Growth Triangle Area Action Plan Habitats Regulation Assessment

Habitats Regulation Assessment of the North- East Norwich Growth Triangle Area Action Plan

For Broadland District Council May 2014 Proposed Submission Stage

HRA of NEGT AAP for BDC May 2014 v.6

Habitats Regulation Assessment of the North-East Norwich Growth Triangle Area Action Plan undertaken for Broadland District Council

Executive Summary

 As required by the Conservation of Habitats and Species Regulations 2010, before deciding to give consent or permission for a plan or project which is likely to have a significant effect on a European site, either alone or in combination with other plans or projects, the competent authority is required to make an appropriate assessment of the implications for that site in view of that site’s conservation objectives. This document is a record of the Habitats Regulation Assessment of the Old Catton, Sprowston, Rackheath & Thorpe St Andrew, or North East, Growth Triangle Area Action Plan, hereafter referred to as the NEGT, undertaken on behalf of Broadland District Council by the Natural Environment Team, Norfolk County Council (NCC).

 Six groups of plans are reviewed with respect to their conclusions with regard to potential in-combination effects: The Greater Norwich Development Partnership Joint Core Strategy (JCS); the emerging site allocations and development management policy document produced by Broadland District Council and South Norfolk Council; The Broads Authority Core Strategy and Tourism Strategy; Great Yarmouth Borough Council’s emerging plans and policy documents; and, Norfolk County Council (Norwich Northern Distributor Road DC Order application).

 An initial scoping exercise indentifies the main potential impacts from development within the North East Norwich Growth Triangle AAP are with issues relating to changes to local ground water flows and levels of recreational disturbance on designated features of International Sites. The GNDP water cycle study (Scott Wilson, 2010), the Water Resources Management Plan (Anglian Water, 2014) and the North East Norwich Water Cycle Study (Hyder Consulting Ltd, 2013) assess the potential impacts of water abstraction and water disposal and as such, these topics are not addressed in detail in the current work.

 Five International Sites that were not scoped-out at initial stage are subjected to tests of likely significance relating to potential impacts from recreational disturbance: The Broads SAC & Ramsar Site/Broadland SPA; The River Wensum SAC; and Horsey-Winterton Dunes SAC. The Broadland sites are also subjected to tests of likely significance relating to impacts from changes in groundwater flows. Potential impacts from disturbance are identified for the Broads International Sites and Horsey-Winterton Dunes SAC and are subjected to an Appropriate Assessment. The AA concluded that there are potential impacts from disturbance at the Broads SAC and Ramsar Site and Broadland SPA.

 Mitigation measures are assessed relating to the deliverability of accessible green infrastructure within the Growth Triangle, both consented and that need to be delivered by the Area Action Plan policies. The assessment concludes that the amount of open space that will be delivered should provide appropriate mitigation for potential disturbance impacts on the Broadland International Sites. Therefore it is considered that there is sufficient confidence for negative impacts on site integrity on International Sites from the development in the Growth Triangle to be considered unlikely.

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Contents

1. Introduction 1.1 Overview 1.2 Legislation & Planning Policy 1.3 The Assessment Process & Methodology 1.4 Evidence Gathering 1.5 Consultation

2. In-combination Effects 2.1 Overview 2.2 Greater Norwich Development Partnership 2.3 Broadland District Council 2.4 South Norfolk Council 2.5 Broads Authority 2.6 Great Yarmouth Borough Council 2.7 Norfolk County Council

3. Characterising Potential Impacts 3.1 Overview 3.2 Scoping of Sites 3.3 Scoping-out of International Sites

4. Designated Features of Sites Not Scoped-out 4.1 Overview of Sites 4.2 The Broads SAC and Ramsar Site, Broadland SPA 4.3 River Wensum SAC 4.6 Winterton-Horsey Dunes SAC

5. Stage1: Tests of Likely Significant Effects 5.1 Overview 5.2 Site Specific Tests of Likely Significance 5.3 Summary of Stage 1: Tests of Likely Significance

6. Stage 2: Appropriate Assessment 6.1 The Broads SAC and Ramsar Site, Broadland SPA 6.2 Winterton-Horsey Dunes SAC 6.3 Summary of Stage 2: Appropriate Assessment

7. Mitigation Measures 7.1 The use of green infrastructure within development sites to reduce impacts on international sites 7.2 Existing and consented publically available green space 7.3 Potential publically accessible green space 7.4 Summary of consented and potentially available green space

8. Repeat of Appropriate assessment

9. References

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Habitats Regulation Assessment of the North-East Norwich Growth Triangle Area Action Plan, Undertaken on behalf of Broadland District Council

May 2014

1. INTRODUCTION

This is a record of the Habitats Regulation Assessment of the North-east Norwich Growth Triangle Area Action Plan, undertaken for Broadland District Council as the Planning Authority. The Assessment is required by Regulations 61 of the Conservation of Habitats and Species Regulations 2010, in accordance with the EC Habitat Directive (Council Directive 92/43/EEC) before the council as the ‘competent authority’ under the Regulations can permit development to proceed.

1.1 OVERVIEW

As required by the Conservation of Habitats and Species Regulations 2010 (hereafter Habitats Regulations), before deciding to give consent or permission for a plan or project which is likely to have a significant effect on a European site, either alone or in combination with other plans or projects, the competent authority is required to make an appropriate assessment of the implications for that site in view of that site’s conservation objectives.

This document has been prepared by the Natural Environment Team at Norfolk County Council on behalf of Broadland District Council and provides a Habitats Regulations Assessment and Appropriate Assessment for the Old Catton, Sprowston, Rackheath & Thorpe St Andrew, or North East, Growth Triangle Area Action Plan, hereafter referred to as the “NEGT” Growth Triangle Area Action Plan (AAP). The purpose of this document is to assess the likely impacts, effects and mitigation associated with the policies, allocation of sites and associated infrastructure proposed within the AAP in the formal context of the Habitats Regulations.

The draft AAP policies and related allocation map, including a Green Infrastructure strategy, have been developed as part of an iterative process with the Habitat Regulation Assessment recorded in this report. Consultations with stakeholders throughout the process have helped inform the HRA, including formal consultations with Natural England and the Broads Authority (see Section 1.5).

The Area Action Plan being assessed Development to the north east of Norwich will be guided by the Old Catton, Sprowston, Rackheath & Thorpe St Andrew, or North East, Growth Triangle Area Action

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(AAP). The Joint Core Strategy (GNDP, 2011 & 2014) required a minimum of 7,000 homes to be built in the area by 2026, rising to at least 10,000 thereafter. This would be on top of the 2008 baseline commitments in the NEGT of approximately 1,400 – 1,500 homes. The current draft of the AAP allocates land sufficient for around 10,800 homes above baseline commitment in order to allow a realistic prospect of delivering the requisite number of units required by the Local Plan by 2026. In addition, reserve sites have been identified to compensate against the potential failure of one or more of the strategic sites identified. The reserve sites identified are of sufficient size to deliver a further 1,000 homes. If brought forwards these homes would be in addition to the identified sites. Therefore the cumulative growth should all sites and strategic reserves be implemented would be approximately 12,000 homes above 2008 baseline commitments, i.e. 13,500 homes overall.

Aside from residential allocations, the NEGT AAP contains land allocated for employment use, primarily in the southern section, as well as open-space designations. A Green Infrastructure Strategy has been developed alongside the policies and allocations as part of an iterative process to identify a range of landscape, ecology and recreation driven projects and to allow for climate change adaption.

A key infrastructure dependency of the proposed growth with the NEGT AAP is the proposed Northern Distributor Road (NDR). The NDR forms part of the Norwich Area Transport Strategy (NATS) and is therefore part of the baseline conditions for the JCS and NEGT AAP. The NDR is not a proposal of either the JCS or NEGT AAP.

The NDR is a major infrastructure project, and was submitted to the Planning Inspectorate for determination as a Nationally Significant Infrastructure Project application in December 2013. A significant section of this dual-carriageway will bisect the NEGT between Rackheath and Thorpe End. The NEGT AAP contains policies to provide a landscape buffer to the south of the NDR from Norwich Airport in the west to Thorpe End in the East, and a series of green infrastructure links. The green infrastructure links utilises the brown bridges, bat gantries and culverts proposed as part of the NDR plans in order to maintain landscape scale green infrastructure connections.

1.2 LEGISLATION & PLANNING POLICY

The need for an appropriate assessment originally arose under the requirements of the EC Habitats Directive (92/43/EEC) and its implementation in the UK under the Conservation (Natural Habitats &c.) Regulations 1994. The Conservation of Habitats and Species Regulations 2010 were published and consolidated the legislation, updated and incorporated the various amendments made to the Conservation (Natural Habitats, &c.) Regulations 1994 (the 1994 Regulations). On 25 July 2012, Defra laid “The Conservation of Habitats and Species

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(Amendment) Regulations 2012” before Parliament. These Regulations came into force on 16 August 2012.

Regulation 61(5) states that “In the light of the conclusions of the assessment, and subject to regulation 62 (considerations of overriding public interest), the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site “. Regulation 61(6) also states “In considering whether a plan or project will adversely affect the integrity of the site, the authority must have regard to the manner in which it is proposed to be carried out or to any conditions or restrictions subject to which they propose that the consent, permission or other authorisation should be given.”

International sites covered by the Habitat Regulations The Habitats Regulations Assessment relates to Special Protection Areas (SPAs), Special Areas of Conservation (SAC) and Ramsar Sites.

SPAs SPAs are sites classified in accordance with Article 4 of the EC Directive on the conservation of wild birds (79/409/EEC), more commonly known as the Birds Directive. They are classified for rare and vulnerable birds, listed in Annex I of the Birds Directive, and for regularly occurring migratory species. Regulation 8 of the 2012 Regulations substitutes regulation 9 of the 2010 Regulations, to provide that public bodies must exercise their conservation functions specifically so as to comply with the Birds Directive.

SACs SACs are classified in accordance with EC Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). Article 3 of this Directive requires the establishment of a European network of important high-quality conservation sites that will make a significant contribution to conserving the 189 habitat types and 788 species identified in Annexes I and II of the Directive.

SPAs and SACS are known as the Natura 2000 network and are commonly referred to as ‘European Sites’.

Ramsar Sites Ramsar Sites are sites qualifying under the International Convention on Wetlands of International Importance, 1971, known as the Ramsar Convention (amended by the Paris Protocol, 1992). Ramsar Sites are not protected in UK law by the Birds and Habitats Directives; however parliament has decreed that, unless otherwise specified, procedures relating to SPAs and SACs will also apply to Ramsar Sites. This was reiterated in the National Planning Policy Framework (DfCLG, 2012). Thus, in this report, the term ‘International Sites’ is used to refer to Ramsar sites as well as SACs and SPAs.

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Appropriate assessment: An appropriate assessment is a decision by a 'competent authority', in this case Broadland District Council, as to whether the proposed plan or project can be determined as not having an adverse effect on the integrity of any European sites.

An adverse effect on integrity is one that prevents the site from maintaining the same contribution to favourable status for the relevant feature or features, as it did when the site was qualifying. Only where a plan or project can be determined by the competent authority as not having an adverse effect on site integrity can it be allowed to proceed. The favourable conservation status of the site is defined through the site's conservation objectives and it is against these objectives that the effects of the plan or project must be assessed.

1.3 THE ASSESSMENT PROCESS & METHODOLOGY PROCESS

The Appropriate Assessment process is outlined below. This involves evidence gathering followed by three stages:

Evidence Gathering: Collation of documentation relating to the plan. Collecting information on relevant European sites, their conservation objectives and characteristics.

Stage 1: The ‘test of likely significant effect’. Establishing whether a plan is ‘likely to have a significant effect’ on a European site, and therefore requiring the Appropriate Assessment.

Stage 2: Assessment of whether there is an effect on site integrity. This is potentially a two-stage process, with a consideration of whether there are likely to be effects, followed if necessary by a detailed consideration of site-specific factors.

Stage 3: Reassessment. If there is an effect on site integrity then the project should be reassessed with the inclusion of compensation and a repeat of stage 2 should then be completed.

1.4 EVIDENCE GATHERING

Data on the project proposals are taken from Broadland District Council’s Draft NEGT Area Action Plan policy and allocation documents (December 2013 iteration). Identification of European sites was undertaken utilising the databases held by Norfolk Biodiversity Information Service (the County Records Centre for Biological and Geographical records, hereafter referred to as NBIS) and the online Multi-Agency Geographic Information for the Countryside database (hereafter referred to as MAGIC; www.magic.gov.uk). Data on the European sites, including qualifying features were taken from the Joint Nature Conservation

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Committee website (www.jncc.gov.uk); data on the component SSSIs, primarily the condition assessment, were taken from the Natural England website (www.naturalengland.org.uk).

In addition, a scientific literature search was undertaken using publically available search engines, grey literature reports and academic databases to utilise relevant research work.

Definition of ‘Site Integrity’

Based on definitions within Article 1 of the Habitats Directive and following English Nature (2004), now Natural England, site integrity is defined as:

For habitats:

 Their range and area must be stable or increasing;

 The species structure and functions necessary for long-term maintenance of the habitat exist and are likely to continue to exist for the foreseeable future; and

 The status of the typical species is considered to be favourable.

For species:

 The population dynamics data on the species indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats; and

 The natural range is stable and likely to continue to be, and there is and will probably continue to be a sufficiently large habitat to maintain its population on a long term basis.

To help identify likely effects and potential mechanisms that could affect site integrity, English Nature (1999, 2004) proposed a checklist of questions. For the assessment to conclude that there are no adverse effects then it is necessary to show that:

 The area of Annex I habitats (or composite features) will not be reduced;

 There will be no direct effect on the population of the species for which the site was Qualifying or classified;

 There will be no indirect effects on the populations of species for which the site was Qualifying or classified due to loss or degradation of their habitat (quantity/quality);

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 There will be no changes to the composition of the habitats for which the site was Qualifying (e.g. reduction in species structure, abundance or diversity that comprises the habitat over time); and

 That there will be no interruption or degradation of the physical, chemical or biological processes that support habitats and species for which the site was Qualifying or classified.

If it is concluded that one or more of the above is not met, or if there is uncertainty, then it is necessary to consider further site-specific factors in order to reach a decision. The key site-specific factors that need to be considered when forming judgments on site integrity (English Nature, 2004) are:

 Scale of impact,

 Long term effects and sustainability,

 Duration of impact and recovery/reversibility,

 Dynamic systems,

 Conflicting feature requirements,

 Off-site impacts, and

 Uncertainty in cause and effect relationships and a precautionary approach.

Mitigation versus Compensatory Measures

It is generally accepted that there are three types of interacting measures to reduce impacts. The first two, avoidance and reduction, are grouped together as mitigation. In addition, there are compensatory measures. The European Commission (2007, p10) present the distinction as:

“Mitigation measures are those measures which aim to minimise, or even cancel, the negative impacts on a site that are likely to arise as a result of the implementation of a plan or project. These measures are an integral part of the specifications of a plan or project”, and

Compensatory measures in the strict sense are independent of the project (including any associated mitigation measures). They are intended to offset the negative effects of the plan or project so that the overall ecological coherence of the Natura 2000 Network is maintained.”

Tyldesley, 2011, (p13) summarises this succinctly: “Mitigation (avoidance and reduction) measures (are) built into the project and form(ing) part of the project

9 of 61 HRA of NEGT AAP for BDC May 2014 v.6 as proposed or applied for” whereas compensatory measures are those which “do not already form part of the project but may be applied as additional conditions or restrictions”.

1.5 CONSULTATION

The competent authority must consult the appropriate nature conservation body, currently Natural England, and have regard to any representations made by that body. As stated earlier, the HRA work was undertaken alongside the development of the AAP policies and allocation process, and formal and informal conversations regarding the approach were undertaken throughout with Natural England.

Due to the nature of potential impacts from the proposed development in the NEGT and the proximity to the northern Broads, discussions were held with the Broads Authority and formal comments sought. Discussions were also held with the RSPB (Eastern Region). A stakeholder workshop to consider environmental impacts and Green Infrastructure was organised by BDC and the output from that workshop was used to inform the current HRA work.

Significant consultation events are described in Table 1 below.

It is worth noting that as the NEGT AAP was developing, other emerging plans and policy documents were also being produced. These include Site Allocation Documents and Development Management Policies Documents for both BDC and South Norfolk Council. These plans have been, or will be, assessed under the Habitat Regulations and many of the discussions and formal consultations relating to these plans have also been relevant to the current work.

Table 1: Record of Consultation

Organisation Date Topics of discussion

Natural England January 2013 Informal discussions on HRA approach, specifically in relation to HRA assessment of planning application 20121516 but with wider discussion on cumulative impacts on NEGT, with Natural England Land Management Specialist at Dragonfly House offices, Norwich on 21 January 2013; meeting notes taken by D. White (NCC) Natural England May 2013 Formal consultation on proposed HRA approach for NEGT with Natural England spatial planner; follow- up comments received by email from NE to D.White (NCC) on 13 May 2013 (NE reference 83415) Stakeholder workshop May 2013 Workshop to discuss environmental matters and GI to be considered within the NEGT AAP on 9 May 2013. Organisations represented included Environment Agency, Norfolk Wildlife Trust, Broads

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Authority, Land Trust, GNDP and developers. A record of workshop discussions was made by BDC Planners RSPB May 2013 Proposed HRA approach and proposed mitigation for a number of different LAP plans including NEGT AAP; round-table discussion with RSPB planning specialists and ecologists on 10 May 2013 at RSPB offices, Thorpe Road The Broads Authority June 2013 Proposed HRA approach and proposed mitigation for a number of different LAP plans including NEGT AAP; round-table discussion with senior planners and ecologists from Broads Authority on 10 June 2013 at BA offices; formal follow-up comments received by email from BA to D. White (NCC) 27 June 2013 Natural England August 2013 Discussions on HRA work, specifically potential impacts from disturbance as a result of increased recreation on the Broadland International sites; Norfolk Wildlife Trust August 2013 Discussion of evolving HRA work; meeting at NWT office 30 August 2013; subsequent comments received from NWT to D. White (NCC) The Broads Authority December 2013 Draft Green Infrastructure Strategy; formal response received 19 December 2013 (email to BDC Planner) Natural England December 2013 Draft Green Infrastructure Strategy; formal response received 15 December 2013 (email to PBDC Planner)

2. IN COMBINATION EFFECTS

2.1 OVERVIEW

It is a requirement of the Habitats Regulations to undertake an in-combination assessment of plans and projects. A project or plan that affects a European site in some way, but where these effects are unlikely to be significant, may be significant when considered in combination with other plans. There are a number of plans prepared by BDC and by neighbouring local authorities which may act in combination with the NEGT Area Action Plan to result in impacts on the integrity of sites.

Six groups of plans are reviewed with respect to their conclusions pertaining to potential in-combination effects. These are plans for

 The Joint Core Strategy (2011 & 2014) for the Greater Norwich Development Partnership area (Broadland, Norwich and South Norfolk districts);

 Broadland District Council’s emerging Site Allocation Plans and Development Management Policies documents;

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 South Norfolk Council’s draft Site Allocation Plans (2013) and draft Development Management Policies documents (2013);

 The Broads Authority plans including Core Strategy (2006) and the Tourism Strategy (2011);

 Great Yarmouth Borough Council’s emerging plans and policy documents, and

 The Norwich Northern Distributor Road DCO application (NCC, 2013)

2.2 GREATER NORWICH DEVELOPMENT PARTNERSHIP AREA

Joint Core Strategy (Mott Macdonald, 2010)

As described by Mott Macdonald, the 2009 Joint Core Strategy (JCS) consultation report was subject to a Stage 1 Test of Likely Significant Effects and the following JCS policies were identified as having the potential to have significant effects on European and Ramsar designated sites:

 Policy 3: Energy and Water (which underpins Policies 10 & 12);

 Policy 4: Housing (which underpins Policies 10 & 12);

 Policy 6: Access and transportation;

 Policy 10: Location for major new or expanding communities, and;

 Policy 12: The remainder of the Norwich urban area, including the fringe parishes.

The Stage 2 Appropriate Assessment considered that all the above policies with the exception of Policy 6 were likely to have a significant impact, on the basis that the relevant schemes would be considered at the project level and not directly related to JCS policies.

Two main issues were considered potentially significant: hydrological issues and impacts from human disturbance.

The Habitats Regulations Assessment of the Joint Core Strategy addressed hydrological issues and the GNDP Water Cycle Study (Scott Wilson, 2010) further assessed the potential impacts of water abstraction and water disposal. Since the publication of the original Mott Macdonald HRA (2010), further planning and legal processes have been undertaken concluding that impacts on International Sites will be negligible. An addendum to the HRA indicated that

12 of 61 HRA of NEGT AAP for BDC May 2014 v.6 measures are underway “towards a resolution of the longer term water resource requirement” (Anglian Water, Environment Agency and Natural England, 2012). This has been consolidated in the Strategic Environmental Assessment (SEA) for the Anglian Water 2014 Water Resources Management Plan (WRMP) (May 2013). The WRMP considers options for:

 Reliable supplies: providing supplies suitable for their customers, that the supply is resilient to the effects of climate change, population and property growth and other challenges such as deteriorating water quality;  Sustainable upstream resource base: no damage to the environment from actions by Anglian Water; and  An affordable investment programme: keeping bills low and protecting vulnerable customers.

The SEA identifies the environmental effects of schemes to take forward into the WRMP Preferred Plan and ensures that scheme options with significant negative effects are either mitigated (mainly through pipeline re-routing to avoid designated sites) or rejected at the option selection process stage and not taken forward into the WRMP Preferred Plan. Schemes NB 10 (Norwich intake with pipeline to Norwich Storage) and NB2 (Norwich Water reuse) will require an Appropriate Assessment and this will be undertaken in due course if appropriate.

The WRMP is further supported by the North-East Norwich Water Cycle Study (Hyder Consulting 2013) provided for Broadland District Council, which considers water resources, supply and efficiency, surface water management and wastewater treatment and water quality in the context of development proposals in the NEGT area. As such, these issues are not addressed in detail in the current HRA report. The suitability of this approach was agreed with Natural England in early consultations and confirmed in an email of 13 May 2013 (NE reference: 83415).

Increased disturbance was assessed as a potentially significant impact of policy 4 (with any in-combination disturbance impacts from policy 12 covered under policy 4). As described for policy 4, site integrity may be impacted from: “In- combination impacts associated with area-wide growth, resulting in increased visitor pressure on European designated sites in combination with growth in neighbouring local authority areas.” The identified International Sites were:

 Broads SAC; Broadland Ramsar & SPA;  Breckland SPA & SAC;  Great Yarmouth North Denes SPA;  Winterton – Horsey Dunes SAC; and  North Norfolk Coast SAC, SPA & Ramsar.

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2.3. BROADLAND DISTRICT COUNCIL

Emerging Site Allocation Plans and Development Management Policies

The North-East Norwich Growth Triangle (NEGT) AAP has been developed in parallel with Broadland Council’s Site Allocation DPD and the emerging Development Management Policies documents. It is intended that all the Site Allocations and Development Management Policies documents will be adopted by Broadland District Council in 2014, or early 2015. All these documents have been assessed under the Habitat Regulations for potential impacts on International Sites.

The HRA for Broadland District Council’s Sites Allocation DPD considers The Broads SAC & Ramsar Site/Broadland SPA, The River Wensum SAC, Winterton- Horsey Dunes SAC, Breydon Water SPA, Breydon Water Ramsar Site & the Norfolk Valley Fens SAC in terms of potential impacts from recreational disturbance and impact on groundwater flows. Tests of likely significance conclude that given the proximity of some allocation sites to component units of the Broadland International Sites and the Winterton-Horsey Dunes SAC, an impact on site integrity from disturbance from recreation could not be discounted. Therefore an Appropriate Assessment was required.

The AA concludes that there were potential impacts from disturbance at the Broads SAC and Ramsar Site and Broadland SPA. However any impacts are assessed as likely to be very small because:

 None of the settlements with site allocations are within close proximity to the International Sites, limiting the opportunities for residents to use such sites for daily recreation, such as dog-walking;  Existing ‘honey pot’ locations will likely to continue to attract most visitors and existing management practices at these localities will continue to address potential impacts from visitor pressures; and  In numerical terms, potential visitors to the International Sites from developments in Broadland District settlements with site allocations will be a very small proportion of the total numbers arising from the existing population together with ‘tourist’ visitors from further afield who are being encouraged by the Tourism Strategies such as that of the Broads Authority.

Nevertheless, although likely to be very small, the potential for some impacts remained and thus mitigation was required in the form of green infrastructure provision within development sites. It was recommended that the emerging Development Management Policy Document should ensure that the necessary mitigation is delivered. It was further recognised that monies arising from the Community Infrastructure Levy (CIL) should contribute to the provision of the

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2.4. SOUTH NORFOLK COUNCIL

Draft Site Specific Allocation Plans (2013)

The draft Site Specific Allocation Plan, including the Wymondham AAP, the Long Stratton AAP and the Cringleford Neighbourhood Plan, was subjected to a Habitat Regulation Assessment (NCC Natural Environment Team, October 2013). An initial scoping exercise indentified the main potential impacts from development sites within South Norfolk were with issues relating to water abstraction and water disposal and levels of recreational disturbance.

The GNDP water cycle study (Scott Wilson, 2010) fully assessed the potential impacts of water abstraction and water disposal and as such, they were not addressed in detail in the HRA. The suitability of this approach was agreed with Natural England (NE reference: 83415). Nine International Sites that were not scoped-out at initial stage were subjected to tests of likely significance relating to potential impacts from recreational disturbance. These were Norfolk Valley Fens, The Broads SAC & Ramsar Site/Broadland SPA; Breckland SPA and Breckland SAC; The River Wensum SAC; Redgrave & South Lopham Fens Ramsar/ Waveney and Little Ouse Valley Fens SAC.

Having completed the Stage 1 test, it was considered that there was sufficient confidence for significant effects to be unlikely and an Appropriate Assessment was not required for disturbance effects on any of the International Sites. Therefore it was concluded that there was no need to undertake further stages of the HRA process in relation to the Site Allocation Documents.

Draft Development Management Policies (2013)

The draft Development Management Policies document was subjected to a Habitat Regulation Assessment (NCC Natural Environment Team, September 2013). This assessment complemented the HRA undertaken for South Norfolk Council’s Site Specific Allocations Document.

Four groups of plans were reviewed with regards to their conclusions in respect of potential in-combination effects on International Sites, including plans for The Greater Norwich Development Partnership, Great Yarmouth Borough Council, Breckland District Council and The Broads Authority. An initial scoping exercise indentified nine International Sites that were subject to Test of Likely Significant Effects. These were The Broads SAC & Ramsar Site and the Broadland SPA, The River Wensum SAC, the Norfolk Valley Fens, Breckland SPA and Breckland SAC, Redgrave & South Lopham Fens Ramsar/ Waveney and Little Ouse Valley Fens SAC.

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Having completed the Stage 1 Test, it was considered that there was sufficient confidence for significant effects to be unlikely and an Appropriate Assessment was not required for disturbance effects on any of the International Sites. Therefore it was concluded that there was no need to undertake further stages of the HRA process with respect to the Development Management Policies.

2.5 BROADS AUTHORITY

Core Strategy (Broads Authority, 2006)

The Habitats Regulations Assessment for the Core Strategy concluded that none of the policies presented a significant risk to site integrity. Specifically it concluded that “any risks will be prevented by the Holistic interpretation of Core Strategy policies, using Core Strategy Policy 2 for sites designated with European and National Importance”. Core Strategy Policy 2 states that: “policies will take into account National & European designated conservation sites”.

The most relevant Core Strategy Policies (CS) to which this applies are CS 2 (protecting and enhancing new water space), CS 4 (creation of new resources), CS 9 (sustainable tourism), CS 10 (tourist and recreation development), CS 14 (additional moorings), CS 15 (safe navigation), CS 16 and CS 17 (accessing The Broads in a sustainable manner) and CS 19 (sustainable locations for medium/larger visitor developments.

Two sites were identified as possibly at risk of impacts namely Breydon Water SPA and Ramsar Site (CS 10); and The Broads SAC/ Ramsar Site/ Broadland SPA (CS 10, CS 16 and CS 17). For both sites CS 2 is identified as the key policy for justifying site-by-site assessment of impacts.

Development Management Policies (Wildfrontier Ecology, 2011)

For the Broads Development Management Policies, the HRA assessment was undertaken as an iterative process. Revisions to the wording and the subsequent strengthening of some policies resulted in the conclusion that impacts on site integrity were unlikely. However, if a proposal is considered in the context of a given policy to have an effect on an internationally designated site then it will need to be considered against the Habitats Directive and a project level Appropriate Assessment will need to be undertaken.

Site Specific Policies (Interim Draft HRA) (Wildfrontier Ecology, 2012)

An assessment of the ‘finer scale’ policies within the Broads Authority concluded that significant effects on site integrity were possible for The Broads SAC, Broadland SPA and Winterton – Horsey Dunes SAC and Great Yarmouth North

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Denes SPA. The draft policies of possible concern were those potentially resulting in disturbance or hydrological issues at the named settlements of Cantley, Brundall, Great Yarmouth marina, Horning and Oulton Broad. Non- settlement draft policies with potential impacts were those relating to management works at Horsey and St Benet’s Abbey. In each case, minor revisions to the wording of individual draft policies resulted in a revised assessment where no impact on site integrity was concluded.

Tourism Strategy (Broads Authority 2011)

The Tourism Strategy for The Broads has not been subject to a HRA (confirmed by email from an officer from the Broads Authority 29 January 2013). The Tourism Strategy aspires that by the year 2015 there will be increased visitors to the Broads, with proportionally more in the southern Broads and with more visitors out of season. Ecotourism is recognised as a major product and market opportunity, and the strategy aspires that there is tangible evidence that overall environmental quality has further increased with the support of tourism.

With particular relevance to the current HRA work for the South Norfolk Council Site Allocation documents, the Tourism Strategy makes reference to local residents (as opposed to visitors from outside the area). In particular, an area for action included a desire to raise local residents’ awareness of the Broads product (p42). It states that the “continuing importance of the day visitor market has been highlighted in this strategy. Business can be generated not only from residents in and around the area but also from their visiting friends and relatives. It is believed that local awareness of Broads products and experiences is still quite patchy.”

Also relevant in the current HRA work are the aims of the Tourism Strategy to:

 Strengthen visitor awareness of opportunities in the peripheral parts of the Broads by providing good information about what can be found at the end of each waterway and how it may differ from the busier, more congested parts, by encouraging further development of relevant product in the upper reaches, for example by canoe, by providing trails and guided walks and wildlife trips and by taking care to manage the scale and distribution of new activity in sensitive areas, with appropriate advice from conservation managers.

 Monitor proposed improved or promoted access to ensure adequate protection is in place to safeguard Qualifying and important wildlife habitats and species.

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2.6 GREAT YARMOUTH BOROUGH COUNCIL

Waterfront Area Action Plan and Core Strategy of the Great Yarmouth Local Development Framework

As reported by Grant (2010) in the HRA of the Waterfront Area Action Plan, the Core Strategy identified the following likely significant effects:

 Recreational pressures from increased numbers of visitors to Winterton- Horsey Dunes SAC, Great Yarmouth North Denes SPA and Breydon Water SPA/Ramsar;

 Urban effects, such as litter and lighting, on Winterton-Horsey Dunes SAC and Great Yarmouth North Denes SPA; and

 Surface run-off resulting in a deterioration of water quality in watercourses, which in turn could have an effect on the Broads SAC and Broadlands SPA/Ramsar and Breydon Water SPA/Ramsar.

The HRA of the Waterfront Area Action Plan concluded that there could be possible impacts on site integrity from water quality and hydrology of The Broads SAC/Broadlands SPA/Ramsar and Breydon Water SPA/Ramsar. It also recognised potential impacts from recreation on the dunes at Winterton-Horsey Dunes SAC and disturbance at Breydon Water SPA/Ramsar and disturbance to nesting little tern at Great Yarmouth North Denes SPA.

The Consultation Draft of the HRA of the Great Yarmouth Local Plan Core Strategy (Footprint Ecology & David Tyldesley & Associates, 2012) detailed and up-dated assessment of current and future recreational use of on the Winterton- Horsey Dunes SAC, Breydon Water SPA/Ramsar and Great Yarmouth North Denes SPA including a full discussion of visitor surveys and potential impacts.

2.7 NORTHERN DISTRIBUTOR ROAD (NORFOLK COUNTY COUNCIL, 2013)

Norfolk County Council applied for a Development Control Order (DCO) for the Norwich Northern Distributor Road (NDR) as a Nationally Significant Infrastructure Project in December 2013. The Planning Inspectorate has until the 4th February 2014 to decide if it will accept application. The NDR scheme is for a 20.4 km long dual carriageway strategic distributor road linking the A1067 Fakenham Road, near Attlebridge, to the A47 Trunk Road (T) at Postwick. The intention is for the construction is programme to be carried out between 2015 and 2017.

A HRA has been undertaken for the scheme (MottMacDonald, 2014) which assessed potential impacts on 9 individual or groups of International Sites. The Stage 1 process identified potential impacts on the integrity of the River Wensum

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SAC from changes in groundwater levels, changes in water chemistry, changes in water flow and siltation. It is considered that the mitigation from engineered features integral to the design of the scheme will reduce any impacts to negligible levels.

3. CHARACTERISING POTENTIAL IMPACTS

3.1 OVERVIEW

The main potential impacts identified in relation to the NEGT are with issues relating to water abstraction and water disposal and levels of recreational disturbance by residents of the new households on International Sites. These are discussed below.

Water abstraction and water disposal

In the Habitats Regulations Assessment of the Joint Core Strategy, hydrological issues were assessed. The GNDP water cycle study (Scott Wilson, 2010), and more recent North East Water Cycle Study (2013) fully assessed the potential impacts of water abstraction and water disposal.

As described above (paragraph 2.2), impacts from water abstraction and water disposal on International Sites are being addressed by Anglian Water in agreement with the Environment Agency and Natural England. Anglian Water’s (AWS) Water Resource Management Plan (WRMP) (2014) identifies specific interventions to maintain the supply demand balance up to 2014 in the Norwich and Broads Water Resource Zone. The SEA for the WRMP identifies the environmental effects of schemes to take forward into the WRMP Preferred Plan and ensures that scheme options with significant negative effects are either mitigated (mainly through pipeline re-routing to avoid designated sites) or rejected at the option selection process stage.

Recent correspondence between AWS and BDC has indicated that the interventions proposed will in real terms would be able to accommodate 10,000 homes in the Growth Triangle by 2026 and at least 15,000 overall, and that appropriate improvements needed to support growth at Whitlingham had been included within the AWS bid to Offwatt in AMP6.

In any event, and as noted by Inspectors Roy Foster and Mike Fox in their report on the Joint Core Strategy (February 2011), if unexpected or irresolvable problems were to occur then Policy 3 of the Joint Core Strategy prevents further development without the accompanying infrastructure.

As such, there is sufficient confidence to conclude that water abstraction and disposal will not have any significant impact on international sites and therefore

19 of 61 HRA of NEGT AAP for BDC May 2014 v.6 they are not addressed in detail in the current HRA work here. The suitability of the principle of this approach was agreed with Natural England in early consultations and confirmed in an email of 13 May 2013 (NE reference: 83415).

Although potential impacts of water abstraction and water disposal are not considered in the HRA presented in this document, potential local impacts on groundwater flows on International Sites as a result of the allocations will be considered.

Disturbance

Of principal importance to this assessment are trampling effects on vegetation and the disturbance of birds, both on breeding birds and those that winter in the East of England, on International Sites as a result of recreational pressure from residents of new households in the NEGT. The most visible impact on most habitats is direct trampling effects, destroying vegetation, preventing re-growth and compressing soils. Related mechanisms include nutrient enrichment from dog fouling and even irresponsible behaviour such as fires and littering.

Assessing the potential impacts from recreational disturbance is not straightforward. Species react differently to one another; effects may vary seasonally and in different weather and relating the behaviour of individual animals to population integrity is complicated. Furthermore data on human visitor numbers and usage across all months and all areas of International Sites will always be deficient. Some of the issues relating to recreational disturbance have been succinctly summarised by Ecology Consultancy (2013) and are included in Box 1 below.

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Box 1: Recreational disturbance from housing growth – Problems in assessing impact on biodiversity (from Ecology Consultancy, 2013).

The significance of disturbance is one of the 100 key policy questions for ecological research (Sutherland et al., 2006). A key question in disturbance research is how to scale individual impacts to the population level, which is required when establishing effects on site integrity. The interpretation of disturbance effects is potentially confounded by a range of factors including differences in behavioural responses among species, the impact on individual condition or ‘fitness’ and consequent impacts on survival and reproduction. Effects are also dependant on the availability of alternative feeding areas and resource availability and weather (Goss-Custard et al., 2006).

Among the factors that confound the interpretation of observational studies of disturbance is the potential difference among species in their responses. Thus, some bird species may fly away or leave an area when disturbed but others may remain but nevertheless feed at a lower rate, with impacts on individual fitness. Some studies may interpret such an absence of an obvious response as tolerance or habituation to disturbance, while the opposite may be true (Gill et al., 2001a).

Thus, in reviewing the impacts of disturbance on birds a precautionary approach should be applied, with an appreciation of the interplay of factors and difficulties in the scaling from behaviour to individual and population level effects.

Projecting increases in disturbance in relation to housing is difficult. Although some work has shown a correlation between housing and visitor numbers (e.g. Jones et al., 2003) the predictive models work well for the numbers of visitors arriving by foot but are much less able to show links between housing numbers and density and visitors arriving by car (Liley et al., 2006). A myriad of factors would be expected to determine the numbers of visitors, including general factors such as the weather and economic conditions, more regional factors such as road and rail accessibility, and local factors such as the proximity of toilets and other facilities. The availability and/or introduction of alternative facilities that may displace visitor numbers is also a key issue, particularly in ensuring that estimates of visitor impact are made on a consistent basis.

Even with an understanding of the actual and projected numbers of visitors, the disturbance experienced by individual birds will vary according to local conditions, possibly including proximity, sight lines and the feeding quality of habitats. Generally, however, disturbance which limits food accessibility at critical times of the year, particularly for open-habitat dwelling bird species, as well as disturbances on the breeding grounds, are the most disturbing types of activity.

Generally, however, visitors to wetland reserves can be appropriately managed by the use of spatial and temporal zoning of activities, screening at sensitive locations and visitor management policies that reflect the site specific conditions and the species potentially affected. Details are provided in Kirby et al. (2004). The RSPB and Wildlife Trusts successfully integrate visitors and nature conservation across a broad range of sites in the UK. Further, the proximity of the disturbance source and its type, substantially affects a bird species response to that disturbance. Disturbance from vehicles along roads adjacent to sites of bird interest may be generally habituated for whereas people walking through an open area can cause significant disturbance to certain species that rely on open habitats with good sight-lines, but this type of disturbance is far less disturbing than someone using a shotgun, for example (see Hill et al., 1997).

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3.2 SCOPING OF SITES

The International Sites considered within the scoping exercise are those identified in the HRA produced for the Joint Core Strategy (Mott Macdonald, 2010). It identified housing delivery and associated disturbance as being a potential impact for the following sites:

 The Broads SAC; Broadland SPA and The Broads Ramsar Site;  Breckland SPA & SAC;  Great Yarmouth North Denes SPA;  Winterton – Horsey Dunes SAC;  North Norfolk Coast SPA, SAC and Ramsar Site.

Some of the Norfolk International Sites are not continuous but are comprised of a number of separate ‘component units’ and these individual units are considered where appropriate. The International Sites are shown on Figure 1.

In the first stage of the screening process a 40km radius was used to identify International Sites that are to be assessed (Table 2). This distance was chosen being towards the larger end of that used in similar studies and is the same distance used in HRA of South Norfolk Council’s Site Specific Allocation Document and Development Management Policies Document. It is twice the distance used as a buffer in the HRA of the Breckland Core Strategy (Liley et al., 2008; p 10), a distance that was determined from experience of visitor survey work in relation to designated sites in Breckland and in the New Forest. The distance is similar to the 50km cut-off as the distance travelled by day-visitors used by Liley (2008) in assessing housing impacts on the North Norfolk Coast.

22 of 61 HRA of NEGT AAP for BDC May 2014 v.6 Figure 1: European and Ramsar Sites in relation to the North East Norwich Growth Triangle

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Table 2: International Sites with component units within 40km of the application

Site name Status Summary of Vulnerabilities (from Mott designated features Macdonald, 2008)

The Broads Ramsar Wetland habitats, plants None cited, but probably as for birds, and other animals. SAC (below) with disturbance likely to be a factor. Estimates of tourist numbers to the Broads and environs are 6.9 million p.a. of which 84% are day visitors (Broads Authority, 2011) The Broads SAC Wetland vegetation, Sea level rise, abstraction plants and other animals. reducing flows in northern rivers, eutrophication from sewage and agricultural runoff Broadland SPA Wetland birds. Disturbance likely to be a factor, although not cited. Tourist numbers to the Broads and environs are estimated at 6.9 million p.a. of which 84% are day visitors (Broads Authority, 2011) River SAC Aquatic vegetation and Development on flood plain, Wensum animals. agricultural eutrophication & run- off, abstraction, non-native spp. Norfolk Valley Fens SAC Wetland vegetation and Reduction in management and plants; groundwater abstraction invertebrates Breydon Water SPA Wetland and estuarine Disturbance to a high tide roost Birds of wading birds, drainage of wet grassland, ‘pressure’ from development of Great Yarmouth Breydon Water Ramsar Wetland and estuarine None cited, but probably as for Birds the Great Yarmouth SPA North Denes SPA Breeding little terns Reduced accretion, predators & disturbance from people & dogs Winterton – Horsey SAC Dune habitats and great Cessation of erosion and Dunes crested newts accretion due to sea defences, beach feeding with inappropriate sand, water abstraction and visitors causing disturbance, erosion & fires Paston Barn SAC Barbastelle bat Development as tourist attraction, wedding venue & cafe Overstrand Cliffs SAC Soft cliff vegetation Coastal protection & drainage work Breckland SPA Heathland birds Nitrogen deposition, egg collecting. Breckland SAC Heathland vegetation and Reduction in grazing and cutting, habitats; Breckland nitrogen deposition, recreation, meres and alluvial forest; groundwater abstraction great crested newt and barbastelle bat

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Redgrave & South Ramsar Wetland habitat and a None cited, but probably as for Lopham Fens spider the Waveney and Little Ouse Valley Fens Waveney and Little SAC Wetland vegetation; Loss of traditional management, Ouse Valley Fens Desmoulin’s whorl snail water abstraction Benacre to East SPA Wetland birds Sea level rise and erosion. Bavents Benacre to East SAC Coastal lagoon habitat None cited, but probably as for Bavents Lagoons and alluvial forest the SPA The Wash and North SAC Coastal and marine Sea level rise, storm surges, Norfolk Coast habitats and vegetation; erosion, abstraction and common seal, grey seal disturbance from tourism and otter North Norfolk Coast SAC Coastal & marine Sea level rise, storm surges, habitats & vegetation; erosion, abstraction and common seal, otter & disturbance from tourism great crested newt & petalwort North Norfolk Coast SPA Wetland and coastal Sea level rise, storm surges, birds erosion, abstraction and disturbance from tourism North Norfolk Coast Ramsar Coastal and marine Sea level rise, storm surges, habitats and vegetation; erosion, abstraction and birds and other animals disturbance from tourism

3.3 SCOPING-OUT OF INTERNATIONAL SITES

The HRA work for the JCS concluded that growth proposed in the strategy could have an impact on International Sites as a result of disturbance from recreation. However, as the distance an International Site is from a settlement increases, the potential impact from recreational pressure from home owners in that settlement is likely to decrease. Therefore it is possible to scope out International Sites based on their distance from the planning application.

As a scoping exercise to identify which International Sites are potentially at risk, the criterion for a site to be scoped-out is that it is likely to be unattractive to visitors from the NEGT (and north Norwich generally) at least in relative terms. This may be via a combination of isolation by distance in absolute terms, the low relative increase in the numbers of visitors compared to those attributable to nearer conurbations or the absence of reasonable attractions for recreational users from Norwich.

Some subjectivity is inevitable in taking this approach. An example of this is the consideration of available information on visitor usage. Work by Dolman et al. (2008) in Breckland, who undertook a survey of visitors actually using semi- natural areas as opposed to more formal tourist attractions, determined that 43% of visitors were from within 5km and another 20% from 5-10km. Given the proposed 9000 housing allocation for the Breckland District Council, it is unlikely

25 of 61 HRA of NEGT AAP for BDC May 2014 v.6 that visitors from the Norwich will contribute significant numbers of visitors to the Breckland International Sites in relative or absolute terms.

The presence or absence of facilities for visitors will also affect the magnitude of potential impacts. Factors that make sites less attractive include limited car parking and the absence of toilets, cafes and other facilities. Some International Sites in Norfolk are highly managed by NGOs and actively encourage visitors. Sites like Strumpshaw Fen (RSPB) and Hickling (Norfolk Wildlife Trust) are heavily promoted and have the infrastructure capacity to take more recreational use. In 2011 there were 28,000 visitors to RSPB Strumpshaw Reserve (Visit England, 2012). Potential adverse impacts on such promoted sites from growth are limited and additionally they encourage visitors away from more vulnerable areas of International Sites.

In Norfolk, special measures are taken by conservation organisations for some bird species that are vulnerable to disturbance. For example, in the Breckland SPA, several nature reserves owned by the Norfolk Wildlife Trust, together with other land with ‘open’ access, are closed to visitors when stone curlew Burhinus oedicnemus are breeding. This access restriction is stringently enforced and is considered effective, not least because there has been a steady increase in the population in eastern England from fewer than 100 pairs in 1985 to circa 280 pairs today (RSPB, 2013) and the stone curlew was moved from the 'Birds of Conservation Concern' red list to amber list in 2009. Breeding colonies of other species are carefully wardened, for example the little terns Sterna albifrons at Great Yarmouth North Denes by the RSPB and volunteers. These specific measures designed to reduce disturbance have been taken into account in the scoping exercise.

Local infrastructure factors can also be important. A site that is accessible by a direct, fast road may be an attractive draw to visitors such as dog walkers, even if the absolute distance between the site and a settlement is quite great. It should also be remembered that the topography of Norfolk can influence the accessibility of sites. Two locations either side of a Norfolk river can be a few tens of metres apart but drive time between the two points may be in excess of 45 minutes.

Using this approach, the majority of International Sites can be scoped out, for example, the North Norfolk International Sites. This is considered reasonable as the North Norfolk Coast is a major tourist destination which receives many staying visitors. Residents from the NEGT will be likely to make a small contribution to day visitors given drive times to the coast and the proposed growth in the north of the county (North Norfolk DC, Norwich City, rest of Broadland DC, Breckland DC and Kings Lynn and West Norfolk BC). The International Sites scoped-out by these criteria are shown in Table 3.

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Table 3: The International Sites scoped-out in Stage 1 of the HRA process

Site Name Status Approx Justification distance from NE Norwich (km) SCOPED OUT Norfolk Valley Fens SAC 11 (nearest A scattered group of small component units largely component without visitor facilities likely only to be attractive to unit) residents very local to the individual sites rather than from residents of the NEGT. Buxton Heath is the nearest component unit which, aside from a small car park, lacks any facilities. Great Yarmouth SPA 26 Additional numbers of residents in the NEGT will be North Denes minor relative to proposed housing allocations of 4000 in the Great Yarmouth Borough Council area. Great Yarmouth is also a major tourist resort and so additional visitor pressure is unlikely to contribute significantly. In 2008 there were 1.3 million staying visitors and 3.7 million day visitors (GYBC 2009). The presence of the designated feature – a colony of little terns – is advertised by the local tourism website and is protected by RSPB volunteers (Enterprise GY, 2012). Paston Barn SAC 20 Distant from NEGT and unlikely to attract casual visitors; facilities include a small tea room. Overstrand Cliffs SAC 26 Distant from NEGT with designated features unlikely to attract casual visitors and largely inaccessible to the general public. Breydon Water SPA 21 Part of major tourist area but with few facilities and unlikely to attract casual visitors from the NEGT (>20km distant) and with other larger housing schemes closer in the Great Yarmouth Area and in South Norfolk District. Breydon Water Ramsar 21 Part of major tourist area but with few facilities and Ramsar unlikely to attract casual visitors from the NEGT (>20km distant) and with other larger housing schemes closer in the Great Yarmouth Area and in South Norfolk District. The Wash and North SAC 38 This SAC is mostly in the western section of the Norfolk Coast North Norfolk coast and is scoped-out on the basis of distance and that substantial parts are managed

as nature reserves with subsequent controls on impacts from visitor access. A major tourist area. Residents from the NEGT will be likely to make a small contribution to day visitors given drive times to the coast and the proposed growth in the north of the county (North Norfolk DC, Norwich City, rest of Broadland DC, Breckland DC and Kings Lynn & West Norfolk BC)

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The North Norfolk SPA A major tourist area. Residents from the NEGT will Coast be likely to make a small contribution to day visitors given drive times to the coast and the proposed growth in the north of the county (North Norfolk DC, Norwich City, rest of Broadland DC, Breckland DC and Kings Lynn & West Norfolk BC) The North Norfolk Ramsar A major tourist area. Residents from the NEGT will Coast be likely to make a small contribution to day visitors given drive times to the coast and the proposed growth in the north of the county (North Norfolk DC, Norwich City, rest of Broadland DC, Breckland DC and Kings Lynn & West Norfolk BC) Breckland SAC 36 Distant from the NEGT with available data showing some 63% of visitors from within 10km. Additional numbers of residents from NE Norwich likely to be minor relative to proposed housing allocations in the Breckland DC area. Some parts include visitor facilities but majority of site remote from facilities. Breckland SPA 36 Distant from the NEGT with available data showing some 63% of visitors from within 10km. Additional numbers of residents from NE Norwich likely to be minor relative to proposed housing allocations in the Breckland DC area. Some parts include visitor facilities but majority of site remote from facilities. Benacre to East SPA 38 Distant from the NEGT and with other larger Bavents housing schemes closer at Great Yarmouth, Lowestoft and Beccles. The HRA work for the Gt Yarmouth Core Strategy assessed the cumulative growth as not likely to cause impacts (Footprint Ecology & David Tyldesley, 2012) Benacre to East SAC 38 Distant from the NEGT and with other larger Bavents Lagoons housing schemes closer at Great Yarmouth, Lowestoft and Beccles. The HRA work for the Gt Yarmouth Core Strategy assessed the cumulative growth as not likely to cause impacts (Footprint Ecology & David Tyldesley, 2012) Redgrave & South Ramsar 39 Very small site, and distant to NGET and with little Lopham Fens attraction to casual visitors and few facilities.

Waveney and Little SAC 39 Very small component unit (Redgrave & South Ouse Valley Fens Lopham Fens), and distant to NEGT and with little attraction to casual visitors and few facilities. NOT SCOPED-OUT The Broads SAC 2.9 Part of a major tourist area, although most of the component units are distant from the NEGT and with other larger housing schemes as close or closer in the Great Yarmouth Area. However the nearest component unit is 2.6km from the NEGT so cannot be scoped out. Broadland SPA 2.9 Part of a major tourist area, although most of the component units are distant from the NEGT and with other larger housing schemes as close or

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closer in the Great Yarmouth Area. However the nearest component unit is 2.6km from the NEGT so cannot be scoped out. The Broads Ramsar Ramsar 2.9 Part of a major tourist area, although most of the component units are distant from the Growth Area and with other larger housing schemes as close or closer in the Great Yarmouth Area. However the nearest component unit is 2.6km from the NEGT so cannot be scoped out. The River Wensum SAC 6 This long linear site is relatively close to the NEGT at its southern end in comparison to other International Sites (6km). It potentially could be used for recreation although facilities are limited. It is not linked hydrologically to the application site being a separate river catchment. However given its proximity and other nearby growth (including in South Norfolk District and Norwich City) it can not be scoped out. Winterton – Horsey SAC 24 Part of a major tourist area but with very limited Dunes facilities. The site is distant from NEGT (>20km) with other larger housing schemes closer in North Norfolk DC and Great Yarmouth Areas. The HRA work for the Great Yarmouth Core Strategy concluded that it was “unlikely proposed development of such a scale as to have an effect will be sufficiently close to the site for effects to occur at significantly increased levels” (Footprint Ecology, 2012). However, a number of consultees in the current work raised concerns over this site and thus it has not been scoped-out.

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4. DESIGNATED FEATURES OF SITES NOT SCOPED-OUT

4.1 OVERVIEW OF SITES

Five sites are not scoped-out for the HRA on the basis that Component Units are potentially close enough to the NEGT and likely to attract visitors:

 The Broads SAC,  The Broads Ramsar Site,  The Broadland SPA,  The River Wensum SAC,  Winterton-Horsey Dunes SAC.

4.2 THE BROADS SAC AND RAMSAR SITE, BROADLAND SPA

The Broads International Sites are an extensive non-contiguous network of river valley habitats in east Norfolk and north Suffolk. The Broads SAC is comprised of 27 component units and the SPA of 26 component units. The Ramsar site is comprised of 28 component sites. Thus while there is considerable overlap between the international designations, not all the component units have all three designations as shown in Figure 1.

Collectively the designated features cover vegetation ‘types’, individual plant species, birds and other animals including invertebrates. The designated features are summarised as:

 Fen vegetation. Calcareous fens with Cladium mariscus and species of the Caricion davallianae; alkaline fens; Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae); transition mires and quaking bogs;  Aquatic vegetation. Hard oligo-mesotrophic waters with benthic vegetation of Chara spp.; and natural eutrophic lakes with Magnopotamion or Hydrocharition-type vegetation.  Woodland. Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae)  Plants. Fen orchid Liparis loeselii and other rare plants  Animals. Otter, Desmoulin’s whorl snail Vertigo moulinsiana, Anisus vorticulus, and other invertebrates  Birds. Overwintering species (pink footed goose Anser brachyrhynchus, wigeon Anas penelope, shoveler Anas clypeata, gadwall Anas strepera, Bewick’s swan Cygnus columbianus, whooper swan Cygnus cygnus, hen harrier Circus cyaneus, great bittern Botaurus stellaris, ruff Philomachus pugnax); overwintering assemblage; breeding birds (marsh harrier Circus aeruginosus).

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The nearest Component Unit of The Broads SAC, The Broads Ramsar site and The Broadland SPA to the NEGT is Crostwick Marsh SSSI which is less than 3km from the northern boundary. Crostwick Marsh SSSI is 11.2 hectares of unimproved meadow, species-rich fen and carr woodland and lies in the valley of Crostwick Beck which is a tributary of the River Bure about 6km south of Wroxham. In places the site is steeply sloping which has encouraged a number of intergrading vegetation types from dry calcicolus vegetation on the upper slopes to tall fen vegetation in the valley bottom. In between, there is damp grassland and species rich fen meadow. The dominant vegetation community is NVC B9: Juncus subnodulous - Circsium palustre Fen Meadow which is rare in the Broads; it is estimated that Crostwick Marsh supports roughly half the total area of this community (Doarkes, 1995).

Public access is limited to a public footpath passing through the northern section of the site. There is a small roadside parking area, estimated to be able to provide for a maximum of 6 cars. Access from nearby residential areas is not straightforward as it would have to be completed on busy roads.

4.3 RIVER WENSUM SAC

The River Wensum SAC is designated from the headwaters near Fakenham downstream to Norwich, with the designated boundary in most parts restricted to the channel and banks but including adjacent marsh and fen in some parts of the valley. The southern limit of the designation is Costessey Mill.

Collectively the designated features cover vegetation ‘types’, individual plant species, birds and other animals including invertebrates. The designated features are summarised as:

 Vegetation, both aquatic and bankside. Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae); calcareous fens with Cladium mariscus and species of the Caricion davallianae; and water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation.  Animals. White-clawed (or Atlantic stream) crayfish Austropotamobius pallipes; Desmoulin`s whorl snail Vertigo moulinsiana; brook lamprey Lampetra planeri; and bullhead Cottus gobio.

The nearest management units of the SSSI to the NEGT are the six in South Norfolk (units 38-43). Of these units, numbers 40-43 are considered by Natural England to be in unfavourable recovering condition (01 March 2013). These units are improving through restoration of the floodplain. Units 38-39 are considered to be in unfavourable, no change condition and the lack of improvement is due to their isolation from the river. The most significant impacts on the river quality relate to agricultural run-off whilst inappropriate grazing

31 of 61 HRA of NEGT AAP for BDC May 2014 v.6 regimes are the most significant factors in hindering improvements in the floodplain.

In the relevant reaches of the river, the floodplain grasslands are private and access is limited to public rights of way which are largely on the fringes of the SSSI. There are no formal facilities for public use in the area closest to the NEGT.

4.4 WINTERTON-HORSEY DUNES SAC

This is a composite site of 427 hectares amalgamated from three former separate SSSI consisting of an extensive dune system stretching along the east coast between Hemsby and Horsey. The designated features of the SAC are the dune habitats and an amphibian. Specifically these designated features are:

 Atlantic decalcified fixed dunes (Calluno – Ulicetea),  Humid dune slacks,  Embryonic shifting dunes (‘white dunes’) and  Great crested newt Triturus cristatus.

There is public access to the majority of the site with a small number of relatively small car parks and a network of both formal and informal paths, some of which shift over time.

5 STAGE 1: TESTS OF LIKELY SIGNIFICANT EFFECTS

5.1 OVERVIEW

Following the methodology described above, each component unit of the International Sites that are not scoped-out are subject to tests of likely significance. The Stage 1: Test of Likely Significant Effect considers disturbance and groundwater flows in relation to:

 The Broads SAC,  The Broads Ramsar Site,  The Broadland SPA,  The River Wensum SAC,  Winterton-Horsey Dunes SAC.

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5.2 SITE SPECIFIC TESTS OF LIKELY SIGNIFICANT EFFECTS

The Broads SAC and Ramsar Site, Broadland SPA

Groundwater flows As recognised previously, where wetland habitats or vegetation are designated features of International Sites, adverse impacts on local groundwater flows may be significant. Crostwick Marsh SSSI is the only component unit of the Broadland International Sites which is close to the NEGT (<3km of Beeston Park) and therefore potentially hydrologically linked to the north and west sections of the NEGT. It is has designated features that relate to wetland vegetation communities.

The groundwater level in much of the northern and western sections of NEGT approximately coincides with the base of the Norwich Crag and the top of the chalk and is at approximately between 15m and 20m below ground level. This is equivalent to between 8m and 15m above OD (Hydrological map BGS 1978 Northern East Anglia; 1:125,000). The direction of groundwater flow across the relevant sections of the NEGT as indicated on the map is generally from the southwest to the north-east towards a small un-named tributary of the Crostwick Beck. The tributary then flows roughly north to its confluence with Crostwick Beck some 4km to the north-east. Crostwick Marsh SSSI is 1km upstream of the confluence and 2.9km from the NEGT.

Based on the understanding of the hydrology, it is considered that the major component of the groundwater flow beneath the northern section of the NEGT will head north-east and so any surface water mixing will occur towards the un- named tributary or downstream in Crostwick Beck. Thus any infiltration resulting in groundwater recharge from the site that will reach Crostwick Beck near or upstream of Crostwick Marsh SSSI is likely to be negligible.

Policy 1 of the JCS requires development to implement sustainable drainage. Therefore all of the allocations made within the NEGT AAP will be required to have a SuDS scheme. The (draft) supporting text to policy GT 2: Green Infrastructure states: “SuDS are expected to be incorporated to all allocations within the Growth Triangle and should replicate or better existing greenfield run- off rates. Drainage strategies within the Growth Triangle should seek to utilise swales, filter strips and ponds/wetlands in preference of hard engineered solutions, as these are best placed to support biodiversity and improve water quality entering aquifers or water courses”.

The north and west sections of the NEGT generally have a thick unsaturated zone between ground surface and the groundwater table that consists of fine- grained granular soil deposits of Brickearth, Glacial Sand and Gravel, and Norwich Crag. This will provide a significant attenuation of any potential

33 of 61 HRA of NEGT AAP for BDC May 2014 v.6 contaminants in surface water run-off as it passes through an infiltration-based SuDS scheme.

It is therefore considered that there will be no significant adverse impacts on the groundwater that feeds Crostwick Marsh SSSI. Therefore it is not necessary to undertake an appropriate assessment with respect to local groundwater flows on International Sites.

The Broads SAC and Ramsar Site, the Broadland SPA

Disturbance The proximity of the Growth Triangle to the Northern Broads strongly suggests that this is the area where impacts on the integrity of the International Sites from disturbance are most likely. However, as pointed out by the Broads Authority in a formal response to HRA work (27 June 2013), it is recognised that there are ‘honey pot’ sites within the National Park with the necessary infrastructure which “are attractive and so deter people from going to protected sites”, for example Wroxham and Hoveton. The Broads Authority went on to state that “some of the most protected sites (in the Northern Broads) cannot be accessed by the public for one reason or another.” For land-based recreation, these reasons include areas where there is no public access or with access restricted to public footpaths and by impassable terrain.

However, the distribution of designated features within the International Site is wide, with some restricted to a very limited number of component units, where access is generally heavily controlled, and others occurring widely and often occurring outside the designated site boundaries. In terms of water-based recreation, it is a fair assumption that an increase in the number of residents in the greater Norwich area could lead to more recreational use of the waterways in Broads, with a possible increase in day hire boats, for example, and therefore disturbance to bank structure.

An increased usage of the Broads for recreation by Norwich residents is an ambition in the Broads Tourism Strategy (2011) and has therefore been considered in their Core Strategy and their development management policies. Nevertheless, given the substantial number of visitors and the diversity of designated features, it can not be concluded that there will be an effect on site integrity as a result of increased households in the NEGT and therefore an Appropriate Assessment is required for disturbance effects on the Broads SAC and Ramsar Site and the Broadland SPA.

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River Wensum SAC

Groundwater flows The application site is within a different river catchment and too distant to the River Wensum for there to be impacts on the groundwater flows.

Disturbance There are few visitor or recreation facilities along the River Wensum. Much of the designated area is in private ownership, with restrictions on access, fishing and canoeing. Public access to water is limited to a few locations, such as an informal access-point near The Swan public house in Ringland. Footpaths run along the banks for limited sections. Furthermore, the designated features are considered to be relatively insensitive to disturbance, requiring actual water- based recreation for impacts to occur.

Given these restrictions on public access and its low attraction to visitors, it is considered unlikely that there would be an impact on site integrity. Therefore it is considered that there is sufficient confidence for significant effects to be considered unlikely as a result of increased households in the NEGT and an Appropriate Assessment is not required for disturbance effects on the River Wensum SAC.

Winterton – Horsey Dunes SAC

Disturbance Recreation pressure on this internation site has been shown as having a deleterious effect on the dune vegetation designated features (Boorman, 1977; Anderson, 1995) and various consultees raised this issue in relation to this report. There is limited parking close to the dunes but the area is popular.

Despite the distance from the application site (>20km), the concerns raised and demonstrated impact on dune vegetation communities from recreation disturbance mean it can not be concluded that there will be not an effect on site integrity as a result of increased households in the NEGT and therefore an Appropriate Assessment is required for disturbance effects on Winterton – Horsey Dunes SAC is required.

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5.3 SUMMARY OF STAGE 1: TESTS OF LIKELY SIGNIFICANT EFFECTS

Table 4: Summary of the Stage 1 Tests of likely significant effects

Appropriate assessments Groundwater flows Disturbance The Broads SAC Not required AA necessary The Broads Ramsar Site Not required AA necessary The Broadland SPA Not required AA necessary The River Wensum SAC Not required Not required Winterton-Horsey Dunes SAC N/A AA necessary

6. STAGE 2: APPROPRIATE ASSESSMENT

6.1 THE BROADS SAC AND RAMSAR SITE, THE BROADLAND SPA

The approach taken here is to consider each of the designated features in turn and to assess identified threats. The potential impact on each designated feature as a result of the housing proposed in the NEGT is then assessed and then summarised in Table 5. The overall conclusions are then discussed.

Fen vegetation Fen vegetation communities are unlikely to be particularly attractive locations to visit for the general visitor, not least because they frequently are very wet underfoot. Similarly Cladium-dominated areas are unpleasant to walk across due to the plant’s serrated blades, many Molinia meadows can be very tussocky and alkaline fens and mires are also very wet and notoriously difficult to traverse. In addition to the inherent difficulty in walking in fen habitat, many areas with these vegetation types are on protected sites with limited/ controlled access and, although some places such as Burgh Common are accessible via public footpaths, there are limited attractions for the general visitor.

Key factors in the management of fen vegetation are grazing, cutting or other disturbance (Doarkes, 1995). Disturbance from visitors in the form of trampling is not considered as being an issue in fen management. As such it is considered unlikely that International Sites with these designated fen vegetation types will not be damaged if there were an increase in the numbers of general visitors overall to The Broads.

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Therefore it is considered that recreational disturbance will not affect the designated fen vegetation types and consequently the integrity of The Broads SAC and Ramsar Site will not be affected (Table 4).

Woodland Alluvial woodland is probably an unattractive habitat to visit being wet and frequently difficult to penetrate with a dense understorey of fallen branches and potentially nettles in drier situations. Alluvial woodland is also likely to be robust in terms of vulnerability to visitor disturbance. Extensive areas also occur in areas without public access, both within and outside the International Sites.

Thus it is considered that any increase in the numbers of visitors to The Broads will have a negligible impact on woodland habitats. As such, it is considered that recreational disturbance from increased numbers of visitors will not affect the designated woodland types, and consequently it is concluded that the integrity of The Broads SAC and Ramsar Site will not be adversely affected (Table 4).

Table 5: Summary of the Appropriate Assessment for the impact of recreation disturbance and pressure on fen vegetation in The Broads SAC and Ramsar Site.

Feature Distribution / Occurrence Impact of recreational disturbance FENS (from ELP, 2010) Alkaline fens. Ant Valley: small number of samples from Catfield No impact on Fen, Broad Fen near Dilham and Smallburgh Fen. site integrity. Bure Valley, lower: scattered samples near Horning (north bank of Bure), Horning Marshes and Barton Broad including Hall Fen. Bure Valley, upper: scattered locations, Upton Broad, Woodbastwick Fen and Marshes and Catfield Fen. Thurne Valley: scattered samples in vicinity of Hickling Broad and Horsey Mere. Waveney Valley: single sample. Yare Valley: two samples, one on Langley Fen and one on Duncan’s Marsh near Thurton Calcareous fens with Ant Valley: clusters of samples, from Horning No impact on Cladium mariscus Marshes, Reedham Marsh, Catfield Fen and site integrity. and species of the nearby areas, Barton Broad, Sutton Fen, Barton Caricion davallianae. Fen, and Common Fen and Broad Fen near Dilham. Bure Valley: clusters of samples, at Burgh Common, Decoy Carr, Upton Broad, Ward Marsh and Ranworth Marshes, Bure Marshes, Horning, Woodbastwick Fen and Marshes, and Reedham Marsh.

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Thurne Valley: Clusters of samples around Hickling Broad and its channels, Horsey Mere and Breydon Marshes, and Martham Broad. Waveney Valley: single sample, near Oulton Broad, Yare Valley: single sample on Langley Marsh, with concentrations at Rockland Marsh, Wheatfen, Strumpshaw Marsh, Surlingham Marsh and Surlingham Broad. Transition Mires and Ant Valley: mostly scattered but with apparent No impact on Quaking Bogs. concentrations at Barton Broad and Catfield Fen; site integrity. other locations are Reedham Marsh, Horning Marshes, Sutton Fen and East Ruston Allotment. Molinia meadows on Ant Valley: scattered locations, near No impact on calcareous,peaty or Woodbastwick Fen and Marshes, Catfield Fen site integrity. clayeysilt- laden and Barton Broad; soils (Molinion Bure valley: scattered locations, Burgh Common, caeruleae). Upton Broad, Ranworth Broad and Repps Level and Woodbastwick Fen and Marshes. Thurne Valley: Repps Level, Mrs Myhill’s Marsh and marshes east of Hickling Broad; Waveney Valley: small number of samples at Barnby Marsh and Fritton Marshes; Yare Valley: small number of samples from Langley marshes, Buckenham marshes, Strumpshaw Common and Strumpshaw Fen. WOODLAND (from JNCC, 2007)

Alluvial forests with The complex of sites in the Broads of East Anglia No impact on Alnus glutinosa and contains the largest blocks of alder Alnus site integrity. Fraxinus excelsior glutinosa wood in England. Within the complex (Alno-Padion, Alnion complete successional sequences occur from incanae, Salicion open water through reedswamp to alder albae). woodland, which has developed on fen peat.

AQUATIC (from JNCC, 2007) VEGETATION

Hard The core of this interest is the Thurne Broads and No impact on oligomesotrophic particularly Hickling Broad. Within the Broads site integrity. waters with benthic examples of Chara vegetation are also found vegetation of Chara within fen pools (turf ponds) and fen and marsh spp. ditch systems.

Natural eutrophic Many of the broads are examples of natural No impact on lakes with eutrophic lakes as are some ditch systems. site integrity. Magnopotamion or Hydrocharition-type vegetation.

RARE PLANTS Distribution in The Broads

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Outstanding Numerous sites No impact on assemblage of rare site integrity. plants

FEN ORCHID Distribution in The Broads

Fen orchid Liparis Three sites No impact on loeselii site integrity.

RARE Distribution in The Broads INVERTEBRATES

Outstanding Important species likely to be widespread. No impact on assemblage of rare site integrity. invertebrates DESMOULIN’S Distribution in The Broads WHORL SNAIL

Desmoulin’s whorl Ant, Thurne and Yare valleys No impact on snail, Vertigo site integrity. moulinsiana

RAMSHORN Distribution in The Broads WHIRPOOL SNAIL

Anisus vorticulus Bure and Waveney valleys No impact on site integrity.

OTTER Distribution in The Broads

Otter Probably widespread No impact on site integrity.

MARSH HARRIER Key sites in The Broads (from various sources) Marsh Harrier The population is believed to have increased Potential recently, and significantly so since the 1960s. adverse impact More precise data are not available. Foraging on site birds are seen widely throughout The Broads and integrity. adjacent areas HEN HARRIER Key sites in The Broads (from various sources; refer to text)

Hen Harrier Two well-known roosts on private farmland or Potential protected sites; other smaller roosts likely. adverse impact Approximately 35-40 wintering individuals on site integrity.

BITTERN Known breeding sites in the Broads (Wootton et al., 2011) Bittern In The Broads there have been 4 and 11 nests in No impact on each year between 2002 and 2011 with breeding site integrity. exclusively on protected sites WHOOPER and Key sites and high counts in 2010 (from NNNS,

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BEWICK SWANS 2011) Whooper Swan Ludham Bridge (10); Hickling Stubb mill (11, Jan); No impact on Stow Bardolph (12, Jan); Ludham (14, Jan); site integrity Catfield and Sutton (10, Jan); Ludham (16, Feb); Hickling Broad (12, Feb); Catfield (10, Feb); Whitlingham (35, Dec) Bewick’s Swan Ludham Bridge (153, Jan); Ludham (175); Catfield No impact on (150, Jan); Ludham (180, Feb); Horning Upper site integrity Street (231, Feb); Ludham Bridge (187, Feb); Catfield (150, Feb); Ranworth Flood / Ward Marshes (150, Feb); Ludham (183, Dec); Potter Heigham and Catfield (120, Dec); Ludham Airfield (125, Dec) WIGEON, Key sites and high counts in 2010 (from NNNS, GADWALL AND 2011) SHOVELER Wigeon Principal localities: Ranworth Broad (1763, Jan); Potential Cantley / Buckenham (4000, Dec); Notable counts adverse impact elsewhere: Mid-yare (5000, Jan); Hardley Flood on site (300, March). integrity. Gadwall Principal localities: Whitlingham (490, Jan). Potential Notable counts elsewhere: Geldeston (330, Feb); adverse impact Hoveton Park (250, Feb); Breydon / Berney (112, on site March); Hoveton Park (100, March); Cockshoot integrity. Broad (69, Sept); Stumpshaw Fen (125, Sept); Cockshoot Broad (50, Oct); Ranworth Broad (70, Oct); Strumpshaw Fen (60, Oct); Hoveton Park (50, Nov); Ranworth Broad (70, Nov); Horsey Mere (67, Dec); Hoveton Park (100, Dec); Ormesby Broad (100, Dec); Wroxham Broad (320, Dec). Shoveler Selected localities: Hickling Broad (67, Jan); Potential Breydon / Berney (568, Nov); Cantley (280, Oct); adverse impact Strumpshaw Fen (280, Oct); Notable counts: on site Ranworth Broad (40, Jan); Mid-Yare (40, Jan); integrity. Filby Broad (257, Feb); Hardley Flood (50, Aug); Ranworth Broad (47, Oct); Filby Broad (130, Nov); Ranworth Broad (98, Nov); Filby Broad (200, Dec); Ormesby Little Broad (158, Dec). RUFF Key sites and high counts in The Broads in 2010 (from NNNS, 2011) Ruff Peak counts at main sites: Breydon / Berney (56, No impact on Dec); Buckenham / Cantley (38, Sep); Hickling site integrity Broad (39, Aug) Also: Potter Heigham(6, Jan); Waxham (17, Nov); Wroxham Broad (1, Dec); Waxham (32, Oct); Strumpshaw Fen (2, Oct). PINK FOOTED Key sites and high counts in The Broads in 2010 GOOSE (from NNNS, 2011) Pink footed goose Roosts: Berney (5050, Jan 25th); Horsey (5260, No impact on Oct 11th); Berney (9000, Dec 6th); Berney (7500, site integrity

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Jan 5th); Berney (12000, Feb 21st); Berney (8400, March 1st). Feeding flocks: Breydon/Berney (2000, Jan); Haddiscoe (3000, Jan); Ludham Bridge (2250, Jan); Sea Palling (6000, Dec); East Ruston (2500, Dec) ASSEMBLAGE OF Summary of important wildfowl sites (from NNNS, WETLAND BIRDS 2011)

Overall assemblage At least 30 sites of some description considered to Potential of wetland birds be key sites or otherwise supporting noteworthy adverse impact numbers of birds. on site integrity.

Aquatic vegetation Aquatic vegetation designated features are represented in both large water bodies, namely the open broads and also smaller ditches and other pools in the northern Broads. In the past, many broads have been subjected to water pollution from agriculture and boat activity (George, 1992). In more recent times improvements in the water quality have lead to similar improvements in the conservation status of the aquatic vegetation. Two issues are considered relevant to the management of ‘oligo-mesotrophic water’. These are necessary reductions in salinity and ochre and diffuse agricultural pollution (Holman & White, 2008) and the cutting of aquatic vegetation to facilitate navigation, notably at Hickling Broad (Ledoux et al., 2000).

The first of these, the pollution impacts, are unrelated to visitor pressure. The second, the cutting of aquatic vegetation, is a specific management activity in response to current navigation demands and is scrutinised by a number of stakeholders (Ledoux et al., 2000). As such, it is considered that an increased population in north-east Norwich will not result in changes in management and an impact on site integrity (Table 5).

Rare plants Rare plants, by definition, are uncommon and many in The Broads are associated with ditches and wet and difficult terrain and largely only in protected areas (Beckett & Bull, 1999) where disturbance is tightly controlled. Thus, casual visitors are unlikely to encounter them. Management prescriptions are focussed on appropriate habitat management such as controlling water levels and flood defence rather than visitor management. As such, it is considered that recreational disturbance will not affect the abundance and distribution of rare plants and consequently the integrity of The Broads Ramsar Site will be unaffected (Table 5).

Fen orchid Fen orchid is a very small plant of limited appeal to casual visitors that occurs in a very small number of sites which are all managed as SSSIs and are not

41 of 61 HRA of NEGT AAP for BDC May 2014 v.6 advertised widely. The terrain where it occurs is wet and unattractive to general visitors and they are not easy plants to find. As such, it is considered that that recreational disturbance will not affect the abundance and distribution of fen orchid and consequently the integrity of The Broads SAC and Ramsar Site will be unchanged (Table 5).

Rare invertebrates The Ramsar citation lists the outstanding assemblage of rare invertebrates within The Broads of which the swallowtail Papilio machoan and the Norfolk hawker dragonfly Aeshna isosceles are perhaps the best known. The vast majority of other important species will only be of interest to specialists as opposed to being appealing to general visitors. As with other designated features, the vast majority of species live in key habitats that are either aquatic or in wet and difficult terrain, where recreational pressure will be low. As such, it is considered that recreational disturbance will not affect the invertebrate assemblage and consequently the integrity of The Broads Ramsar Site for this feature (Table 5).

Desmoulin’s whorl snail Vertigo moulinsiana Desmoulin’s whorl snail is a small wetland snail that lives on marginal vegetation associated with standing and flowing water and ditches. It is uncharismatic and found in wet and difficult terrain, thus unlikely to be exposed to disturbance from the general visitor. As such, it is considered that recreational disturbance will not affect Desmoulin’s Whorl Snail and consequently the integrity of The Broads SAC (Table 5).

Ramshorn whirpool snail Anisus vorticulus Anisus vorticulus is a small aquatic snail found in ditches. The majority of sites where is occurs are protected as SSSIs. It is very unlikely to be encountered by the casual visitor. It is uncharismatic and found in wet and difficult terrain, thus unlikely to be exposed to disturbance from the general visitor. As such, it is considered that Anisus vorticulus will not be affected by recreational disturbance and as such it is considered the integrity of The Broads SAC will be unaffected (Table 5).

Otter Otters are said to be sensitive to disturbance, particularly pregnant females. But provided sufficient locations for holt construction persist, then recreational impacts will be low. Within The Broads, extensive areas of undisturbed alluvial and bankside woodland, along with terrestrial woodland can provide ample locations for the construction of breeding holts. As such, it is considered that recreational disturbance will not affect otters and consequently the integrity of The Broads SAC (Table 5).

Marsh harrier Marsh harriers have made a remarkable recovery as a breeding bird during the last 50 years (Taylor and Marchant, 2001) and are now considered to be a fairly common resident, summer visitor and passage migrant and ‘increasingly

42 of 61 HRA of NEGT AAP for BDC May 2014 v.6 common throughout’ Norfolk (NNNS, 2011). This is thought that this is largely due to reduced persecution and improved habitat management.

Marsh harriers breed in reedbeds and other tall fen vegetation and increasingly in arable crops. It is known that marsh harriers tend to nest in areas with little disturbance, as recreational disturbance appears to impact on the provision of food to nestlings (Gamauf and Preleuthner, 1996; Fernandez and Azkona, 1993 so clearly there is a potential negative effect of recreational disturbance on nesting success of marsh harrier through increases from general visitors in the wider landscape. As such, it is considered that that an increase in the numbers of visitors will result in increased recreational disturbance and impacts at the population level for marsh harrier, consequently the integrity of The Broads Ramsar Site and Broadland SPA may be adversely affected (Table 5).

Hen harrier Hen harriers are designated feature for their wintering numbers. They roost gregariously in tall ground vegetation, frequently inhabiting the same site over several years, often in reedbeds and fen (Clarke & Watson, 1990). In Norfolk, the wintering population between 1999 and 2007 was considered to be 30-35 birds (Moss & Marchant, 2001) in probably seven communal roosts of which at least two were in The Broads (NNNS, 2011). There are believed to be more communal roost sites in The Broads but the locations are kept confidential. Two well known sites are protected from disturbance, a site on private farmland near Hickling, with a viewing platform accessible from the Hickling Nature Reserve (NWT), and the RSPB’s Strumpshaw Fen reserve.

It is likely that roosts are very sensitive to disturbance, but hen harriers are mobile birds and will be foraging widely away from the roost site thus it would be expected that they would be capable of moving to new roost sites if necessary. That said, communal roosts are potentially likely to attract casual visitors and disturbance at key times, such as dusk on cold nights, could be very detrimental. As such, it is considered that an increase in the numbers of visitors could result in increased recreational disturbance and consequently the integrity of The Broads Ramsar Site and Broadland SPA may be adversely affected for this feature (Table 5).

Bittern Bitterns breeding sites are restricted to areas of wet reedbed with adjoining areas for feeding including open water and field ditches. Bittern breeding numbers have been monitored nationally by the RSPB since 1990. Numbers fluctuate annually but there has been a notable increase over time (Wootton et al., 2011). Between 1998 and 2008, there have been between 1 and 21 calling (‘booming’) males but there were more than 10 in each of the years 2002 and 2011. Nesting attempts are invariably fewer than the number of calling males; in The Broads there have been 4 and 11 nests in each year between 2002 and 2011.

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Since 2002 breeding has occurred exclusively in protected sites, with nests only in quiet reedbeds away from the main navigation channels. Foraging can occur in more open and visible areas. Bittern appear very sensitive to disturbance and are more likely to be found in inaccessible areas and away from visitors. This inaccessibility should mitigate an increase in visitors since these visitors will not be able to gain access at these sites. As such, it is considered that an increase in the numbers of visitors will not result in increased recreational disturbance to bitterns and consequently the integrity of The Broads Ramsar Site and Broadland SPA will be unaffected (Table 5).

Whooper swan and Bewick’s swan In Norfolk, both Bewick’s and whooper swans are considered to be common winter visitors, but principally to the Ouse Washes where counts regularly exceed 1500 (NNNS, 2011). Both feed on wet meadows and shallow water. In The Broads area counts for Bewick’s swans average 164 individuals (range of 120- 231) and for whooper they average 15 individuals (range from 10-35). Many of the reported flocks for both species are outside of protected sites, largely on agricultural pasture and grazing marsh. Whooper swans are sensitive to disturbance (Rees et al., 2005) as are probably Bewick’s from walkers and dogs in particular. However, as with pink-footed geese (see below), it is considered that there are substantial areas of grassland away from public footpaths and roads where flocks can feed without disturbance even with an increase in the numbers of visitors; the footpaths of concern are probably likely to be unattractive to casual winter visitors. Additionally, the small size of the flocks and the overall wintering population in The Broads suggests that the fields in The Broads are unlikely to be at carrying capacity and therefore there is an even greater likelihood of flocks being able to find disturbance-free grassland. As such, it is considered that an increase in the numbers of visitors is considered unlikely to result in increased recreational disturbance and that consequently the integrity of The Broads Ramsar Site and Broadland SPA will be unaffected for this feature (Table 5).

Wigeon, gadwall and shoveler Wigeon, gadwall and shoveler are all dabbling ducks, which feed in the shallow water of lakes and flooded areas, often upending to forage vegetable matter and invertebrates (Guillemain et al., 2002). The peak numbers of birds are in winter. All three are relatively common species, distributed widely with peak counts on open water sites although some sites such as Cantley/Buckenham are thought to be on open fields. Notably, some of the sites used are known to be used regularly by water-based users (e.g. Whitlingham, Hickling and Filby), while others are free of water-based recreation or with significant restrictions on winter use (e.g. Ranworth Broad and Horsey Mere). Additional numbers of land-based visitors could impact these three species, particularly by dog walkers, and they would be vulnerable to increased levels of winter boating. Such effects have shown some duck species to be displaced at weekends when recreation is greater (Evans & Warrington, 2007). These are considered the three wildfowl

44 of 61 HRA of NEGT AAP for BDC May 2014 v.6 species most vulnerable to disturbance on the autumn and winter feeding grounds.

It is conceivable that an increased local population may result in a greater demand recreation on The Broads, with knock-on effects on these species. As such, it is considered that there may be an increase in recreational disturbance which will affect the numbers of wigeon, gadwall and shoveler and consequently the integrity of The Broads Ramsar Site and Broadland SPA for this feature (Table 5).

Ruff The ruff is a fairly common passage migrant species and winter visitor that occurs in wet fields and aquatic margins. The majority of the sites identified for the species are protected, with low numbers elsewhere. The low numbers of birds involved – especially compared to some of the other wildfowl and waders – partly reflects its transitory occurrence, to and from overwintering grounds in western Africa. It is thought unlikely that the numbers of individuals is restricted by the presence of suitable, undisturbed habitat or for recreational disturbance to be otherwise impacting the species. As such, it is considered that recreational disturbance is not currently affecting the species and that any increase is likewise unlikely to affect the species, consequently the integrity of The Broads Ramsar Site and Broadland SPA is unaffected for this feature (Table 5).

Pink-footed goose Pink-footed goose is a winter visitor with Norfolk supporting internationally important numbers. In Norfolk the species is concentrated in north-west of the county and in The Broads area including Breydon/Berney area with smaller numbers in the Yare Valley (NNNS, 2011). Although the key roost locations are largely considered to be within protected sites (in coastal grazing marsh and saltmarsh) the major feedings flocks reported are on farmland outside of protected sites.

Over-wintering pink-footed geese feed largely on sugar beet tops – which are the cut ends of sugar beet dumped in fields during the harvesting process and the flocks have been shown to be sensitive to disturbance (Gill et al., 1996). The proximity to roads and the level of traffic on roads appear to determine field usage, and presumably they are also sensitive to pedestrian disturbance. Even where the levels of traffic are low (<20 cars a day) the presence of roads has been shown to affect use by flocks (Madsen,1985); birds show disturbance distances of 500m in autumn, and 300-400m in spring.

An increase in recreation in winter has the potential to be impact pink-footed geese, principally through an increase in the numbers of walkers and dogs using public footpaths running through farmland. Although there are no data on such disturbance there are clearly substantial areas of farmland near the coast without any public footpaths and which may be assumed to be free from visitor

45 of 61 HRA of NEGT AAP for BDC May 2014 v.6 disturbance, at present and in the future. On balance, it is considered unlikely that there will be any increase in the numbers of winter visitors to farmland attributable to growth in the north-east of Norwich, due to the absence of any wider visitor facilities and very limited parking. As such, it is considered that the projected increase in the numbers of visitors will not result in increased recreational disturbance on pink-footed geese, thus the integrity of the Broadland SPA and The Broads Ramsar site will be unchanged for this feature (Table 5).

Wildfowl and waterbird assemblage: additionally including cormorant, great crested grebe, coot, bean goose, white-fronted goose, teal, pochard, tufted duck

The overall assemblage of wetland birds is important in terms of the numbers of individuals, including high numbers of common species such as coot and teal. Of the species listed under this designated feature the rarest are bean goose and white-fronted goose:

 The Taiga bean goose Anser fabialis fabialis is found in the Yare valley, with a flock of 80-150 birds.  White-fronted goose are principally at Hickling/Heigham Holmes (peak of 450 birds) and Buckenham/Cantley (a peak of 164 birds).

The number of sites supporting wildfowl is diverse and variously includes open- water sites, grazing marsh/meadow and arable crops. The important species for key or main sites as listed within NNNS (2011) are included in Table 6 including the species named in the SPA and Ramsar Site designations and also all other waders and wildfowl. The majority of the locations are more than 30 minutes travel time with the closest being on urban fringe of Norwich such as Thorpe Marshes and Whiltingham County Park.

Table 6: Summary of important sites in The Broads for wildfowl, with respect to the assemblage designation for The Broads Ramsar Site and Broadland SPA designation (Travel times are taken from the AA Routeplanner website)

Site Species Assemblages Habitat Travel time (mins) Barton Broad Greylag goose, gadwall, teal, mallard, Open water 23 garganey, pochard, tufted duck, goldeneye, cormorant and great crested grebe coot Breydon / Berney Mute swan, pink-footed goose, greylag Grazing marsh/ 32 goose, wigeon, gadwall, teal, mallard, meadow pintail, garganey, little egret and great crested grebe coot Buckenham / Greylag goose, wigeon, teal, mallard, Grazing marsh/ 30 Cantley Marshes garganey, shoveler, pochard and little meadow egret

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Calthorpe Broad Mallard Open water 30 Catfield Bewick’s swan and whooper swan Grazing marsh/ 30 meadow Chedgrave Mallard, little egret and heron Grazing marsh 28 /meadow East Ruston Pink-footed goose Arable 34 Filby Broad Goldeneye and great crested grebe. Open water 31 Haddiscoe Garganey Grazing marsh/ 36 meadow Halvergate Marshes Pink-footed goose Grazing marsh/ 30 meadow Hardley Flood Mallard Open water 29 and grazing marsh

Hickling (including Whooper swan, pink-footed goose, Open water 36 the broad and greylag goose, teal, garganey and great and grazing adjacent areas) crested grebe marsh/ meadow Horning Coot Grazing marsh/ 17 meadow Horsey Mere and Pink-footed goose, teal and mallard Open water 43 Marshes and grazing marsh/ meadow Hoveton Broads Gadwall, pochard and tufted duck Open water 16 Hoveton Hall Gadwall and moorhen Open water 14 How Hill Mallard and shoveler Open water 23 Ludham including Bewick’s swan and whooper swan Grazing marsh/ 24 Ludham Bridge and meadow Ludham Airfield Martham Broad Goldeneye Open water 34 Ormesby Broads Teal, mallard, shoveler, great crested Open water 39 grebe and coot Potter Heigham Bewick’s swan, whooper swan and Grazing marsh/ 27 greylag goose meadow Ranworth Broad and Bewick’s swan, greylag goose, wigeon, Open water 26 Flood gadwall, teal, mallard, garganey, and grazing shoveler, pochard, tufted duck, marsh/meadow

cormorant, great crested grebe & coot Rockland Broad Great crested grebe Open water 23 Rollesby Broad Shoveler Open water 32 Sea Palling Pink-footed goose Arable 40

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Strumpshaw Fen Greylag goose, gadwall, teal, mallard, Grazing 22 garganey, heron and coot marsh/meadow Thorpe Marshes Bean goose, gadwall and mallard Open water 6 and grazing marsh/meadow Walcott Pink-footed goose Arable 37 Whitlingham Whooper swan, greylag goose, gadwall, Open water 12 garganey, pochard, tufted duck, great crested grebe and coot Wroxham Broad Gadwall, pochard and tufted duck Open water 14

Although earlier assessments have considered increased recreational disturbance to birds on private farmland to be unlikely, the possible increase in both land and water-based recreation and disturbance to birds was not discounted with respect to wigeon, gadwall and shoveler. At least six of the open water sites above are thought to have wintertime boating, but with Horsey Mere and Ranworth Broad having significant restrictions on winter boating and other sites such as Hardley Flood being free of boating at all times. Horsey Mere is closed for navigation from November to February inclusive (Thurne fisheries, 2011).

As such, it is considered that there is potential for increased recreational disturbance and for this to affect individual species and the assemblage of wildfowl species, consequently the integrity of The Broads Ramsar Site and Broadland SPA may be affected (Table 5).

Conclusions of the Appropriate Assessment of disturbance on The Broads International Sites

The Appropriate Assessment of disturbance in The Broads International Sites identified the potential impacts on the designated features of breeding marsh harriers, wintering hen harriers and wintering waterfowl assemblages.

6.2 WINTERTON-HORSEY DUNES SAC

The approach taken here is to consider each of the designated features in turn and to assess identified threats. The potential impact as a result of housing in the NEGT is then assessed.

Dune vegetation Four types of dune vegetation are designated within the Winterton-Horsey Dunes SAC from the frontal edge with its embryonic dunes, the shifting dunes, decalcified dunes and the humid dunes slacks. All are potentially vulnerable to trampling damage.

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Access to the dunes is relatively limited as the dunes back onto private farmland. Public car parks are located at either end of the site. There is a small car park at the north end at Horsey Gap with a capacity for up to about 40 cars, although the capacity appears to be increasing in recent years with the track and road verge also being used, particularly at peak periods. At the southern end, approximately 500m from the village of Winterton, there is a second car park which could reasonably hold 100 cars. Parking here on the access road is prohibited by the use of double-yellow lines. The distance between the two car parks is over 5.3km and a public footpath runs between the two to the rear of the dunes. Visitors can also use the beach itself. To the north of Horsey Gap, approximately 0.5km from the north end of the designated boundary, is a small holiday park with caravans and a camp site.

Many of the visitors to Horsey Gap do so to visit the seal colony. The popularity of this activity has increased dramatically in recent years and the site is now warderned during the time the seals have pups by volunteers with the support of Natural England and others. Visitors to Winterton use its sandy beach for family activities. Generally the numbers of visitors and therefore recreation pressure is likely to be greatest near the car parks (Coombes & Jones, 2010; Coombes et al., 2009). Trampling has been unequivocally shown to damage dune vegetation, but such pressure tends to be along the well-defined paths created by visitors and away from their vicinity the impact becomes rapidly less apparent (Boorman and Fuller, 1977; Anderson, 1995). As viewed on Google Earth, paths can clearly be seen through the dune vegetation with a greater number in the vicinity of the car parks and the holiday park north of Horsey Gap; in addition to paths leading from the car park at Winterton there appear to be a significant number related to pedestrian traffic from the village. The extent and occurrence of paths at present on Winterton do not appear to differ significantly from those present in the 1970s, as compared visually to current Google Earth images and the line map in Boorman and Fuller (1977).

The car parks themselves are likely to cause local changes to the soil and vegetation through compression and dog fouling, with Shaw and Reeve (2008) showing such an effect for up to 50m from the car park. There are substantial areas of the dunes without any apparent footpaths. Thus, although trampling effects are evident at Horsey-Winterton Dunes SAC, the limited car parking space especially at Horsey Gap limits the numbers of additional visitors that can be accommodated. Even with additional visitors, it is unlikely that impacts would increase proportionately as visitors will continue to use the established paths. As such, it is considered that recreational impacts on dune vegetation will be not be attributable to growth in North-east Norwich and consequently the integrity of the Horsey-Winterton Dunes SAC is unlikely to be affected (Table 7).

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Table 7: Summary of the Appropriate Assessment for the impact of recreational disturbance and pressure on dune vegetation at Horsey-Winterton Dunes SAC Designated Feature Distribution / O Designated Feature Distribution/occurrence Impact of recreational disturbance Embryonic shifting dunes 1.7ha (0.4%) No impact on site integrity Shifting dunes along the shoreline 14.3ha (3.3%) No impact on site integrity with Ammophila arenaria (`white dunes`) Atlantic decalcified fixed dunes 28ha (6.6%) No impact on site integrity (Calluno- Ulicetea) Dunes with Hippophae rhamnoides 1.3ha (0.3%) No impact on site integrity Humid dune slacks 0.85ha (0.2%) No impact on site integrity

Great crested newt The only animal listed as a designated feature of the Horsey-Winterton Dunes SAC is the great crested newt, which breeds in the shallow ponds formed within the slacks. These ponds are unlikely to be attractive to casual visitors or particularly vulnerable to disturbance, being in the dune slack at the rear of the dunes away from the beach. The key issues in maintaining the integrity of these ponds are likely to be management and maintaining the natural processes of dune formation and succession. As such, it is considered that it is unlikely that any recreational impacts on great crested newts will be attributable to growth in North-east Norwich and consequently the integrity of the Horsey-Winterton Dunes SAC will not be affected for this feature.

Conclusions of the Appropriate Assessment of disturbance on the Winterton- Horsey Dunes International Sites

The Appropriate Assessment of disturbance in Winterton-Horsey Dunes SAC identified no significant potential impacts on the designated features of either dune vegetation or amphibians.

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6.3 SUMMARY OF STAGE 2: APPROPRIATE ASSESSMENT

The Appropriate Assessment concluded that there are potential impacts from disturbance at The Broads SAC and Ramsar Site and Broadland SPA (Table 8).

Table 8: Summary of the Stage 2 - Appropriate Assessments

Site Disturbance The Broads SAC Potential impact The Broads Ramsar Site Potential impact The Broadland SPA Potential impact Winterton-Horsey Dunes SAC No significant effect

However any impacts are likely to be very small because:

 The NEGT is not in close proximity to the majority of the component units of the Broadland International Sites, limiting the opportunities for residents to use many component sites for daily recreation, such as dog-walking. The only component units of the Broadland International sites to which the NEGT is close are the Bure Broads and Marshes SSSI (2.6km at nearest point) and the Yare Broads and Marshes SSSI (<5km) with the majority of sites much further away;  Existing ‘honey pot’ locations within the Broadland International Sites will be likely to continue to attract most visitors and existing management practices at these localities will continue to address potential impacts from visitor pressures; and  In numerical terms, potential visitors to the International Sites from developments in the NEGT will be a very small proportion of the total numbers arising from the existing population together with ‘tourist’ visitors from further afield who are being encouraged by the Tourism Strategies such as that of the Broads Authority.

Nevertheless, although likely to be very small, the potential for some impacts remains. This should be addressed through mitigation measures.

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7. MITIGATION MEASURES

A potential impact, albeit very small, has been identified on bird populations that are designated features of the Broads International Sites from disturbance as a result of increased recreation pressures from residents of the NEGT. As stated in section 1.4, there are two measures that can be used to reduce impacts: mitigation and compensation. Mitigation measures are those that an integral part of the specifications of a plan or project.

7.1 THE USE OF GREEN INFRASTRUCTURE WITHIN DEVELOPMENT SITES TO REDUCE IMPACTS ON INTERNATIONAL SITES

The HRA work for the Greater Norwich JCS (Mott Macdonald, 2010) highlighted the need for the implementation of green infrastructure developments to offset the possibility of uncertainty regarding potential in combination and cumulative effects associated with impacts on International Sites. The principle being that if attractive and accessible local opportunities for everyday recreational uses such as for dog walking are made available in, or adjacent to, the housing allocations, then there will be a reduced need for residents to visit International Sites. Additional impacts on those ecologically-sensitive sites therefore will be negligible. The Green Infrastructure Policy GT2 in the NEGT AAP further recognises this need stating “the proximity of the Growth Triangle to the Broads, where there are SAC and SPA designations, means that an increase in informal open space is necessary to mitigate additional recreational pressure from the most sensitive ecological sites” (paragraph 7.19).

The draft Green Infrastructure policy in the Development Management DPD requires that new green infrastructure across Broadland district should contribute to the achievement of 4ha of informal space per 1,000 of population. This would apply equally to development sites in the Growth Triangle as it would elsewhere in Broadland. Draft allocation policies GT5, 6, 7, 11 & 15 of the AAP set out site specific requirements in terms of large set piece facilities or specific location requirements for new open space.

In addition, draft policy GT2: Green Infrastructure requires the delivery of two primary and seven secondary GI corridors as shown on the policies map. Informal and formal open space, sports pitches, play areas, walking and cycling routes, landscaping and sustainable urban drainage systems will be located and orientated to support the delivery of the identified primary and secondary corridors. One of the primary GI corridors links to Mousehold Heath, an extensive area of open space with facilities for informal and formal recreation to the south west of the NEGT.

The amount of accessible open space within the NEGT and its locations will be critical if it is to function effectively in drawing local recreation away from the International Sites. A draft paper on Green Infrastructure in the NEGT was

52 of 61 HRA of NEGT AAP for BDC May 2014 v.6 produced by Broadland District Council (October 2013) with the aim of providing greater specificity of the GI plans for the Growth Triangle and the intended policy interventions of the AAP.

7.2 EXISTING & CONSENTED PUBLICALLY ACCESSIBLE GREEN SPACE

There is committed development that will provide green space within the NEGT and opportunities for more in future development allocations. These are discussed below. Some of these applications were not subjected to HRA.

Consented development at North Sprowston and Old Catton (Planning Application 20121516)

Mitigation measures have been consented in the form of the creation of a country park as an integral part of the application. This will be a recreational resource for future residents living within the proposed development and is specifically intended to limit the number of residents from using the Broads International Sites for ‘general’ recreation.

The country park at Beeston Park (including the nearby Red Hall Farm Park) is in the north-east section of the proposed development. In other words, it is adjacent to the eastern edge of the residential/commercial areas and situated between the proposed new houses and the northern Broads. The former 18th Century parkland is a substantial size, being more than 35ha, and currently consists of a conifer tree belt surrounding arable land. The HRA of the application (NCC August 2013) concluded that when enhanced as proposed, the scale of the country park, its location and its attractiveness will enable it to fulfil its intended function to reduce disturbance impacts on the Broads International Sites from residents of the development to negligible levels.

Consented Development at White House Farm (Planning Application 20080367)

This consent brings in to public access 315,567 m2 (or 31.5 hectares) of woodland. The Woodlands to be transferred are:

 Harrison’s Plantation/The Breck – 268,507 m2  Boar Plantation – 47,060 m2

The Section 106 requires that a Woodland Management Plan is agreed before no more than 450 homes are occupied. If retained by the owners a written agreement must be made with the Council that includes public access to/through the Woodlands, otherwise they are transferred to the District Council or a management company. The Woodlands are already accessible from existing residential areas, and close to potential development schemes in the vicinity of Salhouse Road. The White House Farm permission requires for a cycleway

53 of 61 HRA of NEGT AAP for BDC May 2014 v.6 adjacent to Blue Boar Lane to be completed by the 550th dwelling being occupied. On-site sport and open space provision also consists of 1 Neighbourhood Equipped Area for Play (NEAP), 3 Locally Equipped Areas for Play (LEAP), and 5 Local Area for Play (LAP), 1 senior football pitch, 1 junior football pitch, 2 mini pitches, and two tennis courts. This development was not subjected to a specific HRA but the open space provision exceeds the district average by some margin.

Consented development at Brook Farm (Planning Application 20090886)

The total site area of the consented development is 56 hectares, of which approximately half is given over to publically accessible open space. There are three main areas of public open space proposed:

 Between the new housing development and Thorpe End and Plumstead Road East. (This would be open parkland, crisscrossed by paths and cycleways – named by the developer as Brook Farm Meadows.)  A linear park running through the north-south valley leading to Dussindale Park. (This would have a more urban feel with housing each side.)  Neighbourhood equipped play area (NEAP) in front of the local centre. This would be a more controlled area, with an equipped children’s play area.

Even with the on-site play provision consisting of 2 Locally Equipped Areas for Play (LEAP) and 1 Multi-use Games Area (MUGA) the land for informal open space from the Brook Farm scheme can be estimated at 20 hectares. This development was not subjected to a specific HRA but, as nearly half the application site is given over to open space, it is certain that it will exceed the requirements for mitigation.

City Cycle Ambition Programme

The city cycle ambition programme seeks to deliver improvements along an 8km route between the Norfolk & Norwich University Hospital and Salhouse Road, Sprowston. The programme will deliver a high quality cycle links between potential development sites along Salhouse Road, including the consented White House Farm development, and Mousehold Heath and the City Centre.

The programme is underway and is expected to be completed by the end of 2015.

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7.3 POTENTIAL FOR NEW AND IMPROVED ACCESS TO PUBLICALLY ACCESSIBLE GREEN SPACE

There are opportunities for additional accessible green (recreation) space within NEGT.

 Draft policy GT15 of the AAP identifies an open space buffer at the northern tip of the NEGT and requires the provision of at least 30ha to be provided as public open space in addition to standard requirements for sports pitches and children’s play space. If delivered, its location, being situated between the NEGT housing and the northern Broads, should ensure a reduced temptation for residents of the new households to head towards the Broadland International Sites for their ‘everyday’ recreational activities such as dog walking. Currently it is farmland and the site will need to be made attractive to users if it is to fulfil its function. Policy requires this to be delivered in the form of acid grassland habitat or a suitable alternative which might include some woodland or parkland. In size the open space buffer is approximately the same scale as the Beeston Park Country Park approved as part of a recent permission. The HRA undertaken for that application deemed Beeston Park suitable mitigation for a considerably larger number of houses than proposed at Rackheath North and therefore a 30ha site is of a suitable scale.

 Draft Policy GT7 requires the provision of a landscaped parkland buffer to the north west of Thorpe End, a proposed buffer area is shown on the proposals map. This is approximately 11ha in size and will provide both an informal recreational resource and important Green Infrastructure connectivity.

 The smaller scale allocations, particularly in the southern section of the NEGT, will have to provide open space within their site boundaries in accordance with policy RL7 of the Broadland District Local Plan Replacement (2006), or its replacement in the form of EN3 of the draft Development Management Policies DPD. It is possible to create a connected network of small publically accessible spaces and off- carriageway walking and cycling routes through these sites, through the delivery of the GI corridors as required by draft policy GT2 of the AAP. This is supported by draft policy GT1 which requires individual development sites to work across site boundaries and site specific requirements within the draft area based policies of the AAP. A network of this type has the potential to contribute significantly to overall levels of recreation provision within the Growth Triangle. Other land designed as Reserve Sites would provides further opportunities for publically accessible open space of this kind.

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 There area a number of schemes intended to improve connectivity for non-vehicular users, such as improvements to the Norwich Cycle Network through the City Cycle Ambition Programme, Greater Norwich Infrastructure Plan (GNIP) or requirements of the draft area based policies of the AAP, which will link open space to housing areas. One such scheme is the delivery of the ‘Broadland Way’, an off-carriageway route passing through the NEGT linking the cycle network into rural roads and proving safe cycling routes for commuting and leisure use, the aspiration for which is set out in draft policy GT2 of the AAP and specific contributing infrastructure required through draft Area Based Policies GT 15, 17 & 18.

 At the southern point of the NEGT there is a pair of woodlands, Belmore Plantation and Racecourse Plantation, collectively known as Thorpe Woodlands. These privately-owned sites are designated County Wildlife Sites and are used unofficially by local people for recreation (although in the recent past, official access to parts of the woodlands was ensured through a Forestry Commission’s Woodland Grants Scheme). At various times, the owners of these woodlands have brought forward schemes that have included developing parts of the sites for housing.

 Immediately south of Rackheath lies a locally designated Historic Park & Garden related to Rackheath Hall. This area is currently privately owned with no formal public access. Home Farm, within Rackheath Park has been promoted through the AAP process on the basis that greater public access to or across the parkland could be secured through accepting limited development within the wider site. This provides a further potential area of open space within the Landscape Buffer west/south of the NDR indentified in the draft policy GT2 of the AAP.

 Policy GT2 of the AAP states that “outside of areas allocated for development, or as public open space, proposals for the provision of green infrastructure that require planning permission (such as public open space) will be permitted unless the proposal would result in significant harm in terms of biodiversity, landscape or any other material consideration”. This policy could apply to both Thorpe Woodlands and Rackheath Park.

7.4 SUMMARY OF CONSENTED AND POTENTIAL GREEN SPACE

There will be significant provision for publically accessible green space within the NEGT. Existing and consented development will deliver over 85ha of land for recreation in three large blocks containing a variety of habitats, notably parkland and woodland. The open space delivered in these consented developments

56 of 61 HRA of NEGT AAP for BDC May 2014 v.6 exceeds the mitigation requirements for the numbers of houses that will be built in them.

Clearly this does not obviate the need for open space in other sectors. A further 30ha minimum of open space to the north of the NEGT to support significant allocated development north of Rackheath is needed and it is considered very likely to be delivered if that allocation is consented.

Further open space, in accordance with the standards set out in Broadland District Council’s DM Policies DPD will have to be delivered as part of the smaller allocations in line with the policies in the JCS and the site specific requirements of the AAP.

These new areas of open space would support the delivery of the draft policy GT2: Green Infrastructure of the AAP which includes the delivery of two primary and seven secondary corridors across the AAP area.

New development is also required to provide improvements to cycling and walking connections between existing and future areas of open space. These include continued improvements to the Pink Pedalway which links the Growth Triangle to Mousehold Health and is already being significantly enhanced through the Push the Pedalways Programme which is part of the City Cycle Ambition Initiative. Mousehold Heath will be able to provide further recreational opportunities for the residents of the NEGT.

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8. REPEAT OF THE APPROPRIATE ASSESSMENT

Section 7.4 above describes the provision of significant amounts of appropriately located, publically available open space and green infrastructure that is either consented or likely to be delivered by the allocations in line with the policies in the AAP. With this high level of open space (>85ha already with consent, a further 30ha in a single block at the northern section of the Growth Triangle very likely and more delivered through smaller allocations) there will be considerable opportunities for residents of the Growth Triangle to undertake their ‘everyday’ recreational activities locally.

Thus, if policies in the AAP, or other suitable alternatives, are delivered, the level of open space will provide appropriate mitigation for potential disturbance impacts on the Broadland International Sites. Therefore it is considered that there is sufficient confidence for negative impacts on site integrity on International Sites from the development in the Growth Triangle to be considered unlikely.

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Anglian Water Services (2013), Draft Water Resources Management Plan (DWMP) Main report

Bracknell Forest Council (2011) Thames Basin Heaths Special Protection Area Avoidance and Mitigation Supplementary Planning Document Appendices

Broads Authority (2006) Appropriate Assessment of the Core Strategy – Submission Report. Under the Conservation (Natural Habitats, &C) (Amendment) (England and Wales) Regulations 2006. September 2006. Available from: http://www.broadsauthority.gov.uk/authority/consultations/core-strategy/submission- core-strategy-dpdconsultation.Html

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Broads Authority (2011) A Strategy and Action Plan for Sustainable Tourism in the Broads 2011 – 2015. Broads Authority, Norwich.

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Dolman, P., Lake, I. R. & Bertoncelj, I. (2008) Visitor Flow Rate and Recreational Modelling in Breckland. UEA, Norwich.

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Tyldesley, D. (2011) Assessing projects under the Habitats Directive: Guidance for Competent Authorities. Report to the Countryside Council for Wales, Bangor Wildfrontier (2011) Broads Authority Development Management Policies DPD. Appropriate Assessment (schedule of Proposed Minor Changes) – March 2011. Available at: http://www.broads-authority.gov.uk/broads/live/search.html

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