Meads SSSI specifically, the number of ‘local’ visitors was lower than for the park as a whole (although still significant) at 22%. Although ‘local’ was not specifically defined it would certainly include Broxbourne within the recreational catchment for the Park and for Rye Meads.

6.5.13 The Lee Valley (including parts of the Special Protection Area) is already extensively used for recreational activity, forming as it does part of the Lee Valley Park. Inevitably, given the major draw that the Park represents, the additional 3,840 new homes that the Council state needs to be delivered over the plan period to meet the recommendations of the strategic housing assessment will add to recreational pressures. While the Park has detailed management plans to control recreation, it is inevitable that these plans will be placed under greater pressure (and potentially require greater funds to implement) if the number of recreational users increases considerably.

Mitigating aspects of the Core Strategy

6.5.14 Various policies will provide opportunities to control recreational pressure and/or deliver additional green space or greater access to existing green space:

38 Lee Valley Regional Park Authority. 2007. Park Development Framework – Statement of Community Involvement 39 RPS Consultants. 2007. Recreation Technical Report for the East of England Regional Spatial Strategy. Unpublished report

42 Broxbourne Borough Council Core Strategy

• CS1 -Sustainable Neighbourhoods – this policy includes the statement that ’development will…provide …. habitats for wildlife.’ • CS2 - Housing development – ‘The Council working in partnership with developers, landowners, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including ….open spaces…. landscape impacts, wildlife and biodiversity.’ • CS10 - Planning conditions – ‘The Council will seek planning contributions from new development in accordance with national guidance and to help fund policy objectives set out in the Core Strategy, the Sustainable Community Strategy and other planning documents such as town centre strategies and development briefs.’ The Council will prepare an Infrastructure Schedule covering the items listed below to map existing provision, identify any areas of surplus or deficit and plan for future needs. This will be combined with viability appraisal work to inform a Planning Obligations SPD…..Open space, sports facilities and green infrastructure’

6.5.15 The Environment policy does provide a mechanism for providing open space by seeking minimum areas close to residents. However, it will be difficult to avoid impacts through the provision of alternative spaces as it is reasonable to assume that visitors to this site specifically wish to visit the Lee Valley wetlands. The Planning Conditions policy provides a mechanism by which funding from developments in relation to recreational areas could be achieved, however the policy wording needs to be developed further such that a conclusion of no adverse impact on the Lee Valley SPA/Ramsar as a result of recreational pressure can be drawn.

Additional measures recommended

6.5.16 The following active measure should be adopted in order to ensure that the effects of increased recreational pressure from the new housing within the Borough can be offset. While it is accepted that detailed information on these aspects is perhaps not appropriate to a Core Strategy, a commitment should at least be given in the Core Strategy that such details will be developed for an SPD or similar.

The Council should commit to providing assistance (such as via a financial contribution) to ongoing recreational management of the SPA/Ramsar site in order to manage the expected increased visitor pressure that can be expected to arise as an indirect result of the 3,840 homes to be delivered in the borough, when considered in combination with development in other authorities adjacent to the Lee Valley.

Atmospheric Pollution

6.5.17 It can be seen from Table 10 that the SPA/ Ramsar site exceeds the critical threshold for atmospheric NOx levels for the key habitat for which data are available and which the SPA birds are likely to use. It can also be seen that the critical nitrogen deposition load and sulphur dioxide atmospheric levels do not currently appear to be a problem for the site.

43 Broxbourne Borough Council Core Strategy

Table 8 Critical nitrogen loads, actual rates of nitrogen deposition, NOx concentrations40 and sulphur dioxide concentrations for the Lee Valley SPA. Red shading indicates exceedance of thresholds. 41 Site Grid Most Minimum Actual Actual NOx Actual SO2 reference nitrogen critical nitrogen concentration concentration sensitive loads (Kg deposition42 (µgm-3) (µgm-3) habitat N/ha/yr) (Kg N/ha/yr) Lee Valley TL Grazing 20 17.2 31.2 1.6 SPA/ 372026 Marsh43 Ramsar

6.5.18 According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”44. The SPA/Ramsar does not appear to lie close to any major roads within Broxbourne nor does it lie close to minor roads that could be expected to receive a substantial increase in traffic movements. Therefore traffic movements from Broxbourne are unlikely to be contributing to significant local nitrogen deposition effects within the SPA/Ramsar.

6.5.19 Development under the Core Strategy is therefore unlikely to lead to a significant adverse effect on the SPA/Ramsar as a result of deteriorating local atmospheric nitrogen deposition.

Water Quality

Adverse effects of the Core Strategy

6.5.20 Treated sewage effluent generally contains greater concentrations of nutrients than freshwater. This can pose a problem where Sewage Treatment Works discharge treated effluent into rivers and streams, as the result of these increased nutrient levels (particularly phosphate but also nitrates) is the localised growth of more competitive species of plant, fish and invertebrate at the expense of diversity. If a site has been designated for its waterfowl this can have indirect effects on the continued viability of the site as it alters available food resources.

6.5.21 Wastewater from the south of Broxbourne Borough drains to Deephams STW in Edmonton, this water is then discharged to the River Lee Diversion and River Lee Flood Relief Channel, which are themselves used to supply Walthamstow Reservoirs SSSI, part of the Lee Valley SPA. Wastewater from the urban part of the Borough north of Turnford is treated at Rye Meads STW and is also ultimately discharged to the Lee Valley SPA. The Environment Agency have expressed concern45 that water quality within the River could be adversely affected by development within the Rye Meads catchment in particular as a result either of the inability of the infrastructure (e.g. the trunk sewer draining the western side of Stevenage, which is already at capacity) to cope with increased flows46, or simply as a result of the increased volumes of nutrient rich treated effluent that will be discharged to the river as a result of the increased housing within the catchment.

40 Calculated as NO2 41 APIS provides a critical load range – on a precautionary basis, this assessment uses the lowest figure in that range 42 To a resolution of 5 km 43 The closest habitat for which APIS has critical loads are low and medium altitude hay meadows 44 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf 45 Jennie Marsh, EA External Relations Officer, letter of 02/08/07 in response to a data request 46 Current modelling indicates that there is sufficient capacity to accommodate forecast growth at Rye Meads STW itself, although physical expansion of the STW may be difficult due to the presence of sites designated for their nature conservation interest on the immediate boundaries of the STW.

44 Broxbourne Borough Council Core Strategy

6.5.22 Two of the constituent SSSI’s of the Lee Valley SPA (Rye Meads SSSI and Walthamstow Reservoirs SSSI) seem to be hydraulically connected to the River Lee. It is likely that development within Broxbourne borough (wherever it is located) will add to the pressures on these STW’s, particularly when it is borne in mind that the catchment covers not only Broxbourne but several other surrounding authorities, in which considerable development will also be taking place. Water quality in the River Lee (and thus Rye Meads SSSI and Walthamstow Reservoirs SSSI) may deteriorate as a result, and the Rye Meads Water Cycle Strategy has shown that the River Lee currently experiences high phosphorus levels.

Mitigating aspects of the Core Strategy

6.5.23 There are policies in the Core Strategy as it stands that allude to wastewater and sewerage

• CS1 - Sustainable Neighbourhoods – this policy states ‘Improving the sustainability of homes and other buildings. All development proposals will accord with national climate change, energy, waste, water and flood risk policies, achieve the relevant Code for Sustainable Homes standard or a high BREEAM rating and take account of guidance in the Hertfordshire Building Futures programme. Larger development proposals must explain how sustainability objectives will be implemented.’’ • CS2 - Housing Development – this policy states that the Council will ‘Working in partnership with landowners, developers, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including …. sewerage., ….. sustainable drainage.’ • CS9 - Infrastructure – this policy states that ‘To help bring forward infrastructure and services that are needed to support housing, employment and retail development the Council will: Work with utilities bodies to ensure that all areas of the borough are well served by electricity, gas, water, sewerage and telecommunications. The Council will work with Thames Water and the Environment Agency to ensure that Rye Meads, Deephams and other sewage treatment works have sufficient capacity to accommodate new development. Developers should submit utility statements to demonstrate that such services can be supplied and have capacity’. • CS10 - Planning Conditions – this policy states that ‘The Council will prepare an Infrastructure Schedule covering the items listed below to map existing provision, identify any areas of surplus or deficit and plan for future needs. It will be used to inform planning application decisions and planning contributions in accordance with national guidance - Utilities infrastructure, -Flood prevention and sustainable urban drainage measures.’ Additional measures recommended

6.5.24 It is acknowledged that avoiding an adverse effect on this issue is largely in the hands of the water companies (through their investment in future sewage treatment infrastructure) and Environment Agency (through their role in consenting effluent discharges). Nonetheless, there are measures that local authorities can deliver in order to reduce the burden on the system and while they are alluded to above, greater specificity is required in order to enable a conclusion that the development to be delivered in the Borough will not contribute to an adverse effect upon the Lee Valley SPA. It is understood that Broxbourne Borough Council have engaged with the Environment Agency and other stakeholders to produce the Rye Meads Water Cycle study, which has examined in detail the impact of

45 Broxbourne Borough Council Core Strategy

development on the capacity of the plant and its environmental operating limits. This measure goes a long way towards ensuring no adverse effect on European sites.

6.5.25 The supporting text within the Core Strategy for CS9 – Infrastructure outlines the need for the Core Strategy to be aware of uncertainties associated with the future capacity of sewage treatment works. In particular Anglian Water’s and the Environment Agency’s concerns with regards to the capacity for Rye Meads STW to be upgraded and accommodate higher rates of growth without significantly affected the Lee Vallley SPA has been noted. The capacity of Rye Meads STW has been noted as an issue in deciding which green belt sites to release. In addition, Thames Water’s advice with regards to phasing development in line with completion timescales for minor and major upgrades and completely new works has been noted.

6.5.26 The existing draft policy for infrastructure alludes to the need for infrastructure to be in place, including for water and sewerage, in advance of development. This needs to be worded more specifically as detailed below so that a conclusion of no adverse water quality impact on the Lee Valley SPA/ Ramsar site can be drawn.

A policy in the Core Strategy should make specific reference to the fact that the delivery of major development will be phased in order to ensure that it only takes place once any new water treatment infrastructure or appropriate retro-fitted technology (e.g. phosphorus stripping) necessary to service the development while avoiding an adverse effect on the Lee Valley SPA is in place.

Water Resources

Adverse effects of the Core Strategy

6.5.27 Although part of the East of England, Broxbourne is situated within the Environment Agency’s London CAMS area and Thames Water’s London Water Resource Zone. The vast majority of the Public Water Supply for Broxbourne comes from abstraction from the River Lee. In the London CAMS document, the Environment Agency identifies this river as ‘over abstracted’, which means that no further abstraction licences will be issued (and no further abstraction take place) within this catchment. As such, with no other schemes in place, increased residential development within Broxbourne could lead to a need for damaging levels of abstraction from the Lee Valley SPA when considered cumulatively with all other new development in the relevant parts of Thames Water’s London Resource Zone. However, Thames Water are currently implementing several major water supply projects to assist in providing the London Resource Zone with water in a manner that will avoid damaging levels of abstraction from sensitive sites such as the River Lee. These include a scheme that enables abstraction and desalination of water from the tidal River Thames (the Thames Gateway Water Treatment Plant).

6.5.28 However, it is clearly incumbent upon local authorities to assist in reducing the demand for water within their boroughs. As such we could not conclude at this stage that the Core Strategy would not lead to adverse effects upon the Lee Valley SPA purely as a result of Thames Water’s new resource schemes.

Mitigating aspects of the Core Strategy

6.5.29 There are policies in the Core Strategy as it stands that allude to the need for water efficiency and the reduction of demand for resources:

46 Broxbourne Borough Council Core Strategy

• CS1 - Sustainable Neighbourhoods – this policy states ‘Sustainable neighbourhoods will be achieved by..All development proposals will accord with national climate change, energy, water, waste and flood risk policies, achieve the relevant Code for Sustainable Homes standard and/or a high BREEAM rating and take account of guidance in the Hertfordshire Building Futures programme. Larger development proposals must explain how sustainability objectives will be implemented.’ • CS2 - Housing Development – this policy states that the Council ‘Working in partnership with landowners, developers, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including ….. utilities …. sustainability standards, high quality design and planning contributions.’ • CS5 – Employment – this policy states that ‘The Council will work in partnership with landowners, developers, utility providers, other stakeholders and the local community…to address the full range of issues including utilities…sustainability standards.’ • CS7 - Greater Brookfield – this policy states that ‘There should be a strong emphasis on sustainability in the form of statements for energy, waste and water consumption.’ • CS9 - Infrastructure – this policy states that the Council will ‘Work with utilities bodies to ensure that all areas of the borough are well served by electricity, gas, water, sewerage and telecommunications. The Council will work with Thames Water and the Environment Agency to ensure that Rye Meads, Deephams and other sewage treatment works have sufficient capacity to accommodate new development. Developers should submit utility statements to demonstrate that such services can be supplied and have capacity.’ • CS10 - Planning Conditions – this policy states that ‘The Council will prepare an Infrastructure Schedule covering the items listed below to map existing provision, identify any areas of surplus or deficit and plan for future needs. It will be used to inform planning application decisions and planning contributions in accordance with national guidance - Utilities infrastructure.’

Additional measures recommended

6.5.30 It is acknowledged that avoiding an adverse effect on this issue is largely in the hands of the water companies (through their investment in future sewage treatment infrastructure) and Environment Agency (through their role in consenting effluent discharges). Nonetheless, there are measures that local authorities can deliver in order to reduce the burden on the system and while they are alluded to above, greater specificity is required in order to enable a conclusion that the development to be delivered in the Borough will not contribute to an adverse effect upon the Lee Valley SPA.

47 Broxbourne Borough Council Core Strategy

A policy in the Core Strategy will need to make specific reference to the fact that the

delivery of major development will be phased in order to ensure that it only takes place

once any new water supply infrastructure necessary to service the development while

avoiding an adverse effect on European sites is in place.

6.6 Summary

6.6.1 As the Core Strategy currently stands, it is not possible to conclude that the development that it will deliver will not lead to an adverse effect upon the Lee Valley SPA/ Ramsar as a result of increased recreational pressure, water quality or water resources. However, measures are proposed that would enable such a conclusion to be drawn and these should be integrated into the final Core Strategy.

48 Broxbourne Borough Council Core Strategy

7 Overall conclusions

7.1.1 While there are numerous policies within the Core Strategy that will contribute towards reducing the contribution of Broxbourne borough to an adverse effect upon European sites, it is considered that these measures need to be strengthened to enable the Council to conclude that no adverse effect on European sites will result from the housing, retail and employment development to be delivered under the Core Strategy.

Urbanisation

7.1.2 The Council should make a specific commitment to assist with the installation of measures (e.g. fencing and other measures to prevent cars entering the woods and/or increased surveillance to control any increase in ‘urbanisation’ and anti-social behaviour impacts upon Wormley Hoddesdonpark Woods SAC. The ‘Planning Conditions policy would seem the appropriate place for such a reference.

Recreational Pressure

7.1.3 The Council has included natural greenspace provision to a standard beyond the ANG standard in parallel with new housing in their Core Strategy. However, delivery of the greenspace would need to be phased in parallel to occupation of the developments it was intended to serve and would need to serve a similar recreational function to Wormley Hoddesdonpark Woods (in particular), from which it is intended to draw recreational users (i.e. dog-walking and appreciation of nature). However, that does not mean that it would have to be woodland (since this would be impractical, taking decades to mature), species- rich grassland for example could be acceptable. Existing natural greenspace could be included within the allocation provided that a visitor study could demonstrate that it did not already meet its maximum recreational capacity.

7.1.4 With regard to the Lee Valley SPA, it is unlikely to be possible to ‘distract’ users onto other alternative sites. The Council should therefore seek to provide assistance (such as via a financial contribution) to ongoing recreational management of the SPA in order to enable the expected increased visitor pressure that can be expected to arise as an indirect result of the 3,840 homes to be delivered in the borough.

Water Quality

7.1.5 A policy in the Core Strategy should make specific reference to the fact that the delivery of major development will be phased in order to ensure that it only takes place once any new water treatment infrastructure or appropriate retro-fitted technology (e.g. phosphorus stripping) necessary to service the development while avoiding an adverse effect on the Lee Valley SPA is in place.

Water Resources

7.1.6 A policy in the Core Strategy will need to make specific reference to the fact that the delivery of major development will be phased in order to ensure that it only takes place once any new water supply infrastructure necessary to service the development while avoiding an adverse effect on European sites is in place.

7.1.7 If these measures were incorporated into the Core Strategy it would enable the Council to conclude with greater certainty that the development to be delivered under the Core Strategy would not lead to an adverse effect upon European sites.

49 Broxbourne Borough Council Core Strategy

Appendix 1: ‘Tiering’ in Habitat Regulations Assessment

Planning Policy Statements AA

Increasing Sub-Regional Strategies AA specificity in terms of evidence base, impact evaluation, mitigation, consideration of Local Development Frameworks AA alternatives etc.

Individual projects AA

Habitat Regulations Assessment July 2010 50 Broxbourne Borough Council Core Strategy Appendix 2 –Core Strategy Screening Summary

Policy Details Screening Decision CS1 - Sustainable neighbourhoods will be achieved by: No, as this policy could Sustainable have an influence over Neighbourhoods the location of • Planning for beneficial regeneration and growth in and around urban areas. Development will development. provide high quality housing and job opportunities, protect open spaces, design out crime and anti-social behaviour, provide habitats for wildlife and exhibit high standards of design which enhance local surroundings and protect distinctiveness. • Achieving a closer relationship between homes, jobs and other services. Development will be directed to urban sites in existing towns, Greater Brookfield strategic allocation, small edge-of- urban sites that can be delivered without major infrastructure investment and/or large green belt sites supported by investment in roads, public transport, utilities, open spaces and community facilities. • Improving accessibility. Development proposals will reduce the need to travel, improve public transport, walking and cycling opportunities and be accessible to all members of the community. • Improving the sustainability of homes and other buildings. All development proposals will accord with national climate change, energy, water, waste and flood risk policies, achieve the relevant Code for Sustainable Homes standard and/or a high BREEAM rating and take account of guidance in the Hertfordshire Building Futures programme. Larger development proposals must explain how sustainability objectives will be implemented.

CS2 - Housing Provision will be made for 240 dwellings per year, which equates to 3,840 dwellings in the period No, as this policy could Development 2010-2026. Delivery will focus on suitable urban sites throughout the plan period and will be have an influence over complemented by about 350 dwellings at Greater Brookfield strategic allocation in the short and the quantum and medium term and small edge-of-urban sites and/or large green belt sites in the medium and long location of term. development.

Short-Term Medium-Term Long-Term

Habitat Regulations Assessment July 2010

51 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision 2010-2016 2016-2021 2021-2026 Commitments 900 Urban sites 475 620 520 Greater Brookfield 65 285 Green Belt sites 295 680 Housing development will be brought forward by: • Approving development proposals and allocating and phasing suitable urban sites in a Site Allocation DPD based on design and density considerations, infrastructure capacity and deliverability merits. • A strategic allocation at Greater Brookfield for comprehensive mixed use development including about 350 dwellings. • Allocating and phasing small edge-of-urban sites in a Site Allocation DPD in response to housing trajectory information and based on infrastructure considerations, local environmental capacity, deliverability merits and the ability to define defensible new green belt boundaries. Sites will be brought forward for development in the short term if needed. • Allocating and phasing large green belt sites in Areas of Search in a Site Allocation DPD in response to housing trajectory information and based on infrastructure considerations, local environmental capacity, deliverability merits, impact on the borough’s leafy suburban character and the ability to define defensible new green belt boundaries. Sites will be brought forward for development in the short term if needed. • The Council working in partnership with developers, landowners, utility providers, other stakeholders and the local community to prepare comprehensive masterplans for Greater Brookfield and large green belt sites. These should address the full range of issues which are likely to inform a major development proposal, including road access, public transport, walking and cycling, utilities, sewerage, affordable housing, housing mix, job opportunities, education, healthcare, local shops, community facilities, open spaces, flood risk and sustainable drainage, landscape impacts, wildlife and biodiversity, sustainability standards, high quality design and planning contributions.

Habitat Regulations Assessment July 2010

52 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision CS3 - Housing Development proposals will provide a balanced mix of housing types and sizes. No, as this policy could Mix have an influence over • A 40% affordable housing target will be applied to all development proposals of more than 0.5 the location of hectares or 15 dwellings to allow on-site provision where desirable or commuted payments for development. off-site provision where this is considered more appropriate.

• Commuted payments will be sought from smaller development proposals to help fund affordable housing and other community objectives. The Council will prepare a Planning Obligations SPD to calculate the viability • The size/type and density of all development proposals, particularly those in and adjoining urban areas, will be informed by design considerations, local surroundings and infrastructure capacity. Larger properties such as detached, semi-detached, town houses and bungalows will be favoured on small edge-of-urban sites and/or large green belt sites. • The proportion of social rented and intermediate properties that will be sought will be established in the Council’s Housing Strategy. • The Council will prepare design guidance to help developers incorporate Lifetime Homes standards and other standards to help accommodate changing needs and lifestyles. • The Council will promote the provision of specialist accommodation for the elderly and for people with physical and learning disabilities, mental health issues, drug and alcohol addictions and other specialist problems where there is an identified need.

CS4 – Travelling Provision for new gypsy and traveller pitches and new travelling showpeople plots will be allowed No, as this policy could Community within or adjoining the curtilage of existing sites in the borough where it can be conclusively have an influence over demonstrated that they cater for new households arising from within that site and where new the quantum and pitches/plots accord with national guidance, local objectives and site characteristics. location of development. If there is a requirement for new pitches/plots they will be well related to the primary road network, have good vehicle access and safe parking, turning and servicing space. They will have or be capable of receiving essential utilities such as power and water. They will ideally be close to local services such as schools, shops, healthcare and public transport. Sites must not be on important

Habitat Regulations Assessment July 2010

53 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision protected areas or significantly contaminated land and must seek to address flood risk. They will be suitable near motorways, railways, power lines and landfill sites so long as this does not result in unacceptable air, noise or odour pollution. The lack of suitable urban sites means that green belt sites will be considered on their merits.

Travelling showpeople plots also should have sufficient space for separate living, vehicle storage and equipment maintenance areas.

CS5 - Broxbourne will seek to build on objectives in local economic strategies by supporting proposals No, as this policy could Employment which retain and create jobs in existing employment areas and town centres, by supporting new have an influence over tourism activities and new retail and leisure jobs at Greater Brookfield and by promoting higher- the location of value jobs in existing employment areas, at Park Plaza North and new employment sites in Areas of development. Search. • Retain and improve employment sites at Essex Road and Merck Sharp Dohme in Hoddesdon, Delamare Road in Cheshunt, Lee Road / Britannia Road in Waltham Cross and Park Plaza South for offices, general industry, warehousing and ancillary activities. • Protect smaller employment sites unless an alternative use is considered to be of greater overall value to the community. • Promote a mix of high-value jobs and employment uses at Park Plaza North. • Support new retail, leisure, office and other jobs in town centres in accordance with Policy CS7. • Support new retail, leisure and other jobs at Greater Brookfield strategic allocation in accordance with Policy CS8. • Support proposals for hotel, tourism and leisure facilities that build on the presence and legacy of the 2012 Olympic Games, the Lee Valley White Water Centre and other unique assets such as Lee Valley Regional Park. • Appraise new employment land opportunities in the Southern A10 Corridor Area of Search in a Site Allocation DPD. Subject to these appraisals Park Plaza West would be supported for a high quality business park to help achieve a shift towards higher-value jobs and Maxwells Farm West would be supported for a mix of offices, general industry and other job-generating

Habitat Regulations Assessment July 2010

54 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision activities. The Council will work in partnership with landowners, developers, utility providers, other stakeholders and the local community to A10 Route Management Strategy prepare a comprehensive masterplans. This should address the full range of issues which are likely to inform a major development proposal, including road access, public transport, walking and cycling, utilities, flood risk and sustainable drainage, landscape impacts and landscaping, wildlife and biodiversity, sustainability standards, high quality design and planning contributions. All employment proposals should seek to reduce unemployment, support skills and training programmes, help to regenerate their surroundings, reduce out-commuting, minimise vehicle trips and achieve better access by public transport, walking and cycling.

CS6 - Retail and The retail strategy for Broxbourne will ensure that centres grow and develop relative to their size No, as this policy could Town Centres and status by directing uses to the most appropriate location. have an influence over the quantum and • Greater Brookfield is classified as a “Borough Centre” in order to reflect its primary function as a location of non-food shopping and leisure centre for the borough. development. • Hoddesdon is classified as a “Town Centre”. The Council and its partners will deliver the objectives of the Hoddesdon Town Centre Strategy to increase visitor numbers and spending by supporting a range of food shopping, non-food high street retailers, an eating/drinking places and other community facilities as well as a programme of public events and environmental actions. • Waltham Cross is classified as a “Town Centre”. The Council and its partners will deliver the objectives of the Waltham Cross Town Centre Strategy to increase visitor numbers and spending by supporting a range of food shopping, non-food high street retailers, eating/drinking places and other community facilities. • Cheshunt Old Pond is classified as a “District Centre”. The Council and its partners will seek to preserve its role for local residents by maintaining a balance of food and non-food shops and other community services. The Council and its partners will prepare and deliver the objectives of a Cheshunt Old Pond Strategy. • Smaller centres and groups of shops are classified as “Local Centres”. The Council and its partners will seek to preserve their role for local neighbourhoods by retaining and attracting food

Habitat Regulations Assessment July 2010

55 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision shops and other services. The Council and its partners will prepare and deliver the objectives of a Local Centres Strategy.

CS7 - Greater Greater Brookfield is a strategic allocation for up to 50,000 sq.m. gross of new shopping floorspace, No, as this policy could Brookfield up to 15,000 sq.m. gross of new leisure floorspace and about 350 dwellings. The development will have an influence over be implemented in accordance with an agreed masterplan. the quantum and location of • There will be a clear emphasis on non-food shopping and leisure facilities that will not development. undermine the role or function of existing town centres. New shopping facilities should include

a range of department, large and small format stores. New leisure facilities will include a multi- screen cinema, bowling alley and a range of eating and drinking places. • A new link road must be provided from the western arm of the A10 Turnford roundabout and a new access lane from the A10 Turnford roundabout onto the southbound lane of the A10 to help resolve existing traffic problems. • A strong emphasis will be placed on attracting workers and shoppers from all parts of the borough by public transport, walking and cycling. This must improve bus services to the centre. There must be good connectivity between new and existing shopping facilities. • Development must successfully relocate New River Trading Estate tenants, the Council depot, Turnford household recycling waste centre, Halfhide Lane allotments and Halfhide Lane Gypsy site. • Housing development will comprise high quality family homes at an average of 40 dwellings per hectare. These must be built at the same time as shopping and leisure floorspace to avoid the creation of an isolated housing area. • There must be a strong emphasis on sustainability in the form of statements and/or assessments for landscape, heritage and archaeology, energy, waste and water consumption, low or zero carbon energy generation, flood risk, sustainable urban drainage and transport. • There must be a strong emphasis on high quality design in order to create an attractive destination and contribute to wider regeneration ambitions. • There must be a package of appropriate planning contributions for affordable housing, local

Habitat Regulations Assessment July 2010

56 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision services and environmental improvements.

CS8 - To help conserve and enhance the natural, historic and built environment: Yes as this policy Environment controls rather than • Green Belt land will be protected from inappropriate development in accordance with national promotes guidance and a detailed review of green belt boundaries within Areas of Search will be development. undertaken as part of a Site Allocation DPD to test compliance with national green belt guidance, the sustainability credentials of each site, the deliverability merits of each site and the potential erosion of the borough’s leafy suburban character. • The following green corridors will be protected and enhanced to help link open spaces in towns with surrounding countryside: the Lee Valley Regional Park, New River green chain, Spital Brook valley between Barclay Park and Hoddesdon Park Woods, Rags Brook valley between Rosedale and Cheshunt Common, Cheshunt Park, Wormley playing fields and land from Cedars Park into Theobalds Park. The Council will work with Lee Valley Regional Park Authority to deliver the visions, aims and objectives of the Park Development Framework. • All sites in and adjoining the borough which are protected by the planning system for their landscape, wildlife, scientific and /or archaeological value will be conserved and enhanced in accordance with national guidance and local objectives. • The Council will seek to maintain and increase the quantity and accessibility of open spaces in the borough in accordance with the following standards. The current average household size in Broxbourne is about 2.3 people per dwelling.

Space per Accessibility 1,000 residents Parks and Gardens 0.28 hectares 15 min walk Natural and Semi-Natural Space 1.26 hectares 15 min walk Amenity Greenspace 0.46 hectares 10 min walk Provision for Children 0.04 hectares 10 min walk

Habitat Regulations Assessment July 2010

57 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision Teenage Provision 0.02 hectares 15 min walk Allotments 0.2 hectares 15 min walk Outdoor Sports Facilities 1.88 hectares 15 min walk i.e. sports pitches, tennis courts Outdoor Sports Facilities 1.88 hectares 20 min drive i.e. golf courses, swimming pools

• The Council will work with the Environment Agency, landowners, developers and others to minimise the risk of flooding in accordance with national guidance and local evidence. • All development proposals should exhibit a high quality of design and seek to design out crime and anti-social behaviour. This will be informed by design guidance, Conservation Area appraisal and urban characterisation work. The design and density of urban sites should be informed by local surroundings and the capacity of local infrastructure. Greater Brookfield, small edge-of-urban sites and large green belt sites should provide housing in well designed and landscaped environments.

CS9 - To bring forward infrastructure and services that are needed to support housing, employment, retail, Yes as this policy Infrastructure leisure and other development. controls rather than promotes • The Council will work with local highways authority to find ways for development to connect to development. the existing road network and to prepare an A10 Route Management Strategy to ensure that the A10 and other roads and junctions can accommodate future traffic levels. The Council will also work with the Highways Agency to consider the role of the M25 and Junction 25. Developers should submit transport assessments to demonstrate that development proposals can be accommodated… • Ensure that a sensible amount of car parking is provided at key destinations such as town centres and railway stations. • Work with transport bodies to ensure that rail, bus, cycle and pedestrian facilities offer a range of transport options. The Council will support National Express plans to provide more rail services to Broxbourne. The Council will work with Transport for London and other

Habitat Regulations Assessment July 2010

58 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision stakeholders to explore options to extend bus services and the Oyster card scheme into Broxbourne. • Work with utilities bodies to ensure that all areas of the borough are well served by electricity, gas, water, sewerage and telecommunications. The Council will work with Thames Water and the Environment Agency to ensure that Rye Meads, Deephams and other sewage treatment works have sufficient capacity to accommodate new development. Developers should submit utility statements to demonstrate that such services can be supplied and have capacity. • Work with Hertfordshire County Council as the local education authority to ensure that all areas of the borough are well served by schools and other education facilities. • Work with health bodies to ensure that all areas of the borough are well served by hospitals and healthcare facilities. • Work with developers and other stakeholders to maintain and increase the quantity, quality and accessibility of community facilities in the borough. • Provide sufficient burial space to cater for local needs.

CS10 - Planning The Council will seek planning contributions from new development in accordance with national Yes, as there is no Conditions guidance and local policies to help fund policy objectives set out in the Core Strategy, the mechanism by which Sustainable Community Strategy and other planning documents such as town centre strategies and this policy could lead to development briefs. adverse effects since it controls rather than promotes The Council will prepare an infrastructure schedule covering the items listed below to map existing development. provision, identify any surplus/deficit and plan for future needs. This will be combined with viability appraisal work to inform a Planning Obligations SPD.

• Affordable housing • Open space, sports facilities and green infrastructure • Utilities infrastructure

Habitat Regulations Assessment July 2010

59 Broxbourne Borough Council Core Strategy

Policy Details Screening Decision • Flood prevention and sustainable urban drainage measures • Renewable and low carbon energy schemes • Transport infrastructure • Public transport, walking and cycling • Education provision • Healthcare provision • Community facilities • Skills and training programmes • Business support services • Sustainable Community Strategy objectives • Town Centre Strategy objectives • Development Brief objectives

Habitat Regulations Assessment July 2010

60 Ware THIS DRAWING MAY BE USED ONLY FOR THE PURPOSE INTENDED AND ONLY WRITTEN DIMENSIONS SHALL BE USED 1 1 NOTES Welwyn Garden City Hertford 1 Special Area of Conservation A119 1. Epping Forest 1 2. Wormley Hoddensdon-Park Woods A414 A1019 Special Protection Area Harlow 1. Lee Valley A6129 1 Ramsar Site 1 1. Lee Valley 1 A1169 1 A1025 Broxbourne District Boundary A1170 Major Town / City A1001 Hatfield Hoddesdon Mainline Railway 2 2 2 Motorway Primary / A Road 2 2 2

2 A1000 M11 1 A1(M) 1 Broxbourne District A128 1 Cheshunt 1 Epping

1 Copyright Potters Bar This map is reproduced from Ordnance Survey 1 M25 material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Waltham Abbey Stationary Office.

1 © Crown copyright A1005 Unauthorised reproduction infringes Crown 1 copyright and may lead to prosecution or A1(M) 1 civil proceedings. Scott Wilson GD0100031673 2006 1 A1081 1 A113 Loughton A5135 A111 A1168 A110

Revision Details By Date Suffix A112 1 Check Drawing Status 1 FINAL A1004 1 A1112 A105 Job Title A5109 Southgate A1 Chingford Chigwell BROXBOURNE APPROPRIATE A109 ASSESSMENT SCREENING A1055 1 1

Drawing Title

A5100 A1037 LOCATION OF A1010 INTERNATIONALLY A109 A1009 DESIGNATED SITES

1 Scale at A3 A406 1:100,000 A1080 1 Drawn TD Approved JR M1 1 A1400 A125 Stage 1 check Stage 2 check Originated Date A118 Hendon 1 A123 Scott Wilson A111 Scott House A5150 Basing View, Basingstoke A1 1 Romford Hampshire, RG21 4JG A598 A1201 Telephone (01256) 310200 1 A1006 Fax (01256) 310201 1 A1008 www.scottwilson.com A1251 1 Drawing Number Rev A107 FIGURE 1 Plot Date: 23rd October 2007 Filepath: K:\D117071_Broxbourne_AA\ArcGIS\MXDs\Figure Internationally1 Designated Sites.mxd A103 A116 A124