Site Allocations Plan Leeds Local Plan
Post-Examination Hearing Note on HRA Matters: Response to Inspectors’ Questions
Development Plan Document November 2018 Contents Page
1. Context and Inspectors’ Question 1-9 2
Appendices
Appendix 1:
Habitat Regulation Assessment: Screening & Appropriate Assessment for the Leeds Site Allocations Plan (SAP) – November 2018 16
Appendix 2:
Advice from Natural England 62
Appendix 3
Plan of Leeds visitors to the SPM SPA/SAC (Bradford Visitor Survey information 2013) 67
Appendix 4:
Further Proposed Modifications to the Submission Draft Plan May 2017 arising from the Habitats Regulations Assessment 6
1 of 71 Post-Examination Hearing Note on HRA Matters: Response to Inspectors’ Questions
For ease of reference, some questions of the Inspectors (reproduced verbatim below) are punctuated by the reference “[x]”, corresponding to specific questions. Answers given to specific questions are prefaced by the same reference.
1. Context
1. Further to the submission of Examination documents EX35, EX35 and EX35b, the City Council has carried out further technical work on HRA Screening and has undertaken an Appropriate Assessment of the SAP. In response to the Inspector’s Post-Hearing Note, the following provides a response to these questions. In informing this material, the HRA Screening & Appropriate Assessment November 2018, is enclosed (at Appendix 1) and is cross-referenced as part of the response, where relevant.
2. In response to the Inspectors Post-Hearing Note, it should be emphasised also that the City Council has worked closely with Natural England (NE) on this further iteration (their response interim is enclosed in Appendix 2). Prior to the completion of this further version, the response from NE dated 7th September 2018 (Appendix 2), in response to the conclusion of an HRA completed in August 2018 (following on from the Hearing sessions but prior to the City Council’s receipt of the Post- Hearing Note) is also enclosed for completeness.
Inspectors’ Question 1:
How any suggested Main Modifications deleting housing / mixed use sites in Green Belt impacts on HRA?
3. Yes, a positive change which serves to reduce the level of potential impact. There are four proposed Main Modifications that will impact on the HRA. These relate to the proposed deletion of 4 sites within the Green Belt and the 7km zone of influence for potential recreational disturbance (7km Zone of Influence), of the South Pennine Moors Phase 2 (SPMP2) SPA/SAC European Site.
4. Plan 1 of the HRA Screening & Appropriate Assessment (see Appendix 1) (HRA SAA) shows the new housing growth in Leeds Metropolitan District within the 7km Zone of Influence (as identified by the Bradford 2013, South Pennine Moors Visitor Survey). In reflecting the Inspectors observations on broad locations and delivering housing growth over the next 5 years (see Inspectors Post Hearing note 5th October 2018), Plan 1 shows that through the SAP there are 11 sites proposed to 2023, which fall within the 7km zone. These sites have a total capacity of 627 units (see: paragraph 5.3 of the HRA SAA for a breakdown of capacity per site).
5. Plan 3 shows (in blue) the 4 sites formerly proposed for allocation and which will remain in the Green Belt. These would have contributed 586 units. Because of the proposed deletion, the number of units now proposed to be located within the 7km Zone of Influence will reduce from 1213 to 627 units.
2 of 71 6. A consequence of the above proposed Main Modifications (i.e. the reduction of 586 units), is the relationship and correlation between the number of units and the potential for recreational impacts on the SPMP2 SPA and SAC. Therefore, as the number of units within the 7km zone is being reduced, this will in turn reduce the potential for impact upon SPMP2 SPA and SAC. Fewer visitors therefore means that the potential impact upon sensitive habitats and species is reduced.
7. In addition to the approach described above, a series of ‘existing conservation measures’ are also in place within North West Leeds. These comprise the proactive management (together with its quality as a Green flag site) of Chevin Forest Park and the Leeds City Council – Parks and Countryside, “North West Leeds Country Park and Green Gateways” project. This level of provision, management and commitment, offer positive, local and viable alternatives to travelling to the SPMP2 SPA and SAC (see also response to Inspectors Question 4 below).
Inspectors’ Question 2:
How the ‘conservation’, ‘preventative’ and ‘compensatory’ measures set out in Column 6 (Appendix A {Appendix 2: Assessment of Likely Significant Effects} of EX35b) correspond to [relate to the impacts on] the natural habitats and their species in the SPA/SACs [1] and in general terms how the measures are monitored in respect of their effectiveness on the status of the SPA/SAC [2].
[1] 8. As highlighted (in Para. 1) above, further technical work has been undertaken following on from EX35b, resulting in the HRA SAA. As part of this, Column 6 provides clarification of ‘Type of Measure referred to as Avoidance Measure/Precautionary Avoidance Measure of Mitigation, in Columns 4 & 5’. This in turn specifies and categorises measures as, ‘conservation’, ‘preventative’ and ‘compensatory’, where appropriate.
9. Within this context, Para. 4.6 OF Appendix 1 (and Appendix 2 of this document, final Column 6) of the HRA SAA has identified the following Likely Significant Effects (LSEs) that were not ruled out at the Screening Stage, being:
i. Potential recreational impacts through the increased disturbance to qualifying bird species and bird assemblage from increased visitor numbers to the SPA resulting from proposed residential allocations within 7km of the SPA boundary.
ii. Potential recreational impacts through increased disturbance to qualifying habitats from increased visitor numbers to the SAC resulting from any allocations within 7km of the SAC boundary.
10. These two potential recreational impacts on the Site Integrity of the SPMP2 SPA and SAC would be the only impacts on the natural habitats and their species in these SPAs and SACs and the remaining SACs relating to the Metropolitan
3 of 71 District. Consequently, no other Column 6 ‘conservation’, ‘preventative’ and ‘compensatory’ measures, would have any such impacts.
11. The interrelationship between potential recreational impacts (identified at Para. 4.6 of the HRA SAA) and Site Integrity is outlined below. This is taken from the synopsis in Appendix 3 of the HRA SAA:
i. SPM Phase 2 (SPMP2) SPA: the potential recreational impacts arising from additional visits from residents of the 627 new homes (from public access and dogs, off-lead) are: to feeding and breeding birds on the ground. Relevant bird species are the qualifying species of Merlin and Golden Plover, together with all the breeding bird assemblage: Lapwing, Curlew, Dunlin, Snipe, Redshank, Common Sandpiper, Short-eared Owl, Whinchat, Wheatear, Ring Ouzel and Twite;
ii. SPMP2 SAC: the potential recreational impacts arising from additional visits from residents of the 627 new homes (from public access) are: degradation to the structure and function of qualifying habitats features. These are: Atlantic wet heaths, Wet heathland, Dry heathland, Blanket bogs, Transition mires and Quaking bogs, Very wet mires, and Old sessile Oak woods. 12. Section 5 of the HRA SAA concerns the assessment carried out of the above potential recreational impacts on Site Integrity. Para. 5.12 identifies existing conservation’, ‘preventative’ and ‘compensatory’ measures to reduce to an acceptable level any recreational impacts on the SPM P2 SPA and SAC. These are existing measures that provide the role in diverting deflecting recreational visits from the SPMP2 SPA/SAC and comprise of the management and enhancement of the following alternative accessible green spaces in North West Leeds:
• The Chevin Forest Park Local Nature Reserve (Plan 4 HRA SAA) • The North West Leeds Country Park and Green Gateways project (Plan 5 HRA SAA).
13. Section 5 also notes that Core Strategy (CS) Policies SP13, G1, G3 and G4 would together secure the provision of on-site green space from the proposed allocations and provide for the enhancement of off-site green space in North West Leeds. The provision of on-site green space is a measure affecting the status of the SPMP2 SPA and SAC.
14. The above cumulatively comprise all of the measures which will avoid any adverse impacts on Site Integrity on the SPMP2 SPA and SAC to acceptable levels.
[2] 15. The City Council’s Authority Monitoring Report (AMR) (CD1/39) provides an important means of monitoring the effectiveness of CS Policies SP13, G1, G3 and G4. The AMR, in turn specifies and records the expenditure on green infrastructure and green space provision and how these funds are being broadly spent, as an integral aspect of the development process. This summary gives
4 of 71 both a quantitative and qualitative overview of the operation of the CS green space Policies.
16. The AMR indicator number 24 concerns the provision of green infrastructure and green space, and is entitled “Provision of Green Infrastructure and green space as obtained through development process and other sources”.
17. The latest published AMR for 2016/17 confirms that over the previous 5 years, over £5M (of more than £7M) has been expended on green infrastructure and green space projects within Leeds, as a whole. In strategic terms, this illustrates that the Policies are effective in that they are successfully generating funds which are able to secure additional or enhanced green infrastructure and green space from new development. This in turn continues to secure alternative green space and green infrastructure resources within North West Leeds. A consequence of this approach is to deflect visitors away from the SPMP2 SPA and SAC, due to the size, scale, range and quality of alternative local green space provision being available.
Leeds AMR (2016/17), Table 23 Table 23:Section 106 green space contributions - £ received and spent Year Amount received Amount spent 2016/17 £1,702,649 £1,171,134 2015/16 £2,009,517 £1,241,825 2014/15 £1,103,334 £1,259,367 2013/14 £1,530,417 £336,972 2012/13 £804,873 £991,087
18. At a more localised level, the expenditure on green space and green infrastructure within the five wards which comprise North West Leeds (Guiseley & Rawdon, Otley & Yeadon, Adel and Wharfedale, Calverley & Farsley and Horsforth – see below), which lie adjacent to Bradford District, equate to sums which are ‘committed to spend’ (£296, 2140), ‘sums available to spend’ (£1,237,177) and ‘amount spent’ (£486,653) (November 2018). This cumulative level of expenditure highlights the availability of funds specifically within North West Leeds to manage, enhance and provide green space resources, as a positive planning policy outcome. Consequently, the physical location and community benefit associated with these green space resources, provide an immediate ‘local green space destination’, which helps to absorb and to deflect and divert recreational trips away from more sensitive areas within the SPMP2 SPA and SAC.
5 of 71 Wards in North West Leeds
19. Within the wider context of a review of the deployment of green space expenditure, further analysis of Bradford Council’s 2013 Visitor Survey data information has been undertaken. This has focussed upon trip origins within Leeds Metropolitan District to destinations with SPMP2 SPA and SAC. This spatial analysis reveals a dispersed pattern of visitors from postcode locations within Leeds (see Appendix 3). Consequently, this identified a wider ‘spread’ of visitors, rather than exclusive visits from local residents just within North West Leeds. Visits from further afield suggests that such visits are motivated by recreational choices for a ‘day out’ linked to Rombalds/Ilkley Moor, rather than high intensity and frequent visits for local ‘dog walking’ for example and are not directly linked to housing allocations within the 7km zone. 20. In addition to the measures described above, a series of green space and countryside management measures are also in place within North West Leeds. These comprise the proactive maintenance and enhancement (necessary to retain its quality and status as a Green flag site) of Chevin Forest Park and the Leeds City Council – Parks and Countryside service, “North West Leeds Country Park and Green Gateways” project.
6 of 71 Inspectors’ Question 3: What is meant by ‘completed’ measures (as referred to in paragraph 8 of EX35b), as some of the measures (e.g. Policy G3 of the Core Strategy) appear to be on-going.
21. To clarify, the reference made to ‘completed’ measures refers to those measures that have already been planned for and adopted as part of extant Local Plan policies (e.g. Policies of the Leeds Core Strategy).
22. The reference to ‘completed’ measures in document EX35b should not be interpreted as measures that are “no longer being implemented”. These measures are existing measures (i.e. planned for and adopted prior to the SAP) and are presently being implemented on an on-going basis and which will be required to be considered as part of decision taking stage. The focus of this approach is through the ongoing implementation of adopted Policy objectives via the Development Management process. Within this context, the enhancement and provision of green space and green infrastructure across the District, is an integral and cumulative component of the development process in terms of place making and facilitating sustainable communities.
Inspectors’ Question 4:
Additional information is also requested in relation to the following: Recreational Impacts
How the Chevin Forest Park LNR and the ‘North West Leeds Country Park and Green Gateways’ provide a viable alternative to visiting the SPA/SAC? For example, was the use of the LNR informed by surveys of visitors to the SPA/SACs? [1] Noting the information contained within CD1/21a (page 27- 29), have more recent visitor surveys within the LNR been conducted [2], and does this include an assessment of its impact on the SPA/SAC? [3] Although there is reference to the ‘North West Leeds Country Park and Green Gateways’ project in CD1/21a (page 29-30), there is no supporting visitor information or detail on how the project works as it relates to the SPA/SAC and its potential to divert visitors from the SPA/SAC.
[1] 23. As outlined in the response to Question 3 above, Chevin Forest Park LNR and the ‘North West Leeds Country Park and Green Gateways’, are considered to provide viable alternatives to visiting the SPMP2 SPA and SAC. This is a result of the positive and proactive management of these resources by the City Council. Chevin Forest Park and the Leeds Country Park and Gateways initiative, facilitate the use of locally established green space and green infrastructure. The effective management and development of these resources ensure that they are attractive to and have the capacity to sustain a range of recreational visits, in meeting immediate and wider needs. Consequently, these resources are able to absorb and divert visits away from the SPA and SAC, in providing green space amenity and purpose.
7 of 71 24. The City Council has worked collaboratively with Natural England (NE) at the outset and during in the preparation of the SAP and each iteration of the HRA. Integral to this approach has been the consideration of any potential recreational impacts on SPA and SACs.
25. Throughout this process Council has promoted the above two sites in particular as being suitable alternative natural green space, which although not fully replicating the designated habitats, provide more convenient alternatives to the SPMP2. NE have accepted the principle and concept that the provision is acceptable. This point has been reiterated in further correspondence from NE in response to the November 2018 HRA SAA (see Appendix 2) and furthermore, NE has confirmed that this approach is established elsewhere throughout the country and has precedents in plans and projects associated with the Thames Basin Heaths Special Protection Area (SPA), for example. This is further underpinned in Bracknell Forest Council’s approach, including the Thames Basin Heath’s Supplementary Planning Document (https://www.bracknell-forest.gov.uk/parks- and-countryside/suitable-alternative-natural-greenspaces. This approach has therefore naturally informed the subsequent assessment of impacts upon site integrity.
26. In May 2015 (SAP emerging Publication draft) the Council met with NE to discuss the approach of alternative natural green space provision in North West Leeds (see: Appendix 10 of the HRA SAA) to ensure that the capacity of the Chevin Forest Park Local Nature Reserve (LNR) and other accessible natural green space (North West Leeds Country Park and Green Gateways) is sufficient, in quantitative and qualitative terms, to absorb and divert away from the SPMP2 SPA and SAC the additional visitors generated from the creation of new housing.
27. Plan 8 of the HRA SAA shows all of the accessible natural green space together with the Chevin Forest Park LNR and North West Leeds Green Gateways & Country Park project. This demonstrates a substantial network of green space resources (predominantly being of a natural typology), with much of it being in close proximity to the 11 SAP Housing allocations within North West Leeds. Good accessibility is also enabled by the strategic road network.
28. The relevant areas of green space forming part of the North West Leeds Green Gateways & Country Park project are shown on Plan 5 of the HRA SAA. So, as well as the Chevin Forest Park LNR there are 34 other green spaces that are owned and managed by the City Council which are located within the 7km Zone of Influence. These are managed by the Parks & Countryside Service and benefit from a dedicated project officer working with local community groups in order to enhance and promote these sites. For example, there is a trail route linking many of these ‘other’ (34) green spaces.
29. There is additionally a trail route linking many of these other green spaces (see the sample leaflet included at Appendix 12 of the HRA SAA), which highlights the ease of accessibility, connectivity and usability of this infrastructure.
8 of 71 [2] 30. NE advised that the City Council’s HRA should be supported by an analysis of Bradford Council’s 2013 Visitor Survey data, such that the contribution of the residents of Leeds to the level of disturbance and trampling within the SPMP2 SPA and SAC could be identified.
31.The analysis of Bradford Council’s 2013 Visitor Survey data was carried out and has been included in the City Council’s subsequent revisions made to the HRA. This data analysis had concluded that: (i) the implementation of green space improvement measures within the North West area of Leeds will provide sufficient certainty to divert any likely increase in visitor numbers away from Rombalds/Ilkley Moor (which forms part of the SPMP2 SPA and SAC) and (ii) that potential recreational impacts can be kept within an acceptable level in order to avoid a LSE.
32. No more recent visitor surveys within the Chevin Forest Park LNR (other than those which have given rise to the information contained within CD1/21a (page 27-29) have been conducted. The use of Chevin Forest Park LNR by visitors to SPMP2 SPA and SAC has not been specifically recorded through Visitor Survey information.
33. Justification for the City Council’s approach is evident from NE’s clear confirmation that the data analysis contained within the Leeds HRA of the Visitor Survey carried out by Bradford Council in 2013, was satisfactory (see Appendix 2).
34. NE agreed that if the increase in visitors is low and measures to manage visitors are implemented, then the Chevin Forest Park LNR and other areas of accessible natural green space (North West Leeds Country Park and Green Gateways) in North West Leeds is significant in providing the residents of Leeds with adequate access to natural green space which presents a viable alternative to visiting the SPMP2 SPA/SAC.
Inspectors’ Question 5:
What are the sources of ‘appropriate funding’ from proposed allocations, and how will this be invested in accessible green spaces in a manner that relates to the relevant SPA/SAC? 35. The adopted Leeds CS Policy ID1, sets out the full range of Implementation and delivery mechanisms across the Plan. This provides and overall strategic context as a basis to determine ‘appropriate funding’ from the proposed SAP allocations. In addition it should be emphasised that the City Council’s adopted Community Infrastructure Levy (CIL) also provides an ‘appropriate funding’ stream. The CIL ‘1, 2, 3’ list includes green infrastructure and public space (except for on-site provision required by CS Policies). Furthermore, where Parish and Town Councils and Neighbourhood Forums have a Made Neighbourhood Plan, they are able to secure 25% of CIL receipts generated within their Plan area.
36. More specifically in relation to green space, CS Policy G4 (New Green Space), requires for all new development to create appropriate levels of green space within
9 of 71 their boundary in order to mitigate the extra burden on existing green space arising from an increase in population. However, depending on circumstances, this is not always possible. In such instances an “On Site Contribution in Lieu” (OSCL) is secured by way of a planning obligation to fund improvements to green space. In investing in the provision of accessible green space, this is a source of ‘appropriate funding’.
37.The North West Leeds Country Park and Green Gateways Project (NWLCP) covers 35 green space sites (see Appendix 1), which are located within the 7km zone of influence, all of which are managed by Leeds City Council. This project covers an extensive area as part of the wider geography of North West Leeds. This area contains at least three Major Settlements (Guisley/Yeadon/Rawdon, and Otley, forming part of the CS Settlement Hierarchy). Within the context of the scale and distribution of growth identified in the CS, proposals for residential development within HMCA areas have been taken forward via the SAP. These proposals (and windfall development) will give rise to OSCLs that can be directed to the provision or enhancement of green infrastructure and green space, as part of the Country Park initiative.
38. The NWLCP has already secured funding from Green Leeds and the Big Lottery Fund (for a range of management measures including interpretation boards, seating and signage) and a key aim of this work is the involvement of local communities in planning and decision making. Within this overall context, OSCLs (arising from residential development), provide a further opportunity to provide trails and recreation areas, protection of divers wildlife habitats and to preserve the countryside, within the project area. These interventions therefore help to divert and deflect recreation trips away from the SPMP2 SPA/SAC, in presenting a well-managed recreational resources to local communities. Consequently, part of the funding sourced from OSCLs and the residential schemes identified, will be invested in developing the NWLCP and, in this way.
39. A major component of the NWLCP are the accessible foot path and cycling routes allowing for people to travel from the heart of the City Centre, to the Yorkshire Moors and beyond. In addition, the Dales Way link (linked to the Meanwood Valley Trail) is a walking route that runs from Leeds City Centre to the Lake District which bounds the eastern edge of the SPMP2 for several kilometres. The Chevin Forest Park LNR, therefore ‘dovetails’ into this wider integrated network as part of the overall NWLCP.
40.The increased popularity of these routes (noting that the Dales Way is of national repute: http://www.dalesway.org/route.html) will necessarily mean that ‘green tourism’ is materially directed away from the SPA, thereby mitigating the harm potentially caused by future residential development.
41. This overall strategic green infrastructure, localised green corridors and green spaces (recognised by adopted CS and saved UDP Policies), their scale, distribution and close proximity to and through communities, is a unique future of Metropolitan Leeds and the retention and enhancement of such routes are therefore integral to the entire spatial strategy of the CS.
10 of 71 Inspectors’ Question 6 How do Policies SP13 and G4 of the Core Strategy (SC) link to the potential recreational impacts on the SPA/SAC [1], and what assessment has been made to determine the effectiveness of Policies G1 (at paragraph 5.5.2 of the CS) and G3 (at paragraph 5.5.12 of the CS) in reducing recreational impacts on the SPA/SACs [2]? [1] 42. CS Policy SP13 identifies a series of strategic green infrastructure corridors across the District. Within North West Leeds this includes the Wharfe Valley and Chevin Ridge, together with Tong Cockersdale. The green infrastructure corridors located within the 7km zone of influence, are shown on Plan 6 of the HRA SAA.
43. The identification and multifunctional role of these green infrastructure areas serve to provide opportunities for local recreation (underpinned by the NWLCP). These areas are therefore able to absorb local recreation activity, diverting it away from the SPMP2 SPA/SAC. As noted in the response to question 4 above, a key part of the management of these areas is to work in partnership with community groups. Such an approach is able to ensure that these areas are therefore ‘fit for purpose’ in meeting these local needs.
44. CS Policy G4 seeks the provision of 80sqm of green space for every new dwelling. This policy is proposed for revision under the Core Strategy Selective Review, the examination for which will commence in February 2019. The proposed revision sets a requirement that is based upon the size of dwellings and equates to a contribution of 40sqm of green space per dwelling. It is considered that the provision of any additional new on-site green space (regardless of typology) will improve the recreational experience and therefore contribute to absorbing and diverting visitors away from the SPMP2 SPA/SAC.
45. It is anticipated that the 40sqm/dwelling requirement will deliver 2.5ha of new green space from the proposed allocations within the 7km Zone of Influence (calculated net of the proposed four site deletions, outlined in para. 3 above). The sites, their dwelling capacity and green space yield are listed below.
46. Should it not be possible or appropriate to deliver green space on site, OSCL will be utilised to enable green space provision to be enhanced or provided within the locality. The response to Question 4 above describes the initiatives underway within North West Leeds, to enhance and provide green infrastructure and green space for the benefit of local communities.
[2] 47. The focus of CS Policy G1 is to enable the operational delivery of the strategic objectives of SP13, through the policy implementation and development management process. The preparation of Planning Briefs, Master Plans and the determination of planning applications enable an assessment of the policy criteria in relation to specific proposals. The intent behind this approach is to mainstream the enhancement and extension of green infrastructure as an integral component of the development process. The purpose of this is to ensure that such resources are appropriately located and linked to existing networks to enhance the connectivity and integrity of these areas. The effectiveness of this Policy is
11 of 71 monitored via the development management process and the determination of development proposals on their merits.
48. Policy G3 of the CS sets out standards for open space and recreation. This Policy is designed to determine the adequacy of existing supply and the appropriate provision of new open space. Leeds is a large and complex Metropolitan District, with a wide range of green space provision by typology. The inclusion of this Policy within the adopted CS aims to ensure a sufficiency of green space supply across the District for the benefit of community needs and Leeds residents. Through this CS approach, the Plan is seeking to meet Leeds green space needs within its own Metropolitan District boundary, rather than having to rely on green space provision in neighbouring Districts to meet such needs.
Inspectors’ Question 7
Air Quality
Please provide further detail on how the West Yorkshire Local Transport Plan (LTP) and Policy SP11 of the CS affect the rate of acid and nitrogen deposition from traffic or industrial sites? [1] In addition, what would be the means of monitoring the effectiveness of these measures as the CS does not contain monitoring requirements in this respect? [2]
[1] 49. Policy SP11 of the CS (Transport Infrastructure Investment Priorities), provides an overarching context for the delivery of an integrated transport strategy for Leeds, consistent with the objectives of the West Yorkshire Transport Plan and the Leeds City Region Transport Strategy. The focus of this approach is to secure the implementation of a range of infrastructure improvements and other interventions.
50. Integral to this Policy approach is the intent to reduce the need to travel, promote modal shift (including walking and cycling) and to deliver improvements to public transport. A key factor in promoting this approach is the desire to tackle traffic based pollution and to mitigate the effects of climate change (through carbon reduction). The effect of these interventions overall, is to reduce sources of acid and nitrogen deposition for the benefit of public health, biodiversity and the longer term sustainability of communities.
51. In relation to the Leeds SAP, the HRA SAA concludes that there will not be any LSEs in relation to the Kirk Deighton SAC, arising from acid and nitrogen disposition from transport. Advice from NE (see Appendix 2) has confirmed that the distance normally considered to be an issue for acid and nitrogen disposition is 200m. At 382m away from the nearest road to be affected, the Kirk Deighton SAC lies beyond the 200m threshold. NE have commented also, that as the site lies to the east of the SAC and with the UK having a predominantly prevailing westerly wind, most of the emissions will go away from the SAC.
[2]
12 of 71 52. The effectiveness of the SP11 measures outlined above, is set within the wider context of the Leeds City Region Transport Strategy (2040) and the Low Emission Strategy, with monitoring arrangements through the West Yorkshire Combined Authority. In terms of monitoring effectiveness via the planning process, the operation of the established Duty to Cooperate mechanisms provide a basis to consider the strategic impacts and implications of Policies upon neighbouring authority areas. At a local Leeds level, the City Council current identifies and monitors a series of Air Quality Management Areas and is also current progressing a Clean Air Zone (CAZ), consistent with Government requirements.
Inspectors’ Question 8:
Water Quality
In relation to the Humber Estuary SAC and potential increases in waste water production, please provide further information on how the planning application process [1], building regulations [2] and the Environment Agency role [3] impacts on improving or maintaining water quality.
53. In relation to potential increases in waste water (and any impacts upon the Humber Estuary SPA/SAC as a consequence), are series of interventions are in place to prevent, manage and monitor waste water quality. These are set within the overall context of national regulation and statutory responsibilities, together with the operation of the Water Framework Directive. In terms of waste water processes, Yorkshire Water (via Asset Management Plans, which invest in new infrastructure to maintain and improve water quality), the City Council (planning application process and the operation of Building Regulations) and the Environment Agency (via pollution control and licensing), combine to help maintain and improve water quality.
[1] 54. In relation to the planning application process, the City Council has adopted planning Policies in place (Natural Resources and Waste Local Plan 2013) which address water quality in determining planning applications. These Policies have been developed in consultation with Yorkshire Water and the Environment Agency, who are also statutory consultees as part of the planning application process. These Policies are:
• Policy Water 1 of the Natural Resources and Waste Local Plan, promotes the improvement of water efficiency in new developments, and Policy Water 2 aims to protect water quality.
• Policy Water 2, specifically aims to ensure that developments located within areas adjacent to sensitive water bodies demonstrate control of quality of surface water run off for the lifetime of development and during construction. This is through the use of sustainable urban drainage (SUDs), which help filter and ‘clean’ surface water runoff, prior to being discharged into the watercourse This Policy encourages consideration of the design of water management infrastructure (e.g. sewers, drains, swales, pumping stations, ditches and infiltration systems) as an integral part of the urban and landscape design.
13 of 71 • Policy Land 1, requires the suitable remediation of contaminated land prior to development being undertaken.
55. Together, these Policies apply to all development and aid in meeting Water Framework Directive objectives for the reduction or limitation of pollution to watercourses and groundwater.
56. There is additionally national planning policy and guidance. Para. 13 (Reference ID: 56-013-20150327) of the National Planning Practice Guidance on Water Efficiency Standards set out within the optional technical standards states that a local planning authority may consider greater water efficiencies (i.e. the target of 110 litres of water per person per day for new homes).
57. Within this context, as part of the Core Strategy Selective Review, the City Council is seeking to adopt this as a standard for Leeds. If adopted, this will serve to further help reduce waste water generated from new development.
[2] 58. In relation to Building Regulations, these include new, additional optional Building Regulations on water (see Building Regulations 2010, Updated March 2016, G2 Water efficiency, Sanitation, hot water safety, and water efficiency), that assist in managing overall the generation of waste water from new development. The two standards for water consumption are explained as follows in the Building Regulations: Water efficiency G2. Reasonable provision must be made by the installation of fittings and fixed appliances that use water efficiently for the prevention of undue consumption of water. Water efficiency of new dwellings 36.—(1) The potential consumption of wholesome water by persons occupying a new dwelling must not exceed the requirement in paragraph (2). (2) The requirement referred to in paragraph (1) is either— (a) 125 litres per person per day; or (b) in a case to which paragraph (3) applies, the optional requirement of 110 litres per person per day, as measured in either case in accordance with a methodology approved by the Secretary of State. (3) This paragraph applies where the planning permission under which the building work is carried out— (a) specifies the optional requirement in paragraph (2)(b); and (b) makes it a condition that that requirement must be complied with. (4) In this Part, “new dwelling” does not include a dwelling that is formed by a material change of use of a building within the meaning of regulation 5(g).
[3] 59. In terms of water quality, the Environment Agency has a key role to play as a statutory consultee as part of the plan making process and the determination of planning applications. In addition the Environment Agency also has a statutory responsibility for managing pollution control and water quality via licencing discharge consents.
60. The Environment Agency commonly refer to the above development management policies in support of their (statutory) consultation responses in respect of planning applications.
14 of 71 61. The Environment Agency has responsibility for assessing water quality as part of a review of consents in relation to impacts on the Humber Estuary SPA/SAC.
62. In relation to the preparation of the SAP, it should be emphasised that Yorkshire Water and the Environment Agency (as statutory consultees), were consulted throughout and do not consider that the proposed allocations would have a detrimental impact upon water quality.
63. Within this overall context, the HRA SAA concludes that there will not be any LSEs in relation to the Humber Estuary SAP/SAC. In addition to the factors and responsibilities outlined above, it should be noted also that in relation to Leeds, the Humber Estuary SPA/SAC lies 26.5 km away, thereby reducing any potential impacts arising in Leeds.
Inspectors’ Question 9
Monitoring
Subject to the Council’s response to the above, in order for the approach to SPAs/SACs to be robust monitoring for the identified measures will be required and should be referred to in the SAP to reflect circumstances where monitoring is not currently in place. The Inspectors request that the Council draft Main Modifications that refer to monitoring of the measures, where this is not included within adopted plans.
64. In providing a response to the Inspectors questions, the above responses set out the approach taken as part of the HRA SAA. In terms of the Council’s response to Question 2 above, reference is made to the Authority Monitoring Report (AMR) (CD1/39), as a basis to monitor the effectiveness of green space Policies. However, in relation to the issues raised as part of the HRA SAA (in relation to the SPMP2 SPA/SAC, the Council is now proposing MMs, to address this specific monitoring in relation to the SAP (and the 3 HMCA areas where appropriate) (see Appendix 4). The purpose of this is to reflect monitoring indicator 24 of the Council’s Monitoring Framework which supports preparation of the Authority Monitoring Report, as a basis to monitor green space provision in Outer West, Aireborough and North West.
15 of 71 Appendix 1
Site Allocations Plan Leeds Local Plan
Habitats Regulations Assessment: Screening & Appropriate Assessment
Development Plan Document November 2018
16 of 71 Contents
1. Introduction 2. European Designations. Conservation Objectives and Qualifying Features 3. Site Allocations Plan Scope and Objectives 4. Screening Stage 5. Appropriate Assessment 6. Conclusion
Appendices
Appendix 1: European Designations, Conservation Objectives & Qualifying Features which relate to sites
Appendix 2: Screening Stage Assessment
Appendix 3: Appropriate Assessment – assessment of impacts on Site Integrity
Appendix 4: Leeds City Council, Parks & Countryside Service positive management of green space in north-west Leeds Appendix 5: Leeds City Council, Parks & Countryside Service – Chevin Forest Park Action Plan (extract) Appendix 6: Assessment of LSEs in-combination Appendix 7: Visitor Survey 2013 - Significant overlapping postal districts Appendix 8: Visitor Survey 2013 – Postcode sectors Appendix 9: Formal response from Natural England confirming capacity of existing green spaces to absorb additional recreational pressure Appendix 10: Request from Natural England to use Bradford City Council 2013 Visitor Survey data Appendix 11: Distance of road network to Kirk Deighton SAC Appendix 12: North West Leeds Country Park & Green Gateways project leaflet
17 of 71 1. Introduction
1.1 This Habitats Regulations Assessment (HRA) Screening & Appropriate Assessment has been carried out to determine if the policies and site allocations of the Submission Draft Leeds Site Allocations Plan (2017) (SAP) as amended by proposed Main Modifications give rise to any Likely Significant Effects (LSEs), and further, in respect of any LSEs, whether mitigation (or other measures) as such, are required to ensure that no adverse impacts on Site Integrity will occur.
1.2 The following HRA Screening Determinations are superseded by this HRA Screening & Appropriate Assessment:
o Site Allocations Plan Updated Habitat Regulations Assessment Screening Submission Draft May 2017;
o Site Allocations Plan Revised Publication Draft: Area Proposals for Outer North-East HRA Screening Determination September 2016;
1.3 A Habitats Regulations Assessment Screening & Appropriate Assessment is provided for under the European Habitats Directive 92/43/EEC and Conservation of Habitats and Species Regulations 2017.
1.4 Article 6.3 of the Habitats Directive 92/43/EEC provides that any plan or project not directly connected with or necessary to the management of a European protected or Ramsar 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. With regard to this HRA Screening & Appropriate Assessment, the European Designations, Conservation Objectives and Qualifying Features relating to sites, are included at Appendix 1.
1.5 This approach reflects the LSE test provided for by the Habitats Directive, the precautionary principle and effects in combination. The assessment of each plan’s effects (Policies and allocations) on Site Integrity will be undertaken within the Appropriate Assessment, if necessary. The focus of the initial Screening Assessment stage is restricted to assessing whether a LSE may occur, which is a ‘filter’ rather than a detailed assessment of effects on site integrity. Within this context, LSE can be defined as follows: “A likely significant effect (LSE) is any effect that may reasonably be predicted as a consequence of a plan or project that may affect the achievement of conservation objectives of the features for which the site was designed, but excluding trivial or inconsequential effects (de minimis)” (Source: Natural England).
1.6 It is confirmed also that this HRA Screening and subsequent Appropriate Assessment has been undertaken with due regard to the judgment of the Court of Justice of the European Union (CJEU) C-323/17 dated 12 April 2018 in People over Wind, Peter Sweetman v Coillite Teoranta.
18 of 71 2. European Designations, Conservation Objectives and Qualifying Features (relating to Leeds Metropolitan District)
2.1 Appendix 1 sets out the European Designations, Conservation Objectives and Qualifying Features of potential relevance to the SAP. This includes all sites within 10 km of the Leeds City Council MD boundary and in addition, due to its strategic significance, the Humber Estuary has also been taken into account.
2.2 Information for each site has been obtained from the Joint Nature Conservation Committee website and Natural England. These sites are designated at the European Level as Special Protection Areas (SPAs) and/or Special Areas of Conservation (SACs). This means they have a very high level of conservation protection by virtue of their importance as key habitats of European significance. Sites can be designated as both an SPA and a SAC and they are also simultaneously designated for their national importance as Sites of Special Scientific Interest (SSSIs). Within this overall context, it should be noted that the Humber Estuary is identified as a site that may be affected (the Humber Estuary is also a Ramsar site).
2.3 Although only a small part of the South Pennine Moors Phase 2 SPA and SAC, (known locally as Hawksworth Moor or Rombalds/Ilkley Moor) is located within the Leeds City Council boundary (to the far north west of the District), the potential impact on remaining areas of this site (and others) outside the administrative area of Leeds MD must also be assessed. The Humber Estuary is 26.5 km from the Leeds MD boundary and is therefore not close enough for any individual sites allocated in the SAP, to directly impact on it. However, the cumulative effect of sites needs to be considered because of the potential for effects on the River Aire and River Wharfe (that join the River Ouse and ultimately flow into the Humber Estuary).
2.4 Within this context, the list of European sites considered by this HRA Screening & Appropriate Assessment are summarised as follows:
• The North Pennine Moors SPA/SAC: This is over 103,000 ha in size and exists in parts of County Durham, Northumberland, Cumbria and North Yorkshire. Located over 3km north-west of Leeds MD;
• The South Pennine Moors Phase 2 SPA/SAC, most of which lies outside the Leeds MD. It is part of a wider European Site (South Pennine Moors) which totals 64,000 ha covering other parts of West and South Yorkshire and the Pennine areas of Lancashire;
• Kirk Deighton SAC: This is approximately 4 ha in size and is located to the north of Wetherby – 500 metres north of Leeds MD;
• Denby Grange Colliery Ponds SAC: This is nearly 19 ha in size and located over 7km south of Leeds MD near the A637 in Wakefield District;
• Humber Estuary SPA/SAC (and Ramsar site), which is approximately 37,000 ha covering Humberside and Lincolnshire located 26.5km east of Leeds MD.
19 of 71 3. SAP Scope and Objectives
3.1 The SAP forms part of the Local Development Framework or ‘local plan’ for Leeds. The Plan follows on and is set within the overall strategic context of the Leeds Core Strategy, which sets out an overall vision for the District to 2028, together with the overall approach to the scale and distribution of housing growth. The Core Strategy was adopted by the City Council on 12th November 2014 (following independent examination, where the Plan was found to be sound) and identifies a series of strategic and thematic policies for Leeds incorporating priorities for regeneration, Housing, Employment, environmental protection and enhancement (including Green space, Biodiversity and Green Infrastructure) and infrastructure delivery.
3.2 In meeting the requirements of the Habitats Directive, the Core Strategy was subject to its own Habitats Regulation Assessment Screening Determination. This was subsequently agreed by Natural England. As part of this process, a number of Policies were strengthened (including Spatial Policy 1: Location of Development and G1: Green Infrastructure), to help mitigate any adverse nature conservation impacts upon SPAs and SACs. This approach was also considered to be sound by the Core Strategy Inspector.
3.3 In taking the requirements of the Core Strategy forward, the SAP identifies land allocations for Housing, Employment, Green space and Retail. Through Spatial Policies 6, 7, 8 and 9, the Core Strategy identifies the overall requirements for the scale and distribution of housing and economic growth. In addition, specific Policies are incorporated relating to Green space provision and the identification of Town and Local Centres. The Core Strategy also contains Policies relating to Natural Habitats and Biodiversity including Policy (G8) relating to the Protection of Important Species and Habitats (see below).
20 of 71 POLICY G8: PROTECTION OF IMPORTANT SPECIES AND HABITATS
Development will not be permitted which would seriously harm, either directly or indirectly, any sites designated of national, regional or local importance for biodiversity or geological importance or which would cause any harm to internationally designated sites, or would cause harm to the population or conservation status of UK or West Yorkshire Biodiversity Action Plan (UK BAP and WY BAP) Priority species and habitats. In considering development proposals affecting any designated sites and UK or WY BAP Priority species or habitats, the needs of the development and the requirements to maintain and enhance biological and geological diversity will be examined.
Other than the above requirement particular account will be taken of:
• The extent and significance of potential damage to the interest of any national, regional or local site, or UK or WY BAP Priority species or habitat; and • Demonstration that the need for the development outweighs the importance of any national, regional or local site, or UK or WY BAP Priority species or habitat; and • The extent that any adverse impact could be reduced and minimised through protection, mitigation, enhancement and compensatory measures imposed through planning conditions or obligations and which would be subject to appropriate monitoring arrangements.
3.4 The focus of the SAP is to identify allocations for Housing, Employment, Green space and Town and Local Centre boundaries. In identifying sites, consistent with Core Strategy Policy SP7, the District is sub divided into 11 Housing Market Characteristic Areas (HMCAs). Each HMCA has a specific housing target (in contributing to the overall District wide total) and also contributes to the overall target for General Employment Land. The green space allocations help to meet the standards set for different types of green space in Core Strategy Policy G3.
4. Screening Stage consideration for LSEs
4.1 Within the context of the only European Designation (part of the South Pennine Moors Phase 2 SPA/SAC) that occurs within Leeds MD (identified in para. 2.4 above), Plan 1 sets out the proposed SAP allocations (for Housing, Employment and Protected Areas of Search/safeguarded land) in relation to Aireborough/North West Leeds (Green space allocations within Leeds MD are also identified for information). For completeness, Plan 1 also includes existing identified sites, together with 2.5 km and 7km zones of influence in relation to the SPAs and SACs. It should be noted that the 7km zone of influence for recreational impacts is derived from the Bradford City Council’s HRA prepared for it’s Core Strategy, which was based on 2013 visitor survey information with regard to the South Pennine Moors Phase 2 SPA/SAC.
4.2 With regard to the Kirk Deighton SAC (which occurs 500 metres north of the Leeds MD and is situated with the administrative area of Harrogate Borough Council), the proposed housing, employment and green space SAP allocations are identified on Plan 2 for information, showing the nearest allocation being 1.01km away.
21 of 71 4.3 As stated in para. 1.5 above, the focus of the Screening Stage, is upon the identification of LSEs arising from proposed allocations associated with their proximity/likely impact upon European Designations/Conservation Objectives. In reflecting this approach, Appendix 2, provides consideration of whether a LSE is identified in respect of each European Site. Where a LSE is identified at the Screening Stage then an Appropriate Assessment is required to consider in more detail any adverse impacts on Site Integrity and potential threats to Conservation Objectives.
4.4 The identification of LSEs for consideration has been informed by the Core Strategy HRA Screening Determination (previously approved by Natural England and subsequently found to be sound by the Core Strategy Inspector), further advice received from Natural England on the draft HRA Screening determination for the SAP (11th May 2015), the Bradford Core Strategy and Waste Management DPD and HRA Screening and the Kirk Deighton SAC Site Improvement Plan (included at Appendix 1).
4.5 Advice from Natural England dated 24th August 2016 stated that the distance normally considered for acid and nitrogen deposition is 200 metres, and that specifically in the case of Kirk Deighton SAC because allocations are to the east of the SAC emissions will normally go in the opposite direction (from predominantly westerly UK winds). Therefore consideration is only required of roads within 200m of European Sites that are expected to experience an increase in traffic. Appendix 11 shows the nearest road that is likely to receive any increase in traffic being 382.5 metres away.
4.6 The Screening Stage (see Appendix 2 last column) has identified the prospect for the following LSEs in relation to the South Pennine Moors (Phase 2) SPA and SAC and following recent case-law these may not be screened out and will need to be considered further by way of an Appropriate Assessment:
Impacts on qualifying bird species and breeding bird assemblage
• Recreational impacts through increased disturbance to qualifying bird species and bird assemblage from increased visitor numbers to the SPA resulting from any allocations within 7km of the SPA boundary
Impacts on qualifying habitats
• Recreational impacts through increased disturbance to qualifying habitats from increased visitor numbers to the SAC resulting from any allocations within 7km of the SAC boundary.
Section 5 will now proceed to consider the above LSEs as part of the Appropriate Assessment Stage.
22 of 71 Plan 1 - European Designations and Leeds Site Allocations Proposals HG1-15 HG1-16 North Pennine Moors Kirk Deighton HG1-17
South Pennine Moors MX1-1 HG1-18 HG1-19 MX2-1 HG1-20 MX1-26 MX2-2 EG2-2 EG2-3 HG1-21 HG2-13 HG1-22HG1-23 Outer North West
Denby Grange Colliery Ponds
Otley and Yeadon Adel and Wharfedale
HG1-1 HG2-1 HG1-2 EG1-72 HG1-3 HG1-4 Aireborough HG2-2 EG1-1 Guiseley and Rawdon HG1-7 EO1-1 HG1-6 HG1-5
HG1-8 HG2-8 HG2-6 HG2-9 HG2-7 Leeds City Council Wards HG2-4 HG1-9 Housing Market Characteristic Areas HG2-229 North Pennine Moors (SAC/SPA) - 2.5km buffer EG1-4 South Pennine Moors (SAC/SPA) - 2.5km buffer North Pennine Moors (SAC/SPA) - 7km buffer HG1-11 South Pennine Moors (SAC/SPA) - 7km buffer HG1-12 HG1-10 EO1-2 North Pennine Moors (SAC/SPA) South Pennine Moors (SAC/SPA) Denby Grange Colliery Ponds HG1-13 HG1-14 Kirk Deighton EO1 - Identified office employment EO2 - Office allocation EG1 - Identified general employment EG2 - General employment allocation North Leeds Weetwood HG1 - Identified housing k k kHG2 - Housing allocation MX1 - Identified mixed use k k k Horsforth MX2 - Mixed use allocation kGGGG k k GGGGHG3 - Safeguarded land kGGGG k k Green Space Calverley and Farsley © Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 21/11/2018 Outer West Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 1.mxd Created by: NF Plan 2 - Kirk Deighton SAC and Leeds Site Allocations Proposals
1.44km
1.01km
HG2-19 HG2-226
HG1-28
Legend Leed MD Boundary Kirk Deighton distance to sites HG1-34 Allocated for school HG1 - Identified housing HG2 - Housing allocation Kirk Deighton (SAC)
© Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 21/11/2018
Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 2.mxd Created by: NF 5. Appropriate Assessment Stage
5.1 An integral requirement of the HRA Appropriate Assessment process, is to provide an Assessment of Likely Significant Effects (LSEs) on Site Integrity both alone and in–combination with other plans and projects.
5.2 The two potential recreational impacts on Site Integrity of the South Pennine Moors Phase 2 SPA/SAC identified in para. 4.6 are assessed in this section. Firstly there is a consideration of the number of additional houses arising from the SAP in the 7km zone of influence. Secondly there will be consideration of the impacts on Site Integrity arising from any increase in recreational visits. Thirdly, if there was found to be an impact on Site Integrity new measures will need to be agreed with Natural England and put in place as part of this SAP through a Main Modification.
5.3 Plan 3 shows the new housing growth in Leeds MD within the 7km zone of influence for potential recreational disturbance (identified by the South Pennine Moors Visitor Survey). There are currently 20,019 existing or already committed homes in this area. Plan 3 shows that through the Site Allocations Plan there are a further 11 sites proposed to 2023, with a total capacity of 627 units. Plan 3 also shows in blue (for information) the 4 previously proposed housing allocations which were proposed to be removed from the Green Belt but are now proposed to be deleted via Main Modifications. The effect of this is that 586 units less will be allocated for housing than that initially proposed. Therefore, since the Examination in Public the number of units in the 7km zone of influence for recreational disturbance has been reduced from 1213 to 627 units.
Allocations in 7km recreational zone of influence
Allocation Ref. Name of Distance from S Capacity in units allocation Pennine Moors Phase 2 SPA/SAC in km HG2-1 New Birks Farm 3.0 160 HG2-2 Wills Gill 4.6 133 HG2-4 Hollins Hill 3.8 80 HG2-6 Silverdale Av 4.4 32 HG2-7 Swaine Hill Terr 5.5 7 HG2-8 Kirkland House 5.6 17 HG2-9 Victoria Av 6.8 102 HG2-13 White Croft Garth 4.6 16 HG2-229 Old Mill Miry Lane 6.0 15 MX2-1 Ashfield Works 4.6 50 MX2-2 Westgate 4.7 15
23 of 71 HG1-15 Plan 3 - European Designations and Leeds Site Allocations Proposals HG1-16
North Pennine Moors HG1-17
MX1-1
HG1-18 HG1-19 South Pennine Moors MX2-1HG1-20 MX1-26 EG2-2 MX2-2 EG2-3 HG1-21 Outer North West HG2-13 HG1-22HG1-23
Adel and Wharfedale
Otley and Yeadon
HG1-1 BL1-6 HG2-1 HG1-2
EG1-72HG1-3 Guiseley and Rawdon HG1-4 HG2-2 EG1-1 Aireborough HG1-7 BL1-7 EO1-1 HG1-6 EG3 Leeds City Council Wards HG1-5 EO1-41 Housing Market Characteristic Areas EG1-3 North Pennine Moors (SAC/SPA) HG1-8 South Pennine Moors (SAC/SPA) HG2-8 North Pennine Moors (SAC/SPA) - 7km buffer HG2-6 HG2-9 South Pennine Moors (SAC/SPA) - 7km buffer HG2-7 BL1 - Broad Location BL1-8 EO1 - Identified office employment HG2-4 HG1-9 EO2 - Office allocation HG2-229 EG1 - Identified general employment EG1-4 EG2 - General employment allocation HG1 - Identified housing k k kHG2 - Housing allocation BL1-9 HG1-11 k k kMX1 - Identified mixed use HG1-12 MX2 - Mixed use allocation HG1-10 EO1-2 kGGGG k k GGGGHG3 - Safeguarded land kGGGG k k
© Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 19/11/2018 HG1-13HG1-14 North Leeds Horsforth Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 3.mxd Created by: NF 5.4 In terms of future housing growth across Leeds (including within Aireborough and North West Leeds HMCAs) integral to the Core Strategy is the aim to meet a variety of housing needs over the plan period. This includes meeting the needs of older people (less likely to travel for recreational opportunities) and single person households as well as family housing. Policy H4 of the Core Strategy therefore incorporates a requirement for an appropriate Housing Mix to be provided in the delivery of residential development. This Policy will therefore apply to the 11 new sites within Aireborough and North West Leeds where a variety of needs (consistent with the Strategic Housing Market Assessment evidence) will need to be addressed. Consequently, the increase in housing will comprise a variety of types to meet identified needs. It can be assumed therefore that a proportion of these will not generate additional visitor trips to the South Pennine Moors Phase 2 SPA/SAC due to the demographic profile of new residents. Therefore it is considered that although 627 housing units will be delivered in the 7km zone of influence (this equates to an additional population of approximately 1379 at a rate of 2.2 persons per household) some of those are unlikely to generate additional visits to the South Pennine Moors Phase 2 SPA/SAC.
5.5 In order to understand the contribution that visitors from Leeds MD make to recreational visits to the South Pennine Moors Phase 2 SPA/SAC Natural England advised that the Bradford City Council Visitor Survey results from 2013 should be analysed (see Appendix 10 for Natural England advice dated 15th July 2015 on the relevant 2013 Visitor Survey dataset and analysis, together with subsequent response received from Natural England Appendix 9). 1,378 adult visitors in 806 groups to the SPA/SAC were surveyed, these visitors came with 543 dogs. Of the visitors surveyed the contribution from Leeds was able to be identified using the postcode data provided.
5.6 The postcodes around the Leeds / Bradford border do not align with the local authority administrative boundaries but in general they are largely within one authority or another. The exceptions are shown in Appendix 7 and 8, where it is proposed that for the purposes of this Appropriate Assessment, visitors from LS29 should be included within the Bradford visitor figures and visitors from LS21 within the Leeds figures on the basis of their larger settlements. Those visitors from postcodes within Leeds total 107 adults bringing 17 dogs. This equates to 8% of visitors and 3% of dogs.
5.7 This is a relatively small proportion of the overall total number of visitors, and helps provide an understanding of the existing base-line scenario. This Appropriate Assessment provides consideration whether any new measures are required to avoid any adverse impacts on Site Integrity of the South Pennine Moors Phase 2 SPA/SAC from any increase in numbers of visitors arising from the new 627 allocations in the 7km zone of influence.
5.8 The relation between any potential additional recreational impacts on Site Integrity is explained below:
Recreational impacts on qualifying birds and the breeding bird assemblage (as per Appendix 1 column 4)
24 of 71 • South Pennine Moors Phase 2 SPA - the recreational impacts arising from additional visits from residents of the 627 new homes (from public access and dogs off leads) are potentially to feeding and breeding birds on the ground (relevant bird species in this case being the qualifying species Merlin and Golden Plover, together with all the breeding bird assemblage Lapwing, Curlew, Dunlin, Snipe, Redshank, Common Sandpiper, Short-eared Owl, Whinchat, Wheatear, Ring Ouzel and Twite). Recreational impacts on qualifying habitats (as per Appendix 1 column 4)
• South Pennine Moors SAC - the recreational impacts arising from additional visits from residents of the 627 new homes (from public access) are potentially degradation to the structure and function of the qualifying habitats features (Atlantic wet heaths, Wet heathland, Dry heathland, Blanket bogs, Transition mires and Quaking bogs, Very wet mires, and Old sessile Oak woods).
5.9 When considering whether the 627 new homes in the 7km zone of influence will impact on Site Integrity it is also necessary to consider whether there is existing green space in Leeds MD of a scale and typology that can deflect recreational visits from the South Pennine Moors Phase 2 SPA/SAC. In 2015 the HRA Screening Stage of the SAP considered the role of existing green space in North West Leeds and whether this provides a role in absorbing recreational visits from nearby residents. At that time the number of proposed allocations in the 7km zone of influence was 1 213 new homes (higher than the current 627 figure).
5.10 A meeting with Natural England took place on 21st May 2015 (see Appendix 10) to consider whether the existing green spaces managed by Leeds City Council (Otley Chevin Forest Park and the North West Leeds Country Park & Green Gateways project) could be considered to play an acceptable role in diverting and deflecting visitors away from visiting the South Pennine Moors Phase 2 SPA/SAC.
5.11 It was agreed by Natural England that continued management and improvement of existing open spaces in North West Leeds would provide sufficient certainty that any LSEs would be avoided – it should be noted that in 2015 these measures were considered as part of the HRA Screening Stage but since the judgment in People over Wind (referred to in para. 1.6) these existing measures (stated below) are now being considered under the Appropriate Assessment stage for this SAP rather than being screened out at the Screening Stage.
5.12 The existing measures that provide the role in deflecting recreational visits from the South Pennine Moors Phase 2 SPA/SAC are the management and enhancement of the following alternative accessible green spaces in North West Leeds: • The Chevin Forest Park Local Nature Reserve (Plan 4) • The North West Leeds Country Park and Green Gateways project (Plan 5)
5.13 The Chevin Forest Park LNR is a significant area of accessible green space (180 hectares) providing residents of Leeds with access to natural green space that is a viable alternative to visiting the South Pennine Moors Phase 2 SPA/SAC. Visitor Survey information (see Appendix 4) from annual surveys of visitors to Chevin Forest Park between 2004 and 2006 concluded that the Chevin Forest Park has
25 of 71 Plan 4 - European Designations and Leeds Site Allocations Proposals in relation to Chevin Forest Park Local Nature Reserve HG1-15 HG1-16
HG1-17
MX1-1 HG1-18 HG1-19 MX2-1HG1-20 MX1-26 MX2-2 EG1-7 EG2-2EG2-3 HG1-21 BL1-1 HG2-13 HG1-22HG1-23 HG3-5 Outer North West
Chevin Forest Park Local Nature Reserve
Adel and Wharfedale Otley and Yeadon
HG1-1 BL1-6 HG2-1 HG1-2
EG1-72HG1-3 HG1-4 EG1-1 Guiseley and Rawdon HG2-2 HG1-7 BL1-7 EO1-1 Aireborough HG1-6 EG3 Leeds City Council Wards HG1-5 EO1-41 Housing Market Characteristic Areas EG1-3 North Pennine Moors (SAC/SPA) HG1-8 South Pennine Moors (SAC/SPA) HG2-8 North Pennine Moors (SAC/SPA) - 7km buffer HG2-6 HG2-9 South Pennine Moors (SAC/SPA) - 7km buffer HG2-7 BL1-8 BL1 - Broad Location HG2-4 HG1-9 EO1 - Identified office employment HG2-229 EO2 - Office allocation EG1-4 EG1 - Identified general employment EG2 - General employment allocation HG1 - Identified housing BL1-9 HG1-11 HG2 - Housing allocation HG1-12 k k k HG1-10 EO1-2 k k kMX1 - Identified mixed use HG1-58 MX2 - Mixed use allocation kGGGG k k kGGGG k kHG3 - Safeguarded land GGGG HG1-13 North Leeds Chevin Forest Park Local Nature Reserve HG1-14 Horsforth
© Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 20/11/2018 HG2-11 Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Map 4.mxd Created by: NF North West Leeds Country Park and Green Gateways Project Plan 5 - European Designations and Leeds Site Allocations Proposals in relation to
1 Titty Bottle Park North West Leeds Country Park & Green Gateways project 2 Engine Fields 3 Kirk Lane Park 4 Micklefield Park, Rawdon 5 Nethermore Park, Guiseley 3416 6 Nunroyd Park, Guiseley 7 Otley Chevin Country Park 14 8 Tarnfield Park, Yeadon 10 9 Wellcroft 10 Wharfemeadows Park 1 17 11 Grove Hill Park, Otley 13 29 12 Fairfax Grove POS 13 Manor Garth 9 14 Farnley Lane 15 Shaw Lane Recreation Ground 16 Weston Drive Sports Field 20 11 Outer North West 17 Garnetts Field 19 18 Pegholme Drive POS 18 19 Cayton Road Playing Field 25 20 Grove Hill Cricket Ground 24 21 Henshaw Oval 22 Nunroyd Beck (Shaw Lane) 7 23 Hawkhill Avenue 24 Old Railway Line Off Bradford Road 25 Old Railway Off Otley Road 26 New Road Side Playing Fields 27 Little Moor 28 Hawksworth Recreation Ground 29 Stephencroft Park 30 Hawthorn Crescent POS 31 Engine Fields 32 Harper Terrace 33 Swaine Hill Terrace 34 Weston Drive - Playground 35 Engine Fields
5
Housing Market Characteristic Areas Aireborough North Pennine Moors (SAC/SPA) 15 22 South Pennine Moors (SAC/SPA) North Pennine Moors (SAC/SPA) - 7km buffer 23 South Pennine Moors (SAC/SPA) - 7km buffer 6 8 BL1 - Broad Location 3 30 EO1 - Identified office employment 28 12 EO2 - Office allocation 2 33 EG1 - Identified general employment 31 3131 32 EG2 - General employment allocation 3135 HG1 - Identified housing 21 k k kHG2 - Housing allocation k k kMX1 - Identified mixed use MX2 - Mixed use allocation kGGGG k k kGGGG k kHG3 - Safeguarded land GGGGNorth West Leeds Country Park and Green Gateways Project !! North West Leeds Country Park & Green Gateway Trail 27 26 North Leeds 4 © Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 19/11/2018
Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 5.mxd Created by: NF approximately 480 000 visitors per year and most visitors come from within 10km (60% arriving by car).
5.14 The North West Leeds Country Park & Green Gateways project covers 35 sites (including Chevin Forest Park) of green space in the 7km zone of influence, all of which are managed by Leeds City Council (see Appendix 12 for the latest promotional leaflet for this project – note that it only shows fewer main sites). These areas of green space are predominantly natural green space, and all offer accessible recreational opportunities near to local communities. There is also a walking trail route that connects many of these sites, and it should be noted that the South Pennine Moors Phase 2 SPA/SAC is not promoted or signposted in any Leeds City Council recreational marketing information.
5.15 The agreement with Natural England that the above green spaces in North West Leeds have a key role in absorbing/deflecting visitor pressure away from the South Pennine Moors Phase 2 SPA/SAC has been established since July/August 2015 (see Appendix 9), and therefore forms the focus of any subsequent assessment of impacts on Site Integrity.
5.16 In addition to the above existing measures (para. 5.12) there are also existing Core Strategy Policies that relate to:
• Maintaining and enhancing Green Infrastructure (Policy G1 and Spatial Policy 13) • Standards for Open Space, Sport and Recreation (Policy G3) • New Green Space Provision (Policy G4).
5.17 Policy G1 and SP13 apply to the Green Infrastructure (GI) Corridors shown on Plan 6. The supporting text in para. 5.5.2 of the Core Strategy seeks to maintain and enhance GI whilst considering any significant effects on the South Pennine Moors Phase 2 SPA/SAC.
5.18 Policy G3 sets out standards for Open Space, Sport and Recreation in relation to appropriate provision of new open space. The most relevant type of open space to provide an alternative to visiting the South Pennine Moors Phase 2 SPA/SAC is Natural Green Space and this is shown on Plan 7.
5.19 Policy G4 seeks provision of 80sqm of green space for every new dwelling. Following an operational review, Policy G4 is being proposed for revision in the Core Strategy Selective Review which was submitted for examination on 9th August 2018. The proposed revision sets a requirement based on the size of dwellings (5 bed dwellings provide more than 1 bed dwellings) which equates to an equivalent contribution of 40sqm of green space per dwelling. If it is not appropriate or possible to deliver all the green space on-site, equivalent financial contributions will be required. Indicator 24 of the Authority Monitoring Report (AMR), underpinned by the Monitoring Framework, provides a basis to monitor the effectiveness of these Policies.
26 of 71 Plan 6 - European Designations and Leeds Site Allocations Proposals in relation to Strategic Green Infrastructure
North Pennine Moors HG1-15 HG1-16
HG1-17
South Pennine Moors MX1-1 HG1-18 HG1-19 HG1-20 MX2-1 MX1-26 EG1-7 MX2-2 EG2-2EG2-3 HG1-21 BL1-1 HG2-13 HG1-22HG1-23 HG3-5 Outer North West
Otley and Yeadon
Adel and Wharfedale BL1-2 HG1-1 BL1-6 HG2-1 HG1-2 EG1-72HG1-3 Aireborough HG1-4 HG2-2 EG1-1 Guiseley and Rawdon Leeds City Council Wards HG1-7 BL1-7 EO1-1 HG1-6 EG3 Housing Market Characteristic Areas HG1-5 EO1-41 North Pennine Moors (SAC/SPA) EG1-3 South Pennine Moors (SAC/SPA) HG1-8 North Pennine Moors (SAC/SPA) - 7km buffer HG2-8 South Pennine Moors (SAC/SPA) - 7km buffer HG2-6 HG2-9 HG2-7 BL1 - Broad Location BL1-8 EO1 - Identified office employment HG2-4 HG1-9 EO2 - Office allocation HG2-229 EG1 - Identified general employment EG1-4 EG2 - General employment allocation HG1 - Identified housing BL1-9 HG1-11 HG2-29 HG2 - Housing allocation HG1-12 k k k HG1-10 MX1 - Identified mixed use EO1-2 HG1-58 k k k k k kMX2 - Mixed use allocation GGGGHG3 - Safeguarded land GGGG HG1-13 HG1-14 Strategic Green Infrastructure Hawksworth Woods & Moor The Wharfe Valley and Chevin Ridge North Leeds HG2-11 Horsforth The Aire Valley HG2-37 HG1-65 Weetwood © Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 19/11/2018 BL1-10 HG1-64HG1-66
Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 6.mxd Created by: NF Plan 7 - European Designations and Leeds Site Allocations Proposals in relation to Accessible Natural Greenspace
Accessible Natural Greenspace
1 Fulford Grange Meadow 2 Burras Drive (adjacent to allotments) 3 3 Newall Carr Road 4 Westbourne House Woodland 5 Gallows Hill Nature Reserve 5 13 6 Otley Bypass (Adjacent to) 7 Rawdon Littlemoor Primary School 8 Hawksworth Wood (Guiseley) 9 Otley Chevin Country Park 10 Little Moor 16 11 Orchard Hill 4 2 12 Yeadon Banks 146 13 Knotford Nook Outer North West 14 Westbourne Close woodland. 18 15 Cairn Garth 16 Ilkley Road Verge 9 17 Cragg Wood North 18 Old Railway Off Otley Road 19 Springwood Road (Rear of)
Otley and Yeadon
Adel and Wharfedale
15 Aireborough Guiseley and Rawdon
8 12
Leeds City Council Wards Housing Market Characteristic Areas North Pennine Moors (SAC/SPA) South Pennine Moors (SAC/SPA) North Pennine Moors (SAC/SPA) - 7km buffer South Pennine Moors (SAC/SPA) - 7km buffer BL1 - Broad Location EO1 - Identified office employment 7 EO2 - Office allocation 10 EG1 - Identified general employment EG2 - General employment allocation North Leeds HG1 - Identified housing 191 k k kHG2 - Housing allocation k k kMX1 - Identified mixed use Weetwood MX2 - Mixed use allocation kGGGG k k GGGGHG3 - Safeguarded land 11 kGGGG k k 17 Accessible Natural Greespace Horsforth Outer West © Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 19/11/2018 Calverley and Farsley
Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 7.mxd Created by: NF 5.20 The 40sqm/dwelling requirement is expected to deliver 2.5ha of new green space from the proposed allocations within the 7km zone. Green space is expected to be publicly accessible, and the most commonly favoured typology of green space is “Amenity” which allows for a range of outdoor activities including strolling, sitting, playing, dog walking etc. Further, it is reasonably concluded that provision of any additional new on-site green space (regardless of typology) will have a role to some degree in providing a recreational experience and therefore make a small additional contribution to deflecting visitors from the South Pennine Moors Phase 2 SPA/SAC.
Site Site Name Dwelling Green Ref Capacity Space HG2-1 New Birks Farm 160 6400 HG2-2 Wills Gill 133 5320 HG2-4 Hollins Hill 80 3200 HG2-6 Silverdale Av 32 1280 Swaine Hill HG2-7 Terrace 7 01 HG2-8 Kirkland House 17 680 HG2-9 Victoria Av 102 4080 HG2-13 White Croft Garth 16 640 HG2-229 Old Mill Miry Lane 15 600 MX2-1 Ashfield Works 50 2000 MX2-2 Westgate 15 600 Total 627 24800
5.21 Plan 8 shows all the accessible natural green space together with the Chevin Forest Park and North West Leeds Country Park & Green Gateways project in relation to proposed site allocations. This shows that there is a substantial network of green space resource infrastructure (predominantly of a natural typology) and much of it is in close proximity to the new housing sites. 5.22 On the basis of previous assessment and agreement with Natural England (July/August 2015) it can be reasonably assumed that the Chevin Forest Park due to its size and location in relation to the new allocations when compared to the South Pennine Moors Phase 2 SPA/SAC would, like existing properties in that similar location, be the preferred destination for recreational visits. This is further supported when the nature of the road network is considered, which provide better and more direct access to the Chevin Forest Park than the Hawksworth Moor part of the South Pennine Moors Phase 2 SPA/SAC. 5.23 It is considered that the above existing measures will reduce, to an acceptable level, the number of recreational visits to the South Pennine Moors Phase 2 SPA/SAC arising from the SAP. This is a conclusion agreed by Natural England in their response dated 20th August 2015 (see Appendix 9) and given the reduction in housing allocations now proposed by the SAP this conclusion still applies. This will avoid any of the impacts on Site Integrity (stated in para. 5.8) from occurring.
1 Developments of less than 10 dwellings are exempt from the provisions of Policy G4
27 of 71 HG1-15 Plan 8 - European Designations and Leeds Site Allocations Proposals HG1-16 in relation to Accessible Natural Greenspace & other projects HG1-17
MX1-1 HG1-18 HG1-19 MX2-1HG1-20 MX1-26 EG1-7 MX2-2 EG2-2EG2-3 HG1-21 BL1-1 Outer North West HG2-13 HG1-22HG1-23 HG3-5
Chevin Forest Park Local Nature Reserve
Otley and Yeadon BL1-3
HG1-25 Adel and Wharfedale BL1-2 HG2-17 HG1-1 BL1-6 HG2-1 HG1-2 EG1-72HG1-3 Aireborough HG1-4 EG1-1 Guiseley and Rawdon HG2-2 HG1-7 BL1-7 EO1-1 HG1-6 EG3 HG1-5 EO1-41 EG1-3 HG1-8 HG2-8 HG2-6 HG2-9 HG2-7 BL1-8 HG2-4 HG1-9 HG2-229 Leeds City Council Wards EG1-4 Housing Market Characteristic Areas North Pennine Moors (SAC/SPA) BL1-9 HG1-11 HG2-29 South Pennine Moors (SAC/SPA) HG1-12 HG1-10 HG2-30 North Pennine Moors (SAC/SPA) - 7km buffer EO1-2 HG1-58 South Pennine Moors (SAC/SPA) - 7km buffer BL1 - Broad Location HG1-13HG1-14 HG2-31 HG2-33 EO1 - Identified office employment HG2-32 EO2 - Office allocation EG1 - Identified general employment HG2-11 HG2-37 EG2 - General employment allocation HG1-65 HG1 - Identified housing HG1-64HG1-66 Weetwood HG2 - Housing allocation k k k BL1-10 HG1-70 MX1 - Identified mixed use k k k EG1-5 North Leeds MX2 - Mixed use allocation Horsforth HG1-67 HG1-68 k k k BL1-11 EO1-4 GGGGHG3 - Safeguarded land GGGG BL1-12 BL1-13 GGGGAccessible Natural Green Space HG1-69 MX1-2 North West Leeds Country Park and Green Gateways Project HG1-85 !! North West Leeds Country Park & Green Gateway Trail HG1-84 Kirkstall Outer West BL1-14 HG1-500EO1-5 HG1-87 © Crown copyright and database rights 2018 Ordnance Survey 100019567 Date: 16/11/2018 HG1-130HG2-53 Calverley and Farsley HG1-96HG1-97 HG2-42HG1-100 HG1-86 Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Plan 8.mxd Created by: NF 5.24 As there are no adverse impacts on Site Integrity identified (see Appendix 3) there are no new mitigation measures required and therefore no Main Modifications proposed in response to this HRA.
5.25 Having regard to the judgment in People over Wind (referred to in para. 1.6) it is confirmed that the impact of visits and the existing measures are amongst the matters that the Council has also had regard to as part of this Appropriate Assessment in order to reinforce what is already a comprehensive assessment of the measures that may be required to ensure there are no adverse impacts on the integrity of any European site.
5.26 This Appropriate Assessment has had regard to the preparation and status of development plans from the neighbouring authority of Bradford City Council in relation to the LSEs identified and considered in para. 4.5 (see Appendix 6).
5.27 Through duty to cooperate mechanisms and consultation with the West Yorkshire Combined Authority (WYCA), the City Council will continue to work collaboratively with neighbouring authorities including Bradford City Council as a basis to address any strategic or localised ‘cross boundary’ issues.
28 of 71 6. Conclusion
6.1 As outlined above, the preparation of the SAP is set within the context of the adopted Core Strategy and the targets identified for the overall scale and distribution of growth across the District. As noted above, the Core Strategy was subject to a Habitats Regulation Assessment Screening and a number of Policies were strengthened (e.g. Spatial Policy 1: Location of Development) as a consequence of this process. The focus of these changes was to strengthen the balance between the need to plan for housing and economic growth, whilst ensure that there are no adverse impacts arising from this in relation to Special Protection Areas (SPAs) and Special Areas of Conservation. (SACs). The SAP needs to be in conformity with the Core Strategy and as a consequence, will need to reflect the policy requirements set out. Within this overall context Core Strategy Policies G1, G2, G3, G4, G6 G8 and G9, provide a comprehensive framework to protect, enhance Green space, Green Infrastructure and Biodiversity across the District. A key focus of these Policies is to require improvements to existing and/or new Green space provision as an integral component of development proposals. The use of both on site and off site green space enhancement and provision (via the Section 106 Agreements and as appropriate the use of CIL monies) help to implement these Policies.
6.2 Consistent with the HRA Screening an Appropriate Assessment has been undertaken. This HRA has focused upon the consideration of identified potential recreational LSEs in relation to Conservation Objectives and how these can be addressed. This consideration is based upon existing measures Leeds City Council has in place to maintain and enhance accessible green space within Leeds MD, specifically the positive management of the Chevin Forest Park (which also has Green flag status) and the North West Leeds Country Park & Green Gateways project. These are extensive and comprehensive initiatives which are maintaining and enhancing networks of green space and green infrastructure for the benefit of local communities. Through partnership working, these projects include the provision of countryside walking trails and interpretation facilities – to help enhance these resources as positive experiences for recreation.
6.3 These existing measures serve to conclude that there are adequate recreational opportunities provided by existing green space in North West Leeds to reduce any recreational impacts on the Site Integrity of the South Pennine Moors Phase 2 SPA/SAC to an acceptable level (in helping to divert and deflect recreation visits away from more sensitive areas) and therefore will not result in any adverse impacts on the Site Integrity of the South Pennine Moors Phase 2 SPA/SAC alone or in- combination. Consequently, the SAP will not adversely affect the site integrity of SPAs and SACs and because of this no modification to the SAP or other measures are considered necessary.
29 of 71 APPENDIX 1: EUROPEAN DESIGNATIONS, CONSERVATION OBJECTIVES & QUALIFYING FEATURES WHICH RELATE TO SITES
European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA SPECIAL PROTECTION AREAS (SPA)
*also a Ramsar Site SOUTH PENNINE Ensure that the integrity of Partly within the Falco columbarius; Merlin (Breeding) MOORS PHASE the site is maintained or Leeds MD Boundary, Pluvialis apricaria; European golden plover (Breeding) 2 restored as appropriate, and north eastern corner Breeding bird assemblage – Golden Plover; Lapwing; Dunlin; Snipe; Curlew; Redshank; at Ilkley Moor ensure that the site Common Sandpiper; Short-eared Owl; Whinchat; Wheatear; Ring Ouzel; Twite. contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring;
• The extent and distribution of the habitats of the qualifying features • The structure and function of the habitats of the qualifying features • The supporting processes on which the habitats of the qualifying features rely • The population of each of the qualifying features, and,
30 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA • The distribution of the qualifying features within the site. NORTH Ensure that the integrity of Over 3km north west Circus cyaneus; Hen harrier (Breeding) PENNINE the site is maintained or of Leeds Falco columbarius; Merlin (Breeding) MOORS restored as appropriate, and Falco peregrinus; Peregrine falcon (Breeding) ensure that the site Pluvialis apricaria; European golden plover (Breeding) contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring: • The extent and distribution of the habitats of the qualifying features • The structure and function of the habitats of the qualifying features • The supporting processes on which the habitats of the qualifying features rely • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site.
*HUMBER Ensure that the integrity of Approx. 26.5 km east Botaurus stellaris; Great bittern (Non-breeding) ESTUARY the site is maintained or of Leeds, Botaurus stellaris; Great bittern (Breeding) restored as appropriate, and downstream of the Tadorna tadorna; Common shelduck (Non-breeding)
31 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA ensure that the site River Aire and River Circus aeruginosus; Eurasian marsh harrier (Breeding) contributes to achieving the Wharfe Circus cyaneus; Hen harrier (Non-breeding) aims of the Wild Birds Recurvirostra avosetta; Pied avocet (Non-breeding) Directive, by maintaining or Recurvirostra avosetta; Pied avocet (Breeding) restoring; Pluvialis apricaria; European golden plover (Non-breeding) • The extent and Calidris canutus; Red knot (Non-breeding) distribution of the Calidris alpina alpina; Dunlin (Non-breeding) habitats of the qualifying Philomachus pugnax; Ruff (Non-breeding) features Limosa limosa islandica; Black-tailed godwit (Non-breeding) • The structure and Limosa lapponica; Bar-tailed godwit (Non-breeding) function of the habitats of Tringa totanus; Common redshank (Non-breeding) the qualifying features Sterna albifrons; Little tern (Breeding) • The supporting Waterbird assemblage - in the non-breeding season, the area regularly supports 153,934 processes on which the individual waterbirds (five year peak mean 1996/97 – 2000/01), including dark-bellied habitats of the qualifying brent goose Branta bernicla bernicla, shelduck Tadorna tadorna, wigeon Anas penelope, features rely teal Anas crecca, mallard Anas • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site. SPECIAL AREAS OF CONSERVATION (SAC)
NORTH Ensure that the integrity of Over 3km north west Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath PENNINE the site is maintained or of Leeds European dry heaths MOORS restored as appropriate, and Juniperus communis formations on heaths or calcareous grasslands; Juniper on heaths ensure that the site or calcareous grasslands contributes to achieving the Calaminarian grasslands of the Violetalia calaminariae; Grasslands on soils rich in heavy Favourable Conservation metals Status of its Qualifying Siliceous alpine and boreal grasslands; Montane acid grasslands
32 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA Features, by maintaining or Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco- restoring; Brometalia); Dry grasslands and scrublands on chalk or limestone • The extent and Blanket bogs distribution of qualifying Petrifying springs with tufa formation (Cratoneurion); Hard-water springs depositing lime natural habitats and Alkaline fens; Calcium-rich springwater-fed fens habitats of qualifying species Siliceous scree of the montane to snow levels (Androsacetalia alpinae and Galeopsietalia • The structure and ladani); Acidic scree function (including typical Calcareous rocky slopes with chasmophytic vegetation; Plants in crevices in base-rich species) of qualifying rocks natural habitats Siliceous rocky slopes with chasmophytic vegetation; Plants in crevices on acid rocks • The structure and Old sessile oak woods with Ilex and Blechnum in the British Isles; Western acidic oak function of the habitats of woodland qualifying species Saxifraga hirculus; Marsh saxifrage • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely • The populations of qualifying species, and, • The distribution of qualifying species within the site. KIRK DEIGHTON Ensure that the integrity of Approx. 500 m north Triturus cristatus; Great crested newt the site is maintained or of Leeds (north east restored as appropriate, and corner) ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying
33 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA Features, by maintaining or restoring;
• The extent and distribution of the habitats of qualifying species • The structure and function of the habitats of qualifying species • The supporting processes on which the habitats of qualifying species rely • The populations of qualifying species, and, • The distribution of qualifying species within the site. SOUTH PENNINE Ensure that the integrity of Within the Leeds MD Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath MOORS the site is maintained or Boundary, north European dry heaths restored as appropriate, and eastern-most corner Blanket bogs* ensure that the site at Hawksworth Moor Transition mires and quaking bogs; Very wet mires often identified by an unstable contributes to achieving the `quaking` surface Favourable Conservation Old sessile oak woods with Ilex and Blechnum in the British Isles Status of its Qualifying Features, by maintaining or restoring; • The extent and distribution of the qualifying natural habitats
34 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA • The structure and function (including typical species) of the qualifying natural habitats, and, • The supporting processes on which the qualifying natural habitats rely DENBY GRANGE Ensure that the integrity of Approx. 7 km to the Triturus cristatus; Great crested newt COLLIERY the site is maintained or south of the Leeds PONDS restored as appropriate, and District boundary. ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring; • The extent and distribution of the habitats of qualifying species • The structure and function of habitats of qualifying species • The supporting processes on which qualifying natural habitats rely • The populations of qualifying species, and,
35 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA • The distribution of qualifying species within the site. *HUMBER Ensure that the integrity of Approx. 26.5 km east Sandbanks which are slightly covered by sea water all the time; Subtidal sandbanks ESTUARY the site is maintained or of Leeds, Estuaries restored as appropriate, and downstream of the Mudflats and sandflats not covered by seawater at low tide; Intertidal mudflats and ensure that the site River Aire and River sandflats Wharfe contributes to achieving the Coastal lagoons Favourable Conservation Salicornia and other annuals colonising mud and sand; Glasswort and other annuals Status of its Qualifying colonising mud and sand Features, by maintaining or Atlantic salt meadows (Glauco-Puccinellietalia maritimae) restoring; Embryonic shifting dunes • The extent and distribution of qualifying Shifting dunes along the shoreline with Ammophila arenaria ("white dunes"); Shifting natural habitats and dunes with marram habitats of qualifying species Fixed dunes with herbaceous vegetation ("grey dunes"); Dune grassland • The structure and Dunes with Hippophae rhamnoides; Dunes with sea-buckthorn function (including typical Petromyzon marinus; Sea lamprey species) of qualifying Lampetra fluviatilis; River lamprey natural habitats Halichoerus grypus; Grey seal • The structure and function of the habitats of qualifying species • The supporting processes on which qualifying natural habitats and habitats of qualifying species rely • The populations of qualifying species, and,
36 of 71 European Site National (SSSI) and Location Relative Qualifying Features European Conservation to Leeds Objectives for Each SAC/SPA • The distribution of qualifying species within the site.
37 of 71 Kirk Deighton Special Area of Conservation (SAC) - Site Improvement Plan
Priority and issue Action No. Action Wording
Change in Land management 1A Restoration of the over-mature hedgerows within the SAC to improve commuting, hibernation, resting and foraging habitat for Great crested newts.
1B Aim to protect (through the planning process) terrestrial habitat and ponds outwith the SAC which are considered likely to support the metapopulation of Great crested newts linked to the SAC. Habitat Fragmentation 2A Conduct a survey to identify great crested newt breeding/feeding ponds outwith the SAC which are likely to support newts from the SAC's metapopulation. This will add to our understanding of the habitat requirements of the SAC great crested newt population
Once the metapopulation investigation data is available consider the 2B need for new pond/s, suitable for breeding great crested newts, within the SAC, working with the Environment Agency who will act in an advisory role.
38 of 71 APPENDIX 2: SCREENING STAGE ASSESSMENT
European Potential Likely Significant Effect (LSE) to consider Environmental Consideration Does it Site Taken from: give rise to • Core Strategy HRA Screening Determination (previously approved by potential NE) LSE? • NE letter dated 11 May 2015 • Bradford MDC Core Strategy and Waste Management DPD HRA Screening • Site Improvement Plan for Kirk Deighton SAC South Pennine Moors SPA (Phase 2)
Loss of land providing feeding sites for qualifying bird species and bird No proposed site allocations within No assemblage within 2.5km of SPA boundary. 2.5km. Predation by pets on qualifying bird species and bird assemblage and No proposed site allocations within No their nests. 2.5km. Recreational impacts through increased disturbance to qualifying bird Site allocations are proposed within Yes species and bird assemblage (see Appendix 1 Column 4) from increased 7km of the SPA boundary and visitor numbers to the SPA resulting from any allocations within 7km of existing road infrastructure the SPA boundary connectivity exists therefore there may be an LSE through the following recreational impacts: disturbance to ground-nesting birds; disturbance of feeding birds; and degradation of supporting habitat. North Pennine Moors SPA Loss of land providing feeding sites for qualifying bird species and bird No proposed allocations within No assemblage within 2.5km of SPA boundary 2.5km. Predation by pets on qualifying bird species and bird assemblage and No proposed allocations within No their nests. 2.5km.
39 of 71 European Potential Likely Significant Effect (LSE) to consider Environmental Consideration Does it Site Taken from: give rise to • Core Strategy HRA Screening Determination (previously approved by potential NE) LSE? • NE letter dated 11 May 2015 • Bradford MDC Core Strategy and Waste Management DPD HRA Screening • Site Improvement Plan for Kirk Deighton SAC Recreational impacts through increased disturbance to qualifying bird Distance of over 5km from site No species and bird assemblage from increased visitor numbers to the SPA boundary for any housing allocations resulting from any allocations. together with poor existing road infrastructure connectivity in direction of SPA site from any proposed allocations. Humber Estuary SPA Loss of land providing feeding sites for qualifying bird species and bird The River Aire and Wharfe is No assemblage in close proximity of SPA boundary. connected to the Humber Estuary but the site is 26.5km to the east of Leeds. Recreational impacts through increased disturbance to qualifying bird The site is 26.5km to the east of No species and bird assemblage from increased visitor numbers to the SPA. Leeds.
South Pennine Moors SAC Recreational impacts through increased disturbance to qualifying habitats Allocations are proposed within 7km Yes (see Appendix 1 Column 4) from increased visitor numbers to the SAC of the SAC boundary and therefore resulting from any allocations within 7km of the SAC boundary there may be adverse impacts through habitat degradation. Increased acid and nitrogen deposition from industrial sites giving rise to Distance of over 2.5km from site No emissions boundary for housing and employment allocations - no roads within 200metres of SAC affected by proposed allocations.
North Pennine Moors SAC
40 of 71 European Potential Likely Significant Effect (LSE) to consider Environmental Consideration Does it Site Taken from: give rise to • Core Strategy HRA Screening Determination (previously approved by potential NE) LSE? • NE letter dated 11 May 2015 • Bradford MDC Core Strategy and Waste Management DPD HRA Screening • Site Improvement Plan for Kirk Deighton SAC Recreational impacts through increased disturbance to qualifying habitats Distance of over 5km from SAC No from increased visitor numbers to the SAC boundary for housing allocations - together with poor existing road infrastructure connectivity in direction of SAC site from any proposed allocations.
Increased acid and nitrogen deposition from transport or industrial sites Distance of over 5km from site No giving rise to emissions boundary for housing and employment allocations - no roads within 200metres of SAC affected by proposed allocations. Kirk Deighton SAC Change in land management within the site Not affected. No Habitat fragmentation caused by loss of ponds and terrestrial habitat Nearest allocation in Leeds is No used by GCN metapopulation outside the site (within 500m of site 1.01km from SAC boundary and boundary). therefore it is reasonable to assume no impact on the metapopulation. A precautionary check of GCN records has not revealed any GCN between SAC boundary and any proposed allocations in Leeds (north and north-west of Wetherby). Habitat suitability of land between SAC and nearest two proposed allocations has revealed sub-optimal habitat and a number of main roads as
41 of 71 European Potential Likely Significant Effect (LSE) to consider Environmental Consideration Does it Site Taken from: give rise to • Core Strategy HRA Screening Determination (previously approved by potential NE) LSE? • NE letter dated 11 May 2015 • Bradford MDC Core Strategy and Waste Management DPD HRA Screening • Site Improvement Plan for Kirk Deighton SAC obstructions to expand the metapopulation.
Increased water abstraction from new dwellings or economic Distance of 1.01km from nearest site No development. boundary and lack of hydrological connectivity to any proposed allocations.
Increased acid and nitrogen deposition from transport or industrial sites Distance of 1.01km from nearest site No giving rise to emissions boundary for housing and further for employment allocations - no roads within 200metres of SAC affected by proposed allocations (see Appendix 11). Denby Grange Colliery Ponds SAC
Change in land management within the site Not affected. No Habitat fragmentation caused by loss of ponds and terrestrial habitat Not affected. No used by GCN metapopulation outside the site (within 500m of site boundary). Increased water abstraction from new dwellings or economic Distance of 7km from Leeds No development. boundary and lack of hydrological connectivity to any proposed allocations.
Increased acid and nitrogen deposition from transport or industrial sites Distance of 7km from Leeds No giving rise to emissions boundary - no roads within
42 of 71 European Potential Likely Significant Effect (LSE) to consider Environmental Consideration Does it Site Taken from: give rise to • Core Strategy HRA Screening Determination (previously approved by potential NE) LSE? • NE letter dated 11 May 2015 • Bradford MDC Core Strategy and Waste Management DPD HRA Screening • Site Improvement Plan for Kirk Deighton SAC 200metres of SAC affected by proposed allocations.
Humber Estuary SAC Increased water abstraction from new dwellings or economic Reduction in volume of freshwater No development. reaching Humber Estuary. The site is 26.5km to the east of Leeds. Increased waste water production from new dwellings or economic Decrease in water quality of No development. freshwater reaching Humber Estuary. The site is 26.5km to the east of Leeds. Additional barriers to fish movement. Barriers to River Lamprey moving No up-river from Humber Estuary. There are no records of River Lamprey in Leeds waterways connected with the River Aire.
No new barriers to fish movement proposed.
43 of 71 APPENDIX 3: ASSESSMENT OF IMPACTS ON SITE INTEGRITY
South Pennine Moors Phase 2 SPA
Conservation Potential impact on Are there measures that will Will there be Objectives Site Integrity as reduce, to an acceptable an impact in identified in level, the number of Site Integrity? To maintain or Appendix 2 recreational visits to the restore the: Screening Stage South Pennine Moors Phase 2 SPA/SAC arising from the SAP? Extent and No distribution of the Yes – the existence and habitats of the There is potential for continued enhancement of qualifying features additional the green spaces provided Structure and recreational by Chevin Forest Park LNR No function of the pressure having and the North West Leeds habitats of the adverse effects on Country Park & Green qualifying features the Gateways project, together Supporting populations of Annex with Core Strategy policies No processes on 1 (Golden Plover SP13, G1, G3 and G4 have which the habitats and Merlin) and the capacity to reduce of the qualifying regularly occurring recreational visits to the features rely migratory birds South Pennine Moors Phase Populations of the (assemblage of 2 SPA to acceptable levels No qualifying features breeding birds) Distribution of the within the South No qualifying features Pennine Moors within the site Phase 2 SPA in relation to all these Conservation Objectives
South Pennine Moors SAC
Conservation Potential impact on Are there measures that will Will there be Objectives Site Integrity as reduce, to an acceptable an impact in identified in level, the number of Site To maintain or Appendix 2 recreational visits to the Integrity? restore the: Screening Stage South Pennine Moors Phase 2 SPA/SAC arising from the SAP?
Extent and No distribution of the Yes – the existence and qualifying natural There is potential for continued enhancement of habitats additional the green spaces provided recreational by Chevin Forest Park LNR
44 of 71 Structure and pressure having and the North West Leeds No function of the adverse effects Country Park & Green qualifying natural through disturbance Gateways project, together Habitats to qualifying habitats with Core Strategy policies of the South Pennine SP13, G1, G3 and G4 have Supporting Moors SAC in the capacity to reduce No processes on relation to all these recreational visits to the which the Conservation South Pennine Moors Phase qualifying natural Objectives 2 SPA/SAC to acceptable habitats rely levels
45 of 71 APPENDIX 4: LEEDS CITY COUNCIL, PARKS & COUNTRYSIDE SERVICE POSITIVE MANAGEMENT OF GREEN SPACE IN NORTH WEST LEEDS Existing Natural Green space Provision in Aireborough
LCC’s Parks & Countryside Section positively manages a network of green space sites in North West Leeds all of which are promoted to encourage public access. These sites are a mixture of typologies and sizes but are managed to provide a high quality visitor experience (individual site assessments of all Parks & Countryside parks in line with Green Flag scoring have taken place annually since 2005 to ensure improvements are taking place). Where a site meets the nationally recognised Green Flag Criteria it is classed as a Leeds Quality Park. A “Parks & Green space Strategy for Leeds” has been produced in 2008 and can be seen at http://www.leeds.gov.uk/docs/Small%20PGS%20strategy%5B2%5D.pdf Page 32 of this Strategy shows Community Parks in blue and other sites in red that have met Green Flag scoring criteria – such sites in North-West Leeds include Yeadon Tarnfield Park, Rawdon Micklefield Park, Horsforth Hall Park, Guiseley Nunroyd Park and Otley Chevin Forest Park. These Community Parks and Leeds Quality Parks or Green Flag sites all provide a locally significant catchment for visitors across the urbanised areas of Guiseley, Rawdon, Yeadon, Horsforth and Otley.
In relation to providing natural green space close to the proposed allocation sites and existing residential population of North West Leeds the most significant Parks & Countryside site is a Local Nature Reserve that is on the boundary of the Aireborough and Outer North- West HMCAs – Otley Chevin Forest Park. This site provides a park of natural green space for dog walkers and other recreational activities that is of a similar level of attractiveness to Ilkley Moor and Hawksworth Moor in terms of a relatively remote natural setting for visitors.
Otley Chevin Forest Park (the Chevin) This Local Nature Reserve has been publicly accessible since the 1950s. Since 1950 it has increased in size due to LCC purchasing additional portions of land to the 180ha. available today. The Chevin is very popular with a wide range of recreational users because it has very good free access by car (including 5 car parks), public transport and an extensive network of paths. There is a visitor centre and café available at the White House buildings. Parks & Countryside manage The Chevin specifically for people and wildlife to co-exist side- by-side a Management/Action Plan is attached as Appendix 5 to this document/available to view at http://chevinforest.co.uk/uploads/pdfs/Downloads/Management%20Plan.pdf
Page 167 of this has an Aim “To Provide Suitable Opportunities For A Range of Visitors” and a number of Objectives to achieve this Aim. There is a section which summarises visitor survey results (Page 133). Parks & Countryside carried out a Residents Survey across Leeds to understand which parks Leeds residents visit of why – this was done for three consecutive years between 2004 and 2006 (30 000 random questionnaires sent every year). Specific comments that relate to The Chevin are included on Page 134 and 135 of the
46 of 71 Management Plan. From this visitor survey it is estimated that The Chevin has 480 000 visitors per year. A significant proportion of management resources are dedicated to keeping the site clean and attractive to visit, with numerous dog bins and information on the wildlife that is present.
From various surveys and from communication with the Estate Manager of The Chevin between 2009 and 2012 it seems clear that The Chevin attracts local people from the catchment area of Yeadon, Rawdon, Guiseley and Otley. One survey from 1983 reveals out of 216 visitors: 166 came from within the district of Leeds; 36 from the district of Bradford; and 14 from over 20 miles away. A more recent analysis of the Parks & Countryside Leeds
47 of 71 Residents Survey in 2005 indicates that 60% of visitors arrive at The Chevin by car, and that most visitors come from within 10km – see below screenshot from this survey:
Data from the 2005 Leeds Residents Surveys is available to understand why Leeds residents visit the Chevin rather than their nearest park – this data is available on request. As well as a Management Plan, Parks & Countryside also have a detailed Service Improvement Plan for the Chevin – an example from 2008 is available upon request. Below is an extract from this Service Plan:
The above survey information and commitment to manage the Chevin to a high quality leads to the conclusion that Otley Chevin Forest Park has a wide enough catchment to attract people for a natural green space experience from the Otley, Guiseley, Yeadon, Rawdon and Horsforth area on a regular basis.
According to the Estate Manager of the Chevin between 2009 and 2012 the Chevin is capable of receiving a relatively high number of visitors from nearby urban areas and although there are wildlife habitats and species of a sensitive nature it is more desirable to allow low level damage to these features at the Chevin than the more sensitive habitats of a European nature at Ilkley Moor and Hawksworth Moor.
North West Leeds Country Park and Green Gateways Project
In addition to the level of recreational provision at Otley Chevin Forest Park, Parks & Countryside also have a North-West Leeds Country Park and Green Gateways Project http://www.leeds.gov.uk/leisure/Pages/country-parks-and-green-gateways.aspx
48 of 71 This initiative promotes the green spaces in north and north-west Leeds and links these through a recreational path network. It should be emphasised that none of these sites or paths directs users to Hawksworth Moor, instead it is focussed on a circular trail route from the City Centre of Leeds along the Meanwood Valley and across the Chevin before connecting southwards to Rawdon, Yeadon, Guiseley and Rodley before returning to the City Centre (as part of a wider integrated network of Green Infrastructure, within Leeds MD – see the following Plan).
The promoted route for the North West Leeds Country Park and Green Gateways Trail is shown above in pink (note the paths joining with Hawksworth Moor are the existing definitive or permissive ones). This Project will actively promote the existing green spaces owned and managed by Leeds City Council in Otley, Yeadon, Rawdon, Guiseley and Horsforth and how they link together, it will not be promoting Hawksworth Moor as it is not owned or managed by Leeds City Council.
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50 of 71 APPENDIX 5: LEEDS CITY COUNCIL, PARKS & COUNTRYSIDE SERVICE - CHEVIN FOREST PARK ACTION PLAN (EXTRACT)
Extract from Chevin Forest Park Management Plan showing Aim and Objectives in relation to “Recreational Use Of The Site” (other Aims and Objectives exist for other issues such as “Biodiversity”, “Local Community Involvement”, “Marketing” etc.).
The full Management Plan can be viewed at: http://chevinforest.co.uk/uploads/pdfs/Downloads/Management%20Plan.pdf
51 of 71 APPENDIX 6: ASSESSMENT OF LIKELY SIGNIFICANT EFFECTS (LSEs) IN-COMBINATION
EUROPEAN Identified Likely Relevant Plans, Strategies In Combination Effect -after consideration of SITE Significant Effect (LSE) etc. (other than Leeds) Relevant Plans, Strategies etc. (other than Leeds) will a LSE occur? South Pennine Recreational impacts Bradford City Council Core No – Bradford have put measures in place through their Moors SPA through increased Strategy Appropriate Assessment and Leeds City Council have (Phase 2) disturbance to qualifying measures in place through provision of accessible bird species and bird natural green space and positive assemblage from management/promotion of natural green space sites increased visitor numbers closer to any relevant allocated sites in Leeds to the SPA resulting from any allocations within 7km of the SPA boundary
South Pennine Moors SAC Recreational impacts Bradford City Council Core No - Bradford have put measures in place through their through increased Strategy Appropriate Assessment and Leeds City Council have disturbance to qualifying measures in place through provision of accessible habitats from increased natural green space and positive visitor numbers to the SAC management/promotion of natural green space sites resulting from any closer to any relevant allocated sites in Leeds allocations within 7km of the SAC boundary
52 of 71 APPENDIX 7: VISITOR SURVEY 2013 - SIGNIFICANT OVERLAPPING POSTAL DISTRICTS
LS29 Postal District
The LS29 postcode District contains very few properties in Leeds and the only main area of housing is the former Highroyds Hospital comprising around 500 units to the north east of Guiseley. The remainder of the area contains the settlements of Ilkley, Addingham, Menston and Burley in Wharefdale. Visitors from this postcode are not included in the Leeds figures.
LS21 Postal District
The LS21 postcode District stretches significantly into Bradford and Harrogate Districts. However, for the purposes of the analysis and given that Otley and Pool – in-Wharefdale are within this postal district all returns for LS21 have been counted towards the Leeds figures.
53 of 71 APPENDIX 8: VISITOR SURVEY 2013 - POSTCODE SECTORS
54 of 71 APPENDIX 9: FORMAL RESPONSE FROM NATURAL ENGLAND CONFIRMING THE CAPACITY OF THE CHEVIN FIREST PARK AND OTHER GREEN SPACES TO ABSORB ADDITIONAL RECREATIONAL USE ARISING FROM NEW ALLOCATIONS
Date: 20 August 2015 Our ref: 161748 Your ref:
David Feeney Head of Forward Planning & Implementation Customer Services City Development Hornbeam House Leeds City Council Crewe Business Park Electra Way [email protected] Crewe Cheshire CW1 6GJ BY EMAIL ONLY T 0300 060 3900 Dear David
Planning consultation: Habitats Regulations Assessment: Screening Determination for Leeds Site Allocations Plan and Aire Valley Leeds Area Action Plan (August 2015) Location: Leeds
Thank you for your consultation on the above dated 05 August 2015 which was received by Natural England on the same day.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Previous Advice
Within my email to you dated 15 July 2015 we welcomed the addition information regarding the Council’s green space and parks management programmes and the capacity of the Chevin to absorb increased levels of public use and intercept visitors who would otherwise use the South Pennine Moors Special Area of Conservation (SAC) and Special Protection Area (SPA).
We advised however that to determine whether the existing green spaces and management programmes would accommodate an increase in recreational use and therefore rule out likely significant effects (LSE), greater certainty regarding the likely increase in visitor numbers was required. This information could be obtained through the analysis of Rombalds/Ilkley Moor visitor data collected by Bradford City Council.
Habitats Regulations Assessment (August 2015)
The updated Habitats Regulations Assessment (HRA) contains additional paragraphs 5.3 to 5.7 and new appendices 6 and 7. Having reviewed the additional analysis of Leeds’ current contribution to recreational pressure on the South Pennine Moors (extracted from Bradford’s data) and the likely increase as a result of allocations within the 7km zone, Natural England is satisfied with the HRA’s conclusion that the open space improvement measures identified provide sufficient certainty that LSE alone and in combination will be avoided.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter only please contact John King on
Page 1 of 2
55 of 71 03000604129. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected].
We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service.
Yours sincerely
John King MRTPI Yorkshire and Northern Lincolnshire
Page 2 of 2
56 of 71 APPENDIX 10: REQUEST FROM NATURAL ENGLAND TO USE 2013 BRADFORD COUNCIL VISITOR SURVEY DATA & CONFIRMATION THAT LEEDS GREENSPACE QUALITY AND CAPACITY CAN DEFLECT VISITORS FROM SOUTH PENNINE MOORS PHASE2 SPA/SAC
From: Feeney, David [mailto:[email protected]] Sent: 05 August 2015 09:20 To: King, John J (NE) Cc: Ash, Merlin (NE); Marsh, Richard Subject: RE: Leeds Allocations and Area Action Plan HRA
Dear John
Further to your helpful reply below, please find attached a revised draft of the HRA Screening to reflect your further advice. These are covered in additional material in paras. 5.3 – 5.7 and new Appendix 6 and 7. Appendix 5 has also been updated to reflect your comments.
We are planning to commence our formal public consultation on 10th September, your urgent response by end of August at the latest) would therefore be appreciated. In the meantime, if you have any further questions please give me a ring or email.
Many thanks
David Feeney
Head of Forward Planning & Implementation
City Development
Leeds City Council
0113 2474539
From: King, John J (NE) [mailto:[email protected]] Sent: 15 July 2015 14:36 To: Feeney, David Cc: Ash, Merlin (NE) Subject: Leeds Allocations and Area Action Plan HRA
Dear David,
Both Merlin and I have reviewed the revised HRA (July 2015). Please accept this email as Natural England’s interim advice.
The HRA has been amended significantly and addresses many of our previous concerns as set out in our letter dated 11 May 2015 and discussed at the meeting on the 21 May 2015.
Natural England welcomes the additional information regarding the Council’s green space and parks management programmes in North West Leeds and the capacity of the Chevin to absorb existing levels of public use and further increases as a result of the allocations. As discussed the existence of these areas of
57 of 71 open space and the rights of way network provide opportunities to intercept visitors who would otherwise use the South Pennine Moors SPA/SAC for recreation.
In order to avoid LSE and avoid an appropriate assessment of adverse effects, greater certainty regarding likely visitor numbers to the SAC/SPA is required.
As advised the HRA should be supported by the visitor data collected by Bradford to determine what contribution residents of Leeds make to disturbance and trampling within the site. References to Bradford’s HRA are made, however discussions regarding numbers are absent. Without this data within the HRA, the judgement that the existing greenspace has capacity to deflect visitors away from the SPA and SAC are entirely subjective.
Alongside visitor numbers on the site, an analysis of those allocations within the 7km zone and the likely population increase would support a determination of LSE and establish whether the capacity of existing open spaces is sufficient. This was discussed at the meeting. If the population increase is low it would seem likely that the Chevin and other areas are likely to have sufficient capacity (provided improvement programmes are in place).
The in combination assessment would benefit from the above evidence, particularly the visitor data held by Bradford. The HRA appears to rely on Bradford’s own mitigation measures which address their contribution. Leeds cannot rely on Bradford’s measures as these address their effects, not Leeds. Leeds should rely on its own measures to avoid LSE in-combination.
If the HRA confidently determines that the avoidance measures can absorb the likely increase in visitors and no net additional visitors will be generated (current facilities and improvements will deflect existing as well as future residents resulting in no net increase) then in combination would be avoided.
In summary, whilst the HRA requires further evidence to support the assumptions already made, provided this evidence is included a determination of no LSE could be made.
Regards
John King Lead Adviser Sustainable Development and Marine
Yorkshire and Northern Lincolnshire Natural England 8 City Walk Leeds LS11 9AT
58 of 71 Appendix 11 - Distance from Kirk Deighton SAC to road network
HG2-19 HG2-226
HG1-28 HG1-34
418.13m
382 .5m
Leed MD Boundary Kirk Deighton SAC Kirk Deighton SAC 200m buffer Distance to road network Allocated for school Identified housing Housing allocation HG2-19
© Crown copyright and database rights 2016 Ordnance Survey 100019567 Date: 19/11/2018 Path: L:\CGM\Nazia Fazal\Projects\Richard Marsh\SAC_SAP 2018 Appendix 11.mxd Date: 19/11/2018
0 0.03 0.06 0.12 0.18 Miles APPENDIX 12: PARKS & COUNTRYSIDE SERVICE LEAFLET FOR NORTH WEST LEEDS COUNTRY PARK AND GREEN GATEWAY PROJECT
59 of 71
60 of 71
61 of 71 Appendix 2
Advice from Natural England
Comments on November 2018 SAP HRA & AA
From: Ash, Merlin (NE) [mailto:[email protected]] Sent: 27 November 2018 11:28 To: Marsh, Richard
Hi Richard,
Yes absolutely. We have considered examination documents EX35, EX35a and EX35b regarding the People over Wind judgement and your draft responses to the inspectors questions and have the following comments to make.
EX35, EX35a and EX35b
Natural England has commented previously on your approach to people over wind in our email dated 03 July 2018. Having considered the information in examination documents EX35 and EX35b we have no additional concerns or further detailed advice to give on this matter. However we have the following standard advice that you may wish to consider.
A recent judgment from the Court of Justice of the European Union (Case C-323/17 People over Wind v Coillte Ternate) has provided authoritative interpretation relating to the use of mitigation measures at the screening stage of a Habitats Regulations Assessment (‘HRA’) when deciding whether an appropriate assessment of a plan or project is required. The court concluded that measures intended to avoid or reduce the harmful effects of a plan or project on a European Site can only be considered as part of the appropriate assessment stage of HRA, and not at the preceding screening stage. This means that it is no longer appropriate to rely on these measures when deciding whether a plan or project is likely to have a significant effect on a European site(s).
In light of this judgment, Natural England advises that local plan-making authorities may wish to take legal advice on the implications of the judgment to fully understand whether any further assessment of, or changes to, their Plans are now required to ensure their compliance with the Conservation of Habitats & Species Regulations 2017.
We advise that, if reviewing a draft HRA of a Plan, plan-making authorities consider whether there are measures in the Plan that are intended to avoid or reduce the risk or the possibility of significant effects on European Sites that are being relied upon to rule out the need for an appropriate assessment. Where you consider this to be the case, we advise that an appropriate assessment should be undertaken to consider the impacts on the integrity of the European site(s), either alone or in-combination with other plans and projects, in view of the available advice about the site’s conservation objectives. However, when determining whether the plan will have an adverse effect on the integrity of the European site at the appropriate assessment stage, a competent authority may take account of those avoidance and mitigation measures. Natural England must be consulted on any appropriate assessment.
Plan-making authorities may also wish to consider the advice about this judgment currently provided by the Planning Inspectorate (PINS Note 05/2018), which recommends that, where planning cases are on-going and still being determined, any HRAs drafted which contain screening decisions that have taken into account mitigation measures should be re-examined and an appropriate assessment conducted where necessary.
Draft Response to Inspectors Questions: HRA Post-Hearing Note
62 of 71 Natural England welcomes the clarifications provided in your responses to the inspector’s questions regarding the Habitats Regulations Assessment. With regards to your response to question 4 we would add that the concept of providing suitable alternative natural greenspace, which doesn’t necessarily replicate the designated habitats, but provides more convenient alternatives to the services it provides, has been established in plans and projects associated with the Thames Basin Heaths Special Protection Area (SPA). For example Bracknell Forest Council’s approach including the Thames Basin Heath’s Supplementary Planning Document available on their website at: https://www.bracknell-forest.gov.uk/parks-and-countryside/suitable-alternative-natural-greenspaces
Concerning question 7 we are satisfied that the assessment has utilised the 200m threshold as set out in the Department for Transport’s Design Manual for Roads and Bridges. We advise that you should be aware that Harrogate Borough Council have recently undertaken some further assessment of traffic emission impacts on Kirk Deighton Special Area Conservation (SAC) from their Local Plan. However, provided that your traffic assessment is correct that the SAP does not impact on any roads within 200m of the European site, further assessment of the SAP will not be needed.
Finally regarding question 8 we advise that consultation with Yorkshire Water regarding waste water treatment capacity is also important regarding potential water quality impacts on the Humber Estuary SAC.
We hope this advice is helpful. If you have any further comments please do not hesitate to contact me.
Kind regards
Merlin
Merlin Ash
Lead Adviser
Yorkshire and Northern Lincolnshire Team
Natural England
Foss House, 1-2 Peasholme Green, York, YO1 7PX
Tel: 02080 266382
63 of 71 Comments on September 2018 SAP HRA & AA Date: 07 September 2018 Our ref: 256311
Robin Coghlan Leeds City Council Customer Services Merrion House Hornbeam House 110 Merrion Centre Crewe Business Park Electra Way Leeds LS2 8BB Crewe [email protected] Cheshire CW1 6GJ BY EMAIL ONLY T 0300 060 3900
Dear Robin Coghlan
Planning consultation: Leeds Site Allocations Plan – Revised Habitats Regulations Screening and Appropriate Assessment
Thank you for your consultation on the above dated 21 August 2018.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Natural England welcomes the updated Habitats Regulations Screening and Appropriate Assessment for the Leeds Site Allocations Plan which we broadly consider to satisfy the requirements of the Habitats Regulations1. However we have two minor points regarding the use of terminology which we advise that you consider.
Firstly we note that the assessment in section 5 and conclusions in section 6 should refer to ‘no adverse effect on integrity’ rather than ‘no likely significant effect’ (LSE) as per the conventions of an Appropriate Assessment under the Habitats Regulations1.
Based on the evidence provided Natural England is satisfied that the plan will not have any adverse effects on integrity, however in the context of the recent European Court of Justice ruling People over Wind v Coillte Teoranta (Case C-323/17), we would be concerned about a conclusion of no likely significant effects. We advise that the test of likely significant effects can be considered a more stringent test than adverse effects on integrity. Local Plans, unlike Neighbourhood Plans, can be assessed under Appropriate Assessment and are therefore not deemed un-compliant with the Habitats Regulations1 where there is a likely significant effect.
We note also your reference to reducing the level of recreational disturbance to ‘de minimus’ levels in para 5.9. In the context of Habitats Regulations1 case law we consider a determination of de minimus a very stringent level which may be hard to demonstrate. We advise that ‘acceptable levels’ may be a more appropriate term in this case and is likely to be less open to challenge.
Finally with regards to Case C-323/17 People Over Wind v Coillte Teoranta we welcome the consideration given to this judgement in the revised assessment and have the following general advice to give.
A recent judgment from the Court of Justice of the European Union (Case C-323/17 People Over Wind v Coillte Teoranta) has provided authoritative interpretation relating to the use of mitigation measures at the screening stage of a Habitats Regulations Assessment (‘HRA’)
1 Conservation of Habitats and Species Regulations 2017
64 of 71 when deciding whether an appropriate assessment of a plan or project is required. The court concluded that measures intended to avoid or reduce the harmful effects of a plan or project on a European Site can only be considered as part of the appropriate assessment stage of HRA, and not at the preceding screening stage. This means that it is no longer appropriate to rely on these measures when deciding whether a plan or project is likely to have a significant effect on a European site(s).
In light of this judgment, Natural England advises that local plan-making authorities may wish to take legal advice on the implications of the judgment to fully understand whether any further assessment of, or changes to, their Plans are now required to ensure their compliance with the Conservation of Habitats & Species Regulations 2017.
We advise that, if reviewing a draft HRA of a Plan, plan-making authorities consider whether there are measures in the Plan that are intended to avoid or reduce the risk or the possibility of significant effects on European Sites that are being relied upon to rule out the need for an appropriate assessment. Where you consider this to be the case, we advise that an appropriate assessment should be undertaken to consider the impacts on the integrity of the European site(s), either alone or in-combination with other plans and projects, in view of the available advice about the site’s conservation objectives. However, when determining whether the plan will have an adverse effect on the integrity of the European site at the appropriate assessment stage, a competent authority may take account of those avoidance and mitigation measures. Natural England must be consulted on any appropriate assessment.
Plan-making authorities may also wish to consider the advice about this judgment currently provided by the Planning Inspectorate (PINS Note 05/2018), which recommends that, where planning cases are on-going and still being determined, any HRAs drafted which contain screening decisions that have taken into account mitigation measures should be re- examined and an appropriate assessment conducted where necessary.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter please contact Merlin Ash at [email protected] or on 02080 266382. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected].
Yours sincerely
Merlin Ash Yorkshire and Northern Lincolnshire Team Natural England
65 of 71 Kirk Deighton SAC and impacts from nearby road traffic (August 2016) From: O'Reilly, Liam (NE) [mailto:[email protected]] Sent: 24 August 2016 11:13 To: Feeney, David Subject: RE: Leeds City Council Revised HRA Screening document Leeds SAP - Revised Proposals for ONE
Hello David,
As it’s a draft I’ll respond by email but if you want a letter, please let me know.
Overall I agree with your conclusion that there is no Likely Significant Effect on Kirk Deighton SAC but there are a few things that could use changing to reflect the legislation better:
1) The Habitat Regulations are very sequential: You look at the whole plan and then screen for Likely Significant Effect (LSE); if there is a chance of LSE, you carry out an Appropriate Assessment (AA); if significant impacts are identified you look at alternatives (including mitigation measures) etc. So you can’t include precautionary mitigation measures when screening for LSE as that shows uncertainty and point towards AA: E.g. In section 4.4 it says: ‘Overall no LSE but a series of precautionary Avoidance Measures are identified to include future GCN surveys and application of LTP and Core Strategy Policies.’ This suggests that an AA is required which may conclude that alternatives need to be found including mitigation (there are other similar instances in the document also). However, with the Habs Regs, you assess the whole plan, including any mitigation that is outlined in the plan. It may seem a bit fussy but basically, it’s in the wrong order, so it might be better to say something along the lines of: ‘The plan includes a series of precautionary avoidance measures including future GCN surveys and application of LTP and Core Strategy Policies, which, along with the location of the proposed development, means there is no LSE on Kirk Deighton.’
2) Regarding the acid and nitrogen deposition in appendix 3: The distance we normally consider roads to be an issue is 200m from a site (Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1). Not only that but it is situated to the east of the site and with the UK having a predominately westerly wind, most of the emissions will go the other way. LTP3 is of course beneficial as a whole and does provide further mitigation but the way it is worded could suggest that AA is required – so again just re-order the wording (assess the whole plan).
3) The proposed mitigation for the GCN is excellent and to be commended – again ensure that this is part of the plan and then conclude no LSE. If possible, it would be hugely beneficial to the Kirk Deighton population of GCN if any of these works could be put close to SAC to help expand the population (provided any populations on the development site aren’t harmed – which the mitigation suggests that would be the case). It would be a good example of the local plan enhancing biodiversity and show that you’re meeting paragraph 118 of the NPPF. A couple of other points:
4) In appendix 3 it says the nearest allocation is 1.43km but the nearest allocation is actually HG2-19 (1.06km away) but I assume the reason it says 1.43km away is because this is an addition and HG2-19 was dealt with under the original HRA.
5) Recreational pressures haven’t been assessed but we agree that this shouldn’t be an issue and doesn’t need to form part of the LSE assessment.
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I’d like to give you ring about this and some of the other sites this week if that’s possible, please let me know when you’re available.
Kind Regards
Liam
Liam O'Reilly Lead Adviser Sustainable Development Team Natural England Lateral 8 City Walk Leeds, LS11 9AT Tel – 020 802 68668 Mob - 07881 766 631 www.gov.uk/natural-england We are here to secure a healthy natural environment for people to enjoy, where wildlife is protected and England’s traditional landscapes are safeguarded for future generations. Natural England is committed to providing excellent customer service. We are really interested in your feedback on our service to you; please click on this link to complete a short survey
67 of 71 Appendix 3: Plan of Leeds visitors to the SPM SPA/SAC CRAVEN (Bradford Visitor Survey information 2013)
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Distribution of Postcode Locations ! ! Visitor Survey Postcode Location Special Area of Conservation Special ProtectionCALDERDALE Area KIRKLEES Settlements Leeds District Boundary WAKEFIELD ¯ © Crown copyright and database rights 2018 Ordnance Survey 100019567
PRODUCED BY GIS MAPPING & DATA TEAM, CITY DEVELOPMENT, LEEDS CITY COUNCIL 0 3 6 9 12 Kilometers Path: L:\CGM\Nazia Fazal\Projects\Dave Feeney\Visitors Survey Leeds Postcodes.mxd Scale: 1/110,000 @ A3 Date: 05/12/2018 Created by: NF Appendix 4
Leeds Site Allocations Plan
Leeds Local Plan
Further Proposed Modifications to the Submission Draft Plan May 2017 arising from the Habitats Regulations Assessment
December 2018
68 of 71 Draft CD ref and Site Ref. / Proposed modification Reason Mod. Page No. Reference No. in Plan CD1/1b Section 3 Add new ¶3.1.21 as follows: To reflect conclusions Page 78 ¶3.1.21 within the Habitats “The Habitat’s Regulations Assessment has concluded that measures will be required Regulations regarding the provision and enhancement of green spaces within the HMCA so as to Assessment. help avoid visitor pressure on the South Pennine Moors SPA/SAC. The Council will monitor these through monitoring indicator 24 of the Council’s Monitoring Framework which supports preparation of the Authority Monitoring Report. This will quantify the delivery of green space and green infrastructure delivered in the area along with the amount of commuted sums collected and spent on space projects. Moreover, for the purposes of monitoring this measure the AMR will also report on specific improvements to green spaces in this HMCA, which arise as a result of the North West Leeds Green Gateways and Country Park project.”
CD1/1h Section Add new ¶3.7.21 as follows: To reflect conclusions Page 405 ¶3.7.21 within the Habitats “The Habitat’s Regulations Assessment has concluded that measures will be required Regulations regarding the provision and enhancement of green spaces within the HMCA so as to Assessment. help avoid visitor pressure on the South Pennine Moors SPA/SAC. The Council will monitor these through monitoring indicator 24 of the Council’s Monitoring Framework which supports preparation of the Authority Monitoring Report. This will quantify the delivery of green space and green infrastructure delivered in the area along with the amount of commuted sums collected and spent on space projects. Moreover, for the purposes of monitoring this measure the AMR will also report on specific improvements to green spaces in this HMCA, which arise as a result of the North West Leeds Green Gateways and Country Park project.”
CD1/1l Section 3 Add new ¶3.11.21 as follows: To reflect conclusions Page 669 ¶3.11.21 within the Habitats “The Habitat’s Regulations Assessment has concluded that measures will be required Regulations regarding the provision and enhancement of green spaces within the HMCA so as to Assessment. help avoid visitor pressure on the South Pennine Moors SPA/SAC. The Council will monitor these through monitoring indicator 24 of the Council’s Monitoring Framework
69 of 71 Draft CD ref and Site Ref. / Proposed modification Reason Mod. Page No. Reference No. in Plan which supports preparation of the Authority Monitoring Report. This will quantify the delivery of green space and green infrastructure delivered in the area along with the amount of commuted sums collected and spent on space projects. Moreover, for the purposes of monitoring this measure the AMR will also report on specific improvements to green spaces in this HMCA, which arise as a result of the North West Leeds Green Gateways and Country Park project.”
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