Habitats Regulations Assessment of the Royal Borough of Windsor and Maidenhead Local Plan

Report to Inform the HRA

March 2020

Report to Inform the HRA

LC-575 Document Control Box

Client Royal Borough of Windsor and Maidenhead Council

Report Title Report to Inform the HRA

Status Final

Filename LC-575_BLPSV-PC_Report to Inform HRA_16_230320SC.docx

Date March 2020

Author SC

Reviewed RG

Approved NJD

Photo: Virginia Water by Edmund Gall

Report to Inform the HRA of the BLPSV-PC March 2020 LC-575_BLPSV-PC_Report to Inform HRA_16_230320SC.docx

Contents 1 Introduction ...... 1 1.1 Background ...... 1 1.2 The HRA process ...... 1 2 Local Plan ...... 5 2.1 Borough Local Plan ...... 5 2.2 Background to the Local Plan development ...... 5 2.3 Local Plan policies and allocations ...... 7 2.4 Previous HRA work ...... 7 2.5 Purpose of report ...... 9 3 Methodology ...... 10 3.1 HRA guidance ...... 10 3.2 Identification of European sites ...... 10 3.3 HRA methodology ...... 11 3.4 Stage 1: Screening for likely significant effects ...... 12 3.5 What is a Likely Significant Effect? ...... 13 3.6 In-combination effects ...... 15 3.7 Case law ...... 18 3.8 Stage 2: Appropriate Assessment and Integrity Test ...... 20 3.9 Dealing with uncertainty ...... 20 3.10 The Precautionary Principle ...... 21 4 Screening ...... 22 4.1 Background ...... 22 4.2 European sites ...... 22 4.3 Ecological information ...... 25 4.4 Threats and pressures ...... 27 4.5 Screening out sites ...... 30 4.6 Air quality ...... 30 4.7 Public Access and Disturbance ...... 31 4.8 Burnham Beeches SAC - public access and disturbance screening ...... 33 4.9 Chilterns Beechwood SAC – public access and disturbance screening ...... 35 4.10 South West London Waterbodies SPA and Ramsar - public access and disturbance screening ...... 37 4.11 Thames Basin Heaths SPA - public access and disturbance screening ...... 42 4.12 Windsor Forest and Great Park SAC – public access and disturbance ...... 45 4.13 Hydrology ...... 48 4.14 Burnham Beeches SAC – hydrology screening ...... 58 4.15 Chilterns Beechwoods SAC – hydrology screening ...... 60 4.16 South West London Waterbodies SPA/Ramsar – hydrology screening ...... 61 4.17 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC – hydrology screening ...... 63 4.18 Windsor Forest and Great Park SAC – hydrology screening ...... 64 4.19 Habitat fragmentation and loss ...... 65 4.20 Burnham Beeches SAC – habitat loss and fragmentation screening ...... 66 4.21 Thames Basin Heaths SPA – habitat loss and fragmentation screening ...... 67 4.22 Thursley, Ash, Pirbright and Chobham SAC – habitat loss and fragmentation screening .... 68 4.23 Arson and Wildfire ...... 69 4.24 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC – arson and wildfire screening ...... 69 4.25 In-combination screening ...... 70 4.26 Policy screening ...... 71 4.27 Sites screening ...... 72 4.28 Screening conclusion ...... 72 5 Appropriate assessment – air quality ...... 74 6 Appropriate Assessment: Public Access and Disturbance ...... 75 6.2 Existing mitigation provided by the BLPSV-PC ...... 75 6.3 Burnham Beeches SAC ...... 77 6.4 Chilterns Beechwoods SAC ...... 79

6.5 Thames Basin Heaths SPA ...... 82 6.6 Windsor Forest and Great Park SAC ...... 83 7 Appropriate assessment – hydrology ...... 86 7.2 Existing mitigation provided by the BLPSV-PC ...... 86 7.3 South West London Waterbodies SPA and Ramsar ...... 87 7.4 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC ...... 88 7.5 Windsor Forest and Great Park SAC ...... 89 8 Next Steps ...... 91 8.1 Summary ...... 91 8.2 Next steps ...... 92

Appendix A: Policy screening Appendix B: Allocation screening Appendix C: Natural England correspondence Appendix D: Conservation objectives Appendix E: SSSI information Appendix F: European sites threats / pressures Appendix G: In-combination assessment Appendix H: Existing recreational resource in RBWM and the surrounding area Appendix I: Ricardo Energy & Environment Air Quality Report

List of Figures Figure 1.1: Stages in the Habitats Regulations Assessment...... 4 Figure 3.1: Outline of steps in stage 1; the screening process ...... 12 Figure 3.2: Outline of the in-combination pre-screening assessment methodology ...... 16 Figure 4.1: European sites considered in the HRA and overview of allocation locations...... 24 Figure 4.2: Surface Water Operational Catchment Zones within RBWM and the surrounding area. .. 50 Figure 4.3: Groundwater Catchment Zones RBWM and surrounding area...... 51

List of Tables Table 2.1: Findings of previous HRA documents prepared to support the plan-making process ...... 8 Table 3.1: Assessment and reasoning categories from Part F of the DTA Handbook ...... 13 Table 4.1: Pressures and threats for European sites that may potentially be affected by the BLPSV-PC (taken from Natural England Site Improvement Plans (SIP) and Supplementary Advice)...... 29 Table 4.2: Site allocations within 5km of the Chilterns Beechwoods SAC (Bisham Woods SSSI)...... 35 Table 4.3: Site allocations within 5km of the South West London Waterbodies SPA and Ramsar ...... 41 Table 4.4: Site allocations within 5km of the Thames Basin Heaths SPA ...... 44 Table 4.5: Site allocations within 5km of Windsor Forest and Great Park SAC ...... 46 Table 4.6: Summary of Water Quality Assessment for RBWM ...... 57 Table 4.7: Thames Basin Heaths SPA qualifying features and their suitable habitats...... 67 Table 4.8: Allocation site habitat to be lost to development ...... 67 Table 4.9: Summary of screened in policies...... 72

Acronyms

AA Appropriate Assessment AADT Annual Average Daily Traffic AIOSI Adverse Impact on Site Integrity APIS Air Pollution Information System BBOWT Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust BLP Borough Local Plan BLPSV-PC Borough Local Plan Submission Version – Proposed Changes CIC Community Interest Company CJEU Court of Justice of the European Union DfT Department for Transport DMRB Design Manual for Roads and Bridges DTA David Tyldesley and Associates EEC European Economic Community g Grams GIS Geographic Information System ha Hectares HDV Heavy Duty Vehicles HELAA Housing and Economic Land Availability Assessment HRA Habitats Regulations Assessment IRZ Impact Risk Zone IUCN International Union for Conservation of Nature JNCC Joint Nature Conservation Committee kg Kilograms km Kilometre LSE Likely Significant Effect m Metres m3 Metres cubed N Nitrogen NE Natural England

NO2 Nitrogen Dioxide NOx Nitrogen Oxides NPPF National Planning Policy Framework PRoW Public Right of Way RBMP River Basin Management Plan RBWM Royal Borough of Windsor and Maidenhead

RSPB Royal Society for the Protection of Birds SAC Special Area of Conservation SAMMS Strategic Access Management and Monitoring Strategy SANG Suitable Alternative Natural Greenspace SIP Site Improvement Plan SPA Special Protection Area SPD Supplementary Planning Document SSSI Site of Special Scientific Interest SuDS Sustainable Urban Drainage System UK United Kingdom WFD Water Framework Directive WwTW Wastewater Treatment Works μg Microgram

1.1 Background

1.1.1 Lepus Consulting has prepared this report to inform the Habitats Regulations Assessment (HRA) of the Royal Borough of Windsor and Maidenhead (RBWM) Borough Local Plan Submission Version – Proposed Changes (referred to hereafter as BLPSV-PC) on behalf of RBWM Council. The Local Plan covers the period from 2013 to 2033 and will cover the whole of the RBWM Council area (referred to hereafter as the Plan area).

1.1.2 The HRA has been prepared in accordance with the Conservation of Habitats and Species Regulations 20171 (the Habitats Regulations). When preparing development plan documents, the Council is required by law to carry out a HRA. The requirement for authorities to comply with the Habitats Regulations when preparing a Local Plan is also noted in the Government’s online planning practice guidance.

1.2 The HRA process

1.2.1 The HRA process assesses the potential effects of a plan or project on the conservation objectives of European sites designated under the Habitats2 and Birds3 Directives. These sites form a system of internationally important sites throughout Europe known collectively as the ‘Natura 2000 Network’.

1 The Conservation of Habitats and Species Regulations 2017 (2017) SI No. 2017/1012, TSO (The Stationery Office), London. 2 Official Journal of the European Communities (1992). Council Directive 92 /43 /EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora. 3 Official Journal of the European Communities (2009). Directive 2009/147/EC of the European Parliament and of the Council of 30 November 2009 on the conservation of wild birds.

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1.2.2 European sites provide valuable ecological infrastructure for the protection of rare, endangered and/or vulnerable natural habitats and species of exceptional importance within the EU. These sites consist of Special Areas of Conservation (SACs), designated under European Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive), and Special Protection Areas (SPAs), classified under European Directive 2009/147/EC on the conservation of wild birds (the Birds Directive). Additionally, paragraph 176 of the National Planning Policy Framework (NPPF)4 requires that sites listed under the Ramsar Convention (The Convention on Wetlands of International Importance, especially as Waterfowl Habitat) are to be given the same protection as fully designated European sites.

1.2.3 There is no set methodology or specification for carrying out and recording the outcomes of the HRA assessment process. The Habitats Regulations Assessment Handbook, produced by David Tyldesley Associates (referred to hereafter as the ‘DTA Handbook’), provides an industry recognised good practice approach to HRA. The DTA Handbook, and in particular ‘Practical Guidance for the Assessment of Plans under the Regulations5, which forms part F, was therefore used to prepare this report. The DTA Handbook is used by Natural England, the Government’s statutory nature conservation organisation and is widely considered to be an appropriate basis for the HRA of plans.

1.2.4 A step-by-step guide to the HRA methodology adopted in this assessment, as outlined in the DTA Handbook, is illustrated in Figure 1.1. In summary, the four key stages of the HRA process are as follows:

• Stage 1. Screening: Screening to determine if the Local Plan would be likely to have a significant effect on a European site. This stage comprises the identification of potential effects associated with the Local Plan on European sites and an assessment of the likely significance of these effects. • Stage 2. Appropriate Assessment and the ‘Integrity Test’: An assessment to ascertain whether or not the Local Plan would have a significant adverse effect on the integrity of any European site to be made by the Competent Authority (in this instance RBWM). This stage comprises an impact assessment and evaluation in view of a European site’s conservation objectives. Where adverse impacts on

4 Ministry of Housing, Communities & Local Government (2019). National Planning Policy Framework. 5 Tyldesley, D., and Chapman, C., (2013) The Habitats Regulations Assessment Handbook (September) (2013) edition UK: DTA Publications Limited. Available at www.dtapublications.co.uk

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site integrity are identified, consideration is given to alternative options and mitigation measures which are tested. • Stage 3. Alternative solutions: Deciding whether there are alternative solutions which would avoid or have a lesser effect on a European site. • Stage 4. Imperative reasons of overriding public interest and compensatory measures: Considering imperative reasons of overriding public interest and securing compensatory measures.

1.2.5 This report presents the methodology and findings of Stages 1 and 2 of the HRA process.

1.2.6 This report is structured as follows:

• Chapter 1: Introduction; • Chapter 2: BLPSV-PC; • Chapter 3: Methodology; • Chapter 4: Screening; • Chapter 5 to 7: Appropriate Assessment; and • Chapter 8: Next Steps.

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Outline of the four-stage approach to the assessment of plans under the Habitats Regulations

Article 6(3) Article 6(4) (Regulation 63 or 105) (Regulations 64 & 68 or 107 & 109)

Stage 2: Stage 4: Stage 1: Appropriate Stage 3: Imperative reasons Screening for Assessment (AA) Alternative of overriding public likely significant and the Integrity Solutions interest (IROPI) and effects Test compensatory measures

Identify underlying Is the risk and harm to Can plan be exempted, Agree the scope and excluded or eliminated? methodology of AA need for the plan? the site overridden by Gather information about Undertake AA Identify whether imperative reasons of the European sites. Apply the integrity alternative solutions public interest (taking In a pre-screening process, test, considering exist that would account of ‘priority’ check whether plan may further mitigation achieve the features where affect European sites, either where required. objectives of the plan appropriate? alone or in combination, and change the plan as far Embed further and have no, or a Identify and prepare

as possible to avoid or mitigation into plan lesser effect on the delivery of all necessary

reduce harmful effects on European site(s)? compensatory Consult statutory the site(s). body and others Are they financially, measures to protect In a formal screening Is it possible to legally and technically overall coherence of decision, decide whether feasible? Natura 2000 network plan may have significant ascertain no adverse effects on a European site. effect on integrity? Notify Government

Assessment is complete Assessment is Assessment ends IF Assessment is

IF complete IF There are alternative complete: Either

Taking no account of Taking account of solutions to the A] there are IROPI and

mitigation measures, mitigation measures, compensatory plan: the plan has no likely plan has no adverse Plan cannot be measures: Plan can be significant effect either effect on integrity of adopted without adopted alone or in combination any European site, modification B] if not, Plan cannot with plans or projects: either alone or in be adopted Plan can be adopted combination: Plan can be adopted

Figure 1.1: Stages in the Habitats Regulations Assessment6.

6 Tyldesley, D., and Chapman, C., (2013) The Habitats Regulations Assessment Handbook (October) (2018) edition UK: DTA Publications Limited. Available at www.dtapublications.co.uk

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2.1 Borough Local Plan

2.1.1 The BLPSV-PC is a plan for the future development of the local area. It will guide the location and nature of future development and inform decisions on whether or not planning applications can be granted. Once adopted the BLPSV-PC will replace the current Local Plan7 and some policies in the Maidenhead Town Centre Action Area Plan8 and will direct new development in the Borough up to 2033.

2.1.2 The BLPSV-PC identifies how much development is being planned in the borough for the period to 2033 and shows, through the spatial strategy, how this will be distributed. It includes policies on a range of issues, including natural resources, housing, economy and infrastructure, and site allocations. The BLPSV-PC has been through a number of stages in the plan-making process.

2.2 Background to the Local Plan development

2.2.1 The Regulation 18 consultation of the Local Plan aimed to engage with local residents and relevant organisations to identify how planning policy could be used to address issues within the Plan area. It also highlighted the preferred approaches to address these issues through planning policy. A consultation on the draft Local Plan was prepared in December 20179. This was supported by an HRA Screening Report10.

7 RBWM, 2003. The Royal Borough of Windsor and Maidenhead Local Plan. Available at: https://www3.rbwm.gov.uk/downloads/download/154/local_plan_documents_and_appendices 8 RBWM, 2011. Maidenhead Town Centre Area Action Plan. Available at: https://www3.rbwm.gov.uk/info/200209/planning_policy/1344/maidenhead_town_centre_area_action_plan 9 RBWM, 2017. Borough Local Plan 2013 - 2033. Regulation 18. Available at: https://www3.rbwm.gov.uk/info/201026/borough_local_plan/1349/regulation_18_consultation 10 RBWM, 2016. HRA Screening Report. Available at: http://consult.rbwm.gov.uk/portal/blp/blp/blp?tab=files

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2.2.2 At Regulation 19, the Council published the final version of the Local Plan11 for consultation. The Local Plan at this stage was supported by an updated HRA Screening Report12.

2.2.3 Following the Regulation 19 publication stage, the Local Plan, together with all supporting documents and any comments that had been received, were submitted in January 2018 to the Secretary of State for examination by an independent Inspector. These supporting documents included the above HRA Screening Reports and also an HRA Air Quality Assessment update13.

2.2.4 In 2019 the HRA work was updated in light of emerging case law14,15. This ensured that the HRA assessment was compliant with the Sweetman ‘People over Wind ruling’ in terms of the way in which it considered mitigation (refer to Box 1 for more information on this case law).

2.2.5 The Local Plan is now being independently examined by the Planning Inspector through the examination process. A series of short hearings were held in June 2018. Following these, the Council has sought to provide further information in response to issues raised during the hearings. As part of this process the Council has updated its Housing and Economic Land Availability Assessment (HELAA). The Council has subsequently reviewed and amended the housing, employment and green infrastructure allocations and modified some planning policies. Collectively, these are known as the Borough Local Plan Submission Version – Proposed Changes (BLPSV-PC). Consequently, the HRA process has been updated to assess the implications of BLPSV-PC on European sites.

11 RBWM, 2017. Borough Local Plan 2013 – 2033. Submission Version. Available at: https://www3.rbwm.gov.uk/info/201026/borough_local_plan/1348/regulation_19_publication_stage 12 RBWM, 2017. HRA Screening Report. Available at: http://consult.rbwm.gov.uk/portal/blp/blpr19/blpr19?tab=files 13 Ricardo, 2018. Habitats Regulations and Air Quality Assessment Update. Available at: https://www3.rbwm.gov.uk/info/201026/borough_local_plan/1351/submission 14 Ricardo, 2019. Habitats Regulations Screening Report. Regulation 19 Consultation. 15 Ricardo, 2019. RBWM Borough Local Plan Appropriate Assessment. Information to Inform an Appropriate Assessment (Habitats Regulations Assessment (HRA) Stage 2).

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2.3 Local Plan policies and allocations

2.3.1 The policies that form the BLPSV-PC sit under a number of themes as follows.

• Spatial strategy; • Quality of place; • Housing; • Economy; • Town centres and retail; • Visitors and tourism; • Historic environment; • Natural resources; • Environmental protection; and • Infrastructure.

2.3.2 The policies will be implemented through the delivery of a number of allocations for housing, employment and green infrastructure. Appendix B provides figures of the location of each allocation and further details.

2.4 Previous HRA work

2.4.1 Table 2.1 summarises the outcome of the HRA work that has been undertaken to date to support the plan-making process.

2.4.2 Natural England raised some concerns in relation to the outcomes of the draft HRA (dated 2017) as part of their response to the Regulation 19 publicity period for the Borough Local Plan 2013 – 2033. This led to a challenge of the soundness of the Local Plan.

2.4.3 In response, RBWM carried out further work, in the form of the Air Quality Assessment Update January 2018. A Statement of Common Ground was then agreed between Natural England and RBWM in May 2018 (provided in Appendix C). In addition, RBWM continue to work proactively on the issues raised by Natural England concerning the provision of sufficient Suitable Alternative Natural Greenspace (SANG). The Council has an adopted Supplementary Planning Document (SPD) on this matter16.

16 RBWM. July 2010. Royal Borough of Windsor and Maidenhead Local Development Framework. Thames Basin Heaths Special Protection Area Supplementary Planning Document (Part 1). Available at: https://www3.rbwm.gov.uk/download/downloads/id/3227/thames_basin_heaths_special_protection_area_spd.pd f Date Accessed: 01/10/19.

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Table 2.1: Findings of previous HRA documents prepared to support the plan-making process HRA Report Findings

HRA Screening Report The 2016 Screening Report was prepared to support a consultation December 2016 draft of the Local Plan at Regulation 18. The key issues identified Author: RBWM included fly tipping and effects on flight paths. Taking into consideration policies (such as NE2: Thames Basin Heaths Special Protection Area) and other mitigation such as Council bin collections and restrictions in regard to high rise buildings (Policy SP3: Design and Policy NE1: Nature Conservation) it was concluded that the Local Plan at that stage was unlikely to have significant effects on the integrity of designated sites, and that therefore a full Appropriate Assessment of the plan was concluded not to be required. It is noted that this screening exercise was undertaken before the 2018 ‘Sweetman ruling’ (see Section 3 for further details).

HRA Screening Report The Screening Report was prepared to support the final version of June 2017 the Local Plan at Regulation 19. Similar conclusions were drawn to Author: RBWM those outlined above for the 2016 HRA Screening Report. It is noted that this screening exercise was undertaken before the 2018 ‘Sweetman ruling’ (see Section 3 for further details).

Habitats Regulation and Air The purpose of this assessment was to evaluate the potential effects Quality Assessment Update of development on air quality within Natura 2000 sites. This was January 2018 Author: Ricardo intended to reflect developments in and the progress of the planning system in relation to air quality and, in part, to take into consideration the implications of the Sweetman ruling. The air quality modelling undertaken indicated that alone the Local Plan would have no adverse air quality impacts with the exception of a small component of the Bisham Woods SSSI, part of the Chilterns Beechwoods SAC. In-combination effects were identified as likely at the following sites: - Chilterns Beechwoods SAC - Thames Basin Heaths SPA - Thursley, Ash and Pirbright & Chobham SAC - Windsor Forest and Great Park SAC - Burnham Beeches SAC The assessment recommended that the relevant authorities work together to further investigate these impacts and develop mitigation. Habitats Regulations Screening Report. Regulation 19 Consultation. February 2019 Author: Ricardo Ricardo (2019) RBWM Borough Local Plan Update of HRA (screening and appropriate assessment) to take into Appropriate Assessment. consideration emerging case law: Sweetman ruling. Information to Inform an Appropriate Assessment (Habitats Regulations Assessment (HRA) Stage 2). February 2019 Author: Ricardo

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2.5 Purpose of report

2.5.1 The purpose of this report is to inform the HRA of this stage of the BLPSV-PC using best available information. The Council, as the Competent Authority, will have responsibility to make the Integrity Test, which can be undertaken in light of the conclusions set out in this report.

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3.1 HRA guidance

3.1.1 As noted above, the application of HRA to land-use plans is a requirement of the Conservation of Habitats and Species Regulations 2017, the UK’s transposition of European Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). HRA applies to plans and projects, including all Local Development Documents in England and Wales.

3.1.2 This report has been informed by the following guidance:

• Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites’ - European Commission, 200117; • Planning Practice Guidance: Appropriate Assessment18; • The Habitat Regulations Assessment Handbook - David Tyldesley and Associates (referred to hereafter as the DTA Handbook), 2013 (in particular Part F: ‘Practical Guidance for the Assessment of Plans under the Regulations’); and • The Appropriate Assessment of Spatial Plans in England – A Guide to How, When and Why to do it - RSPB, 200719.

3.2 Identification of European sites

3.2.1 There is no guidance that defines the study area for inclusion in HRA. Planning Practice Guidance for Appropriate Assessment (listed above) indicates that:

17 Assessment of plans and projects significantly affecting European sites. Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. European Commission Environment DG, November 2001 18 Ministry of Housing, Communities and Local Government (July 2019) Planning Practice Guidance Note, Appropriate Assessment, Guidance on the use of Habitats Regulations Assessment 19 RSPB (2007). The Appropriate Assessment of Spatial Plans in England. A Guide to How, When and Why to do it.

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3.2.2 “The scope and content of an appropriate assessment will depend on the nature, location, duration and scale of the proposed plan or project and the interest features of the relevant site. ‘Appropriate’ is not a technical term. It indicates that an assessment needs to be proportionate and sufficient to support the task of the competent authority in determining whether the plan or project will adversely affect the integrity of the site”.

3.2.3 Therefore, in order to determine a study area for the HRA, consideration has been given to the nature and extent of potential impact pathways from the BLPSV-PC and their relationship to European sites.

3.2.4 The 2016 and 2017 HRA Screening reports (see Table 2.1) consider a 5km study area from the BLPSV-PC area on the basis of identified impact pathways and previous HRA work undertaken for RBWM. These Screening Reports provided an assessment of the BLPSV-PC on seven European sites within this study area. The European sites assessed in this HRA therefore include the following:

• Burnham Beeches SAC; • Chilterns Beechwoods SAC; • South West London Waterbodies SPA; • South West London Waterbodies Ramsar; • Thames Basin Heaths SPA; • Thursley, Ash, Pirbright and Chobham SAC; and • Windsor Forest and Great Park SAC.

3.3 HRA methodology

3.3.1 HRA is a rigorous precautionary process centred around the conservation objectives of a European site's qualifying interests. It is intended to ensure that designated European sites are protected from impacts that could adversely affect their integrity, as required by the Birds and Habitats Directives. A step-by-step guide to this methodology is outlined in the DTA Handbook and has been reproduced in Figure 1.1. This report comprises Stage 1 and 2 of the HRA process.

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3.4 Stage 1: Screening for likely significant effects

3.4.1 The first stage in the HRA process comprises the screening stage. This process identifies Likely Significant Effects (LSE) of a plan or project upon a European site, either alone or in combination with other plans or projects. This stage considers the potential ‘significance’ of adverse effects. Where elements of the plan will not result in an LSE on a European site these may be screened out and not considered in further detail in the process.

3.4.2 The screening stage follows a number of steps which are outlined in Figure 3.1 below.

Outline of the steps in stage 1, the whole of the screening process

Is the plan exempt from assessment? (F.3.1)

Is the plan excluded from assessment? (F.3.2)

Can the plan obviously be eliminated from further assessment? (F.3.3)

Gathering information about the European sites potentially affected (F.4)

Checking the plan’s strategy, aims, objectives and broad options (F.5)

Pre-screening checks for likely significant effects either alone or in combination with other plans or projects and changes to the plan to avoid or reduce them (F.6)

A single, formal ‘screening’ decision for likely significant effects on European sites, alone or in combination with other plans or projects (F.7)

Preliminary consultations (F.8)

Recording the assessment (F.8)

Extract from The Habitats Regulations Assessment Handbook, www.dtapublications.co.uk © DTA Publications Limited (November 2018) all rights reserved This work is registered with the UK Copyright Service

Figure 3.1: Outline of steps in stage 1; the screening process

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3.4.3 The screening process uses a number of evaluation codes to summarise whether or not a plan component is likely to have significant effects alone or in-combination (see Table 3.1).

Table 3.1: Assessment and reasoning categories from Part F of the DTA Handbook Assessment and reasoning categories from Part F of The Habitats Regulations Assessment Handbook (DTA Publications, 2013):

A. General statements of policy / general aspirations. B. Policies listing general criteria for testing the acceptability / sustainability of proposals. C. Proposal referred to but not proposed by the plan. D. General plan-wide environmental protection / site safeguarding / threshold policies. E. Policies or proposals that steer change in such a way as to protect European sites from adverse effects. F. Policies or proposals that cannot lead to development or other change. G. Policies or proposals that could not have any conceivable or adverse effect on a site. H. Policies or proposals the (actual or theoretical) effects of which cannot undermine the conservation objectives (either alone or in combination with other aspects of this or other plans or projects). I. Policies or proposals with a likely significant effect on a site alone. J. Policies or proposals unlikely to have a significant effect alone. K. Policies or proposals unlikely to have a significant effect either alone or in combination. L. Policies or proposals which might be likely to have a significant effect in combination. M. Bespoke area, site or case-specific policies or proposals intended to avoid or reduce harmful effects on a European site.

3.5 What is a Likely Significant Effect?

3.5.1 HRA screening provides an analysis of LSEs. It considers the nature, magnitude and permanence of potential effects in order to inform the plan-making process.

3.5.2 The DTA Handbook guidance provides the following interpretation of LSEs:

3.5.3 “In this context, ‘likely’ means risk or possibility of effects occurring that cannot be ruled out on the basis of objective information. ‘Significant’ effects are those that would undermine the conservation objectives for the qualifying features potentially affected, either alone or in combination with other plans or projects… even a possibility of a significant effect occurring is sufficient to trigger an ‘appropriate assessment”20.

20Tyldesley, D. (2013) The Habitats Regulations Assessment Handbook – Chapter F. DTA Publications

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3.5.4 With reference to the conservation status of a given species in the Habitats or Birds Directives, the following examples would be considered to constitute a significant effect:

• Any event which contributes to the long-term decline of the population of the species on the site; • Any event contributing to the reduction, or to the risk of reduction, of the range of the species within the site; and • Any event which contributes to the reduction of the size of the habitat of the species within the site.

3.5.5 Rulings from the 2012 ‘Sweetman21’ case provide further clarification:

3.5.6 “The requirement that the effect in question be ‘significant’ exists in order to lay down a de minimis threshold. Plans or projects that have no appreciable effect on the site are thereby excluded. If all plans or projects capable of having any effect whatsoever on the site were to be caught by Article 6(3), activities on or near the site would risk being impossible by reason of legislative overkill”.

3.5.7 Therefore, it is not necessary for the Council to show that the BLPSV-PC will result in no effects whatsoever on any European site. Instead, the Council is required to show that the BLPSV-PC, either alone or in- combination with other plans and projects, will not result in an effect which undermines the conservation objectives of one or more qualifying features.

3.5.8 Determining whether an effect is significant requires careful consideration of the environmental conditions and characteristics of the European site in question, as per the 2004 ‘Waddenzee’22 case:

3.5.9 “In assessing the potential effects of a plan or project, their significance must be established in the light, inter alia, of the characteristics and specific environmental conditions of the site concerned by that plan or project”.

21 Source: EC Case C-258-11 Reference for a Preliminary Ruling, Opinion of Advocate General Sharpston ‘Sweetman’ delivered on 22nd November 2012 (para 48)

22 Source: EC Case C-127/02 Reference for a Preliminary Ruling ‘Waddenzee’ 7th Sept 2004 (para 48)

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3.6 In-combination effects

3.6.1 As well as considering the LSEs of the BLPSV-PC policies alone on European sites at the screening stage, it is also necessary to consider whether the effects of the policies in-combination with other plans and projects would combine to result in an LSE on any European site. It may be that the BLPSV-PC alone may not have a significant effect but could have a residual effect that may contribute to in-combination effects on a European site.

3.6.2 The in-combination assessment presented in Chapter F of the DTA Handbook comprises a ten-step approach as illustrated in Figure 3.2 below.

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Outline of the in-combination screening assessment methodology

Assembling basic information about the effects of the subject project (step 1)

Considering whether cumulative effects can be eliminated before unnecessary or abortive work is undertaken (step 2)

Can in combination effects be eliminated because the project complies with a policy framework designed to ensure that plans and projects do not have cumulative effects (step 3)?

Considering the potential for cumulative effects (step 4), including additive or synergistic effects, layering, spreading or scattering effects, increases in sensitivity or vulnerability

Identifying the type, timing and location of plans or projects that could possibly contribute to cumulative effects (step 5)

Selecting the plans and projects at the appropriate stages that could contribute to cumulative effects (step 6)

Excluding projects with potentially serious effects (step 7)

Focusing on the most influential plans and projects where necessary (step 8)

Assessing whether cumulative effects are likely to be significant (step 9)

Recording the outcome of the in-combination screening stage (step 10)

Figure 3.2: Outline of the in-combination pre-screening assessment methodology

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3.6.3 For the purpose of the HRA of the BLPSV-PC it has been determined that, due to the nature of likely impact pathways, the most relevant plans and projects for consideration in the in-combination assessment will be those that increase housing and commercial development within the study area. In addition, other plans and projects with the potential to increase traffic across the study area which may act in-combination with the BLPSV-PC, such as transport, waste and mineral plans and projects, have also been taken into consideration. Finally, plans which allocate water resources for the area have been considered.

3.6.4 The following neighbouring local authorities’ Local Plans and other relevant plans and projects and their HRA work was reviewed as part of this assessment. This reflects the scope of the in-combination assessment previously considered in the HRA process and in particular in the Air Quality Assessment Update (see Table 2.1).

• Bracknell Forest Borough Local Plan; • Chiltern and South Bucks Local Plan; • London Borough of Hillingdon Local Plan; • Reading Borough Local Plan; • Runnymede Local Plan; • Rushmoor Local Plan; • Slough Local Plan; • South Oxfordshire Local Plan; • Chiltern and South Buckinghamshire Local Plan; • Spelthorne Local Plan; • Surrey Heath Local Plan; • Surrey Waste Local Plan; • Wokingham Borough Local Plan; • Wycombe District Local Plan; • Royal Borough of Windsor and Maidenhead Local Transport Plan; • Central and Eastern Berkshire Authorities Minerals and Waste Plan; • Western Rail Link to Heathrow; and • M4 Junctions 3 to 12 Smart Motorway improvements.

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3.6.5 In terms of projects, major developments in the UK which could potentially affect European sites under consideration were identified from the National Infrastructure Planning website. All live projects were identified which were: (a) located within the HRA study area, and (b) had the potential to adversely affect one of the European sites that forms the focus of this HRA. These projects included both road and non-road strategic developments. Published information relevant to these developments was obtained from the National Infrastructure Planning website (for current and determined applications)23. In addition, the Council was consulted to determine other relevant projects for inclusion it the in-combination assessment.

3.7 Case law

3.7.1 The European Court Judgement on the interpretation of the Habitats Directive in the case of People Over Wind and Sweetman vs Colitte Teoranta (Case C-323/1724) determined that mitigation measures are only permitted to be considered as part of an Appropriate Assessment (Box 1).

Box 1: The Sweetman Case (April 2018)

A recent decision by the Court of Justice of the European Union (CJEU) People Over Wind and Sweetman v Coillte Teoranta (C-323/17) (from here on known as the ‘Sweetman Case’) has important consequences for the HRA process in the UK. In summary, the ruling reinforces the position that if an LSE is identified during the HRA screening process it is not appropriate to incorporate mitigation measures to prevent the LSE at this stage. An appropriate assessment (AA) of the potential effects and the possible avoidance or mitigation measures must be undertaken. The ‘re-screening the Plan after mitigation has been applied’ is no longer an option which would be legally compliant: “Article 6(3) of Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora must be interpreted as meaning that, in order to determine whether it is necessary to carry out, subsequently, an appropriate assessment of the implications, for a site concerned, of a plan or project, it is not appropriate, at the screening stage, to take account of the measures intended to avoid or reduce the harmful effects of the plan or project on that site.”

3.7.2 In light of the above, it is necessary to further define mitigation measures. The DTA Handbook notes that there are two types of measures as follows:

23 https://infrastructure.planninginspectorate.gov.uk/projects/ Accessed: 10.07.19 24 Available at: http://curia.europa.eu/juris/document/document.jsf?docid=200970&doclang=EN

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• “Measures intended to avoid or reduce harmful effects on a European site; or • Features or characteristics of a plan which are essential in defining the nature, scale, location, timing, frequency or duration of the plan’s proposals, or they may be inseparable aspects of the plan, without which an assessment of the plan could not properly be made, in the screening decision, even though these features or characteristics may incidentally have the effect of avoiding or reducing some or all of the potentially adverse effects of a plan”.

3.7.3 The HRA screening stage for the BLPSV-PC has not taken account of incorporated mitigation or avoidance measures that are intended to avoid or reduce harmful effects on a European site when assessing the LSEs of the BLPSV-PC on European sites. These are measures, which if removed (i.e. should they no longer be required for the benefit of a European site), would still allow the lawful and practical implementation of a plan.

3.7.4 Traffic and roads present a cross boundary issue. On 20th March 2017 a high court ruling25 found that traffic increases and subsequent air pollution on roads within 200m of a European site also requires an in- combination approach that considers the development of neighbouring and nearby authorities (Box 2).

Box 2: The Wealden Case (March 2017)

On 20th March 2017 a high court ruling found that traffic increases and subsequent air pollution on roads within 200m of an EU site requires an in-combination approach that considers the development of neighbouring and nearby authorities. This is because projects and plans that increase road traffic flow have a high likelihood of acting together, or ‘in-combination’, with other plans or projects that would also increase traffic on the same roads. If the combined effects of districts’ development will lead to increases of traffic of more than 1,000 cars a day, further consideration of the issue is required. This would be through traffic and air quality modelling. It is therefore necessary to consider the potential impact of the Plan on roads within 200m of each EU site both alone and in-combination with relevant plans and projects.

3.7.5 Consideration has therefore been given at the screening stage to LSEs of both the BLPSV-PC both alone and in-combination with other plans and projects. This approach is compliant with the Wealden Judgement.

25 Wealden District Council & Lewes District Council before Mr Justice Jay, available online at: http://www.bailii.org/ew/cases/EWHC/Admin/2017/351.html

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3.8 Stage 2: Appropriate Assessment and Integrity Test

3.8.1 Stage 2 of the HRA process comprises the appropriate assessment and integrity test. The purpose of the appropriate assessment (as defined by the DTA Handbook) is to “undertake an objective, scientific assessment of the implications for the European site qualifying features potentially affected by the plan in light of their conservation objectives and other information for assessment”.

3.8.2 As part of this process decision makers should take account of the potential consequences of no action, the uncertainties inherent in scientific evaluation and should consult interested parties on the possible ways of managing the identified adverse effects, for instance, through the adoption of mitigation measures. Mitigation measures should aim to avoid, minimise or reduce significant effects on European sites. Mitigation measures may take the form of policies within the BLPSV-PC or mitigation proposed through other plans or regulatory mechanisms. All mitigation measures must be deliverable and able to mitigate adverse effects for which they are targeted.

3.8.3 The appropriate assessment aims to present information in respect of all aspects of the BLPSV-PC and ways in which it could, either alone or in- combination with other plans and projects, affect a European site.

3.8.4 The plan-making body (as the Competent Authority) must then ascertain, based on the findings of the appropriate assessment, whether the BLPSV-PC will adversely affect the integrity of a European site either alone or in-combination with other plans and projects. This is referred to as the Integrity Test.

3.9 Dealing with uncertainty

3.9.1 Uncertainty is an inherent characteristic of HRA and decisions can be made only on currently available and relevant information. This concept is reinforced in the 7th September 2004 ‘Waddenzee’ ruling26:

26EC Case C-127/02 Reference for a Preliminary Ruling ‘Waddenzee’ 7th September 2004 Advocate General’s Opinion (para 107)

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3.9.2 “However, the necessary certainty cannot be construed as meaning absolute certainty since that is almost impossible to attain. Instead it is clear from the second sentence of Article 6(3) of the habitats directive that the competent authorities must take a decision having assessed all the relevant information which is set out in particular in the appropriate assessment. The conclusion of this assessment is, of necessity, subjective in nature. Therefore, the competent authorities can, from their point of view, be certain that there will be no adverse effects even though, from an objective point of view, there is no absolute certainty”.

3.10 The Precautionary Principle

3.10.1 The HRA process is characterised by the precautionary principle. This is described by the European Commission as being:

3.10.2 “If a preliminary scientific evaluation shows that there are reasonable grounds for concern that a particular activity might lead to damaging effects on the environment, or on human, animal or plant health, which would be inconsistent with protection normally afforded to these within the European Community, the Precautionary Principle is triggered.”

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4.1 Background

4.1.1 As noted above, the HRA has been an iterative process undertaken alongside the development of the BLPSV-PC. The outputs of this assessment have informed the plan-making process.

4.1.2 The screening stage identifies Likely Significant Effects (LSEs) of the BLPSV-PC upon European sites, either alone or in combination with other plans or projects. This section considers the potential ‘significance’ of adverse effects. Where elements of the plan will not result in an LSE on a European site these have been screened out and not considered in further detail in the HRA process.

4.2 European sites

4.2.1 Each site of European importance has its own intrinsic qualities, besides the habitats or species for which it has been designated, that enables the site to support the ecosystems that it does. An important aspect of this is that the ecological integrity of each site can be vulnerable to change from natural and human induced activities in the surrounding environment (known as pressures and threats). For example, sites can be affected by land use plans in a number of different ways, including the direct land take of new development, the type of use the land will be put to (for example, an extractive or noise-emitting use), the pollution a development generates, and the resources used (during construction and operation for instance).

4.2.2 An intrinsic quality of any European site is its functionality at the landscape ecology scale. This refers to how the site interacts with the zone of influence of its immediate surroundings, as well as the wider area. This is particularly the case where there is potential for developments resulting from the plan to generate water or air-borne pollutants, use water resources or otherwise affect water levels. Adverse effects may also occur via impacts to mobile species occurring outside a designated site, but which are qualifying features of the site. For example, there may be effects on protected birds that use land outside the designated site for foraging, feeding, roosting or other activities.

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4.2.3 The 2016 and 2017 HRA Screening Reports (see Table 2.1 for a summary) provided an assessment of adverse effects associated with the BLPSV- PC at seven European sites. The locations of these European sites are shown in Figure 4.1.

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Figure 4.1: European sites considered in the HRA and overview of allocation locations.

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4.3 Ecological information

4.3.1 The CJEU ruling in the Holohan case (C-461/1727) confirmed that appropriate assessment should: (i) catalogue (i.e. list) all habitats and species for which the site is protected and (ii) include in its assessment other (i.e. non-protected) habitat types or species which are on the site and habitats and species located outside of the site if they are necessary to the conservation of the habitat types and species listed for the protected area (Box 3).

Box 3: Holohan v An Bord Pleanala (November 2018)

“Article 6(3) of Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora must be interpreted as meaning that an ‘appropriate assessment’ must, on the one hand, catalogue the entirety of habitat types and species for which a site is protected, and, on the other, identify and examine both the implications of the proposed project for the species present on that site, and for which that site has not been listed, and the implications for habitat types and species to be found outside the boundaries of that site, provided that those implications are liable to affect the conservation objectives of the site. Article 6(3) of Directive 92/43 must be interpreted as meaning that the competent authority is permitted to grant to a plan or project consent which leaves the developer free to determine subsequently certain parameters relating to the construction phase, such as the location of the construction compound and haul routes, only if that authority is certain that the development consent granted establishes conditions that are strict enough to guarantee that those parameters will not adversely affect the integrity of the site. Article 6(3) of Directive 92/43 must be interpreted as meaning that, where the competent authority rejects the findings in a scientific expert opinion recommending that additional information be obtained, the ‘appropriate assessment’ must include an explicit and detailed statement of reasons capable of dispelling all reasonable scientific doubt concerning the effects of the work envisaged on the site concerned”.

4.3.2 This Report to Inform the HRA fully considers the potential for effects on species and habitats. This includes those not listed as a qualifying feature for the European site, but which may be important to achieving its conservation objectives. This ensures that the functional relationships underlying European sites and the achievement of their conservation objectives are adequately understood.

27 Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:62017CJ0461&from=EN

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4.3.3 Appendix D identifies the qualifying features of each of these sites and presents details of their conservation objectives. This information is drawn from the Joint Nature Conservancy Council (JNCC)28 and Natural England29.

4.3.4 SSSI are protected areas in the United Kingdom designated for conservation. SSSIs are the building blocks of site-based nature conservation in the UK. A SSSI will be designated based on the characteristics of its fauna, flora, geology and / or geomorphology. Whilst typically analogous in ecological function, the reasons for its designation can be entirely different to those for which the same area is designated as a SAC, SPA or Ramsar.

4.3.5 Natural England periodically assesses the conservation conditions of each SSSI unit, assigning it a status. SSSIs located either entirely or partially within the European sites considered in this report are listed in Appendix E along with their current conservation status. The conservation status of each SSSI highlights any SAC/SPA that is currently particularly vulnerable to threats/pressures. Conservation status is defined as follows:

• Favourable; • Unfavourable – recovering; • Unfavourable – no change; or • Unfavourable – declining.

4.3.6 SSSI units in either an ‘Unfavourable – no change’ or ‘Unfavourable – declining’ condition indicate that the European site may be particularly vulnerable to certain threats or pressures. It is important to remember that the SSSI may be in an unfavourable state due to the condition of features unrelated to its European designation. However, it is considered that the conservation status of SSSI units that overlap with European designated sites offer a useful indicator of habitat health at that location.

28 JNCC. http://jncc.defra.gov.uk/page-1458. 29 Natural England. http://publications.naturalengland.org.uk/publication.

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4.3.7 Natural England defines zones around each SSSI which may be at risk from specific types of development, these are known as Impact Risk Zones (IRZ). These IRZs are “a GIS tool developed by Natural England to make a rapid initial assessment of the potential risks to SSSIs posed by development proposals. They define zones around each SSSI which reflect the particular sensitivities of the features for which it is notified and indicate the types of development proposal which could potentially have adverse impacts. The IRZs also cover the interest features and sensitivities of European sites, which are underpinned by the SSSI designation and “Compensation Sites”, which have been secured as compensation for impacts on Natura 2000/Ramsar sites”30. The location of IRZs has been taken into consideration in this assessment as they provide a useful guide as to the location of functionally linked land and likely vulnerabilities to development proposed within the BLPSV-PC.

4.4 Threats and pressures

4.4.1 Threats and pressures to which each European site is vulnerable have been identified through reference to data held by the JNCC on Natura 2000 Data Forms, Ramsar Information Sheets and Site Improvement Plans (SIPs). This information provides current and predicted issues at each European site. The full range of threats and pressures at each European site is provided at Appendix F.

4.4.2 Supplementary advice notices prepared by Natural England provide more recent information on threats and pressures upon European sites than SIPs. Additional threats flagged up by supplementary advice notices have also been screened.

4.4.3 A number of similar threats and pressures have been considered together, for instance ‘recreation’ is considered under ‘public access and disturbance’. Furthermore, a number of threats and pressures are considered to be beyond the scope of the potential impacts of the BLPSV-PC. The following threats and pressures are, therefore, not considered further in this assessment:

• Deer; • Forestry and woodland management; • Feature location/ extent/ condition unknown;

30 Natural England. 2018. User Guide. Available at: https://magic.defra.gov.uk/Metadata_for_magic/SSSI%20IRZ%20User%20Guidance%20MAGIC.pdf

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• Disease; • Changes in species distribution; • Undergrazing; • Inappropriate scrub and weed control; • Natural changes to site conditions; • Invasive species; • Species decline; • Changes in land management; • Fisheries: Fish stocking; • Military; • Abiotic (slow) natural processes; • Changes in biotic conditions; • Grazing; • Interspecific floral relations; and • Problematic native species.

4.4.4 Following a review of HRA work undertaken to date for the BLPSV-PC (see Table 2.1), the remaining threats and pressures that were considered to be within the scope of influence of the BLPSV-PC are summarised in Table 4.1 and include:

• Air Pollution: impact of atmospheric nitrogen deposition; • Public access and disturbance (to include outdoor sports and leisure activities, recreational activities and other human intrusions and disturbances); • Hydrological changes (to include water quality and quantity); • Habitat fragmentation and loss; and • Wildfire / arson.

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Table 4.1: Pressures and threats for European sites that may potentially be affected by the BLPSV- PC (taken from Natural England Site Improvement Plans (SIP) and Supplementary Advice). Pressures/ threats Habitat Public access/ Hydrological Wildfire and European sites Air Pollution fragmentation / disturbance changes arson loss All qualifying Burnham All qualifying All qualifying features All qualifying

Beeches SAC31 features (SIP) features (SIP) (Supplementary features (SIP) advice) S1083 Stag Chilterns All qualifying S1083 Stag beetle Beechwoods features (SIP) beetle (SIP) (Supplementary SAC32 advice) South West All qualifying All qualifying London features All qualifying features

Waterbodies (Supplementary features (SIP) (Supplementary SPA33 advice) advice) South West London

Waterbodies Ramsar34 H4010 Wet heathland with cross-leaved Thames Basin All qualifying All qualifying All qualifying All qualifying heath, H7150 Heaths SPA35 features (SIP) features (SIP) features (SIP) features (SIP) Depressions on peat substrates (SIP) H4010 Wet heathland with Thursley, Ash, cross-leaved All qualifying All qualifying All qualifying Pirbright & heath, H7150 features (SIP) features (SIP) features (SIP) Chobham SAC36 Depressions on peat substrates (SIP) H9120 Beech H9120 Beech H9120 Beech forests on acid forests on acid Windsor Forest forests on acid soils, H9190 Dry soils, H9190 Dry & Great Park soils, H9190 Dry oak-dominated oak-dominated SAC37 oak-dominated woodland woodland woodland (SIP) (Supplementary (Supplementary advice) advice)

31 JNCC (2015), Natura 2000 Standard Data Form: Burnham Beeches. Natural England (2015) Site Improvement Plan: Burnham Beeches 32 JNCC (2015), Natura 2000 Standard Data Form: Chilterns Beechwoods. Natural England (2015) Site Improvement Plan: Chilterns Beechwoods 33 JNCC (2015), Natura 2000 Standard Data Form: South West London Waterbodies. Natural England (2014) Site Improvement Plan: South West London Waterbodies 34 JNCC (2015), Natura 2000 Standard Data Form: South West London Waterbodies. Natural England (2014) Site Improvement Plan: South West London Waterbodies 35 JNCC (2015), Natura 2000 Standard Data Form: Thames Basin Heaths. Natural England (2014) Site Improvement Plan: Thames Basin Heaths 36 JNCC (2015), Natura 2000 Standard Data Form: Thursley, Ash, Pirbright & Chobham. Natural England (2014) Site Improvement Plan: Thursley, Ash, Pirbright & Chobham 37 JNCC (2015), Natura 2000 Standard Data Form: Windsor Forest & Great Park. Natural England (2014) Site Improvement Plan: Windsor Forest & Great Park

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4.5 Screening out sites

4.5.1 For the seven European sites set out in Table 4.1, the screening stage has considered LSEs on each European site in the context of the threat and pressure identified above. The results of the screening assessment are set out in further detail below by topic.

4.5.2 Whilst the Ramsar information sheet identifies no adverse ecological impacts for South West London Waterbodies Ramsar, the site will still be considered in this report as current threats and pressures were identified in the SIP for South West London Waterbodies SPA.

4.6 Air quality

4.6.1 Air pollution can affect European sites if it has an adverse effect on its features of qualifying interest. The main mechanisms through which air pollution can have an adverse effect is through eutrophication (nitrogen), acidification (nitrogen and sulphur) and direct toxicity (ozone, ammonia and nitrogen oxides)38. Deposition of air pollutants can alter the soil and plant composition and species which depend upon these.

4.6.2 As noted in Table 4.1 air pollution, and in particular atmospheric nitrogen deposition, has been identified as a threat or pressure for qualifying features of the following European sites within the relevant SIPs:

• Burnham Beeches SAC; • Chilterns Beechwoods SAC; • Thames Basin Heaths SPA; • Thursley, Ash, Pirbright & Chobham SAC; and • Windsor Forest & Great Park SAC.

4.6.3 In addition, a review of supplementary advice on conserving and restoring site features prepared by Natural England indicates that features within the South West London Waterbodies SPA are also sensitive to changes in air quality, in particular, in shallow areas where the majority of water supply is derived from rainfall39.

38 APIS. http://www.apis.ac.uk/ecosystem-services-and-air-pollution-impacts. [Date Accessed: 06.07.19]. 39 Natural England. 2018. European Site Conservation Objectives: Supplementary Advice on Conserving and Restoring Site Feature. South West London Waterbodies Special Protection Area (SPA) Site code: UK9012171. http://publications.naturalengland.org.uk/publication/4901473695563776 Available at: [Date Accessed: 02/10/19].

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4.6.4 An assessment of air quality impacts was undertaken in 2020 by Ricardo Energy & Environment. This assessment is reported upon in the Air Quality Habitats Regulations Assessment for RBWM BLPSV-PC Housing Allocation Review Report40. The Air Quality Report is provided at Appendix I. The air quality work was undertaken in two parts to reflect the requirements of the HRA process (Figure 1.1); screening (Part 1) and appropriate assessment (Part 2). The detailed methods and conclusions of the Air Quality report are not repeated within this report.

4.6.5 The Air Quality report screened in LSEs associated with air pollution as a result of the BLPSV-PC alone or in-combination at the following sites:

• Chiltern Beechwoods SAC; • South West London Waterbodies SPA and Ramsar; • Thames Basin Heaths SPA; • Thursley, Ash, Pirbright and Chobham SAC; and • Windsor Forest and Great Park SAC.

4.6.6 These sites were therefore considered further in the HRA process within the Air Quality report’s appropriate assessment.

4.7 Public Access and Disturbance

4.7.1 As noted in Table 4.1, public access and associated disturbances has been identified as a threat or pressure for qualifying features of the following European sites within the relevant SIPs:

• Burnham Beeches SAC; • Chilterns Beechwoods SAC; • South West London Waterbodies SPA; • South West London Waterbodies Ramsar; and • Thames Basin Heaths SPA.

40 Ricardo Energy & Environment. March 2020. Air Quality Habitat Regulations Assessment for RBWM BLPSV-PC Housing Allocation Review. ED13199100. Issue Number 6.

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4.7.2 In addition, a review of supplementary advice on conserving and restoring site features prepared by Natural England indicates that features within Windsor Forest and Great Park SAC are also sensitive to public access and disturbance threats, in particular, due to soil compaction around ancient trees from recreation related footfall and from illumination impacts41.

4.7.3 Public access / disturbance can take a number of forms. Physical disturbance as a result of urbanisation may include damage to habitats through erosion, troubling of grazing stock, causing changes in behaviour to animals such as birds at nesting and feeding sites, spreading invasive species, litter and fly-tipping, tree climbing, wildfire and arson, noise and light pollution and vandalism. Typically, disturbance of habitat and species is the unintentional consequence of people’s presence which can impact breeding success and survival. In particular, problems can be associated with dogs and cats, such as predation, disturbing birds and dog fouling.

4.7.4 The Thames Basin Heaths Special Protection Area Delivery Framework42 makes recommendations for accommodating development while also protecting the SPA's features of interest. This includes the recommendation of implementing a series of zones within which varying constraints would be placed upon development. The zone extending 400m from the SPA boundary concerns urbanisation (particularly predation of the chicks of ground-nesting birds by domestic cats). The delivery plan concludes that the adverse effects of any net increase in residential development located within 400m of the SPA boundary could not be mitigated since this was the range within which cats could be expected to roam as a matter of routine and there was no realistic way of restricting their movements. As such, no new housing is to be located within this zone.

41 Natural England. 2019. European Site Conservation Objectives: Supplementary Advice on Conserving and Restoring Site Feature. Windsor Forest and Great Park (SAC) Site code: UK0012586. http://publications.naturalengland.org.uk/publication/5175000009015296 Available at: [Date Accessed: 02/10/19]. 42 Thames Basin Heaths Joint Strategic Partnership Board (2009). Thames Basin Heaths SPA Delivery Framework. https://www.bracknell-forest.gov.uk/sites/default/files/documents/thames- basin-heaths-spa-delivery- framework.pdf. [Date Accessed: 08/08/19].

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4.7.5 In terms of recreational impacts, the Thames Basin Heaths SPA Delivery Framework states that within a 400m to 5km zone from the perimeter of a European Site, avoidance measures are considered necessary to avoid recreational impacts. It also notes that applications for large scale development (i.e. those comprising more than 50 houses which are located between 5-7km from the edge of the European site) would be considered on a case-by-case basis. Whilst it is recognised that the European sites considered in this report, with the exception of the Thames Basin Heaths SPA itself, are designated for site specific qualifying features which do not reflect those for which the Thames Basin Heaths SPA has been designated, the Delivery Framework provides a conservative guide to the likely buffer zone within which public access and disturbance impacts can be experienced. Where other bespoke buffer zones are available for European sites these distances have been applied in lieu of the Thames Basin Heaths Delivery Framework.

4.7.6 Whilst employment allocations set out in the BLPSV-PC are located within 5km of a European site, the closest allocation is situated over 3.8km from the closest European site (Site AL14 is located 3.89km to the north west of Windsor Forest and Great Park SAC). Given this distance, it is reasonable to assume that workers would not access European sites for recreational purposes during coffee and lunch breaks. Recreational impacts from employment sites are therefore not considered further in this assessment.

4.8 Burnham Beeches SAC - public access and disturbance screening

4.8.1 Burnham Beeches is owned jointly by the City of London and the Portman-Burtley Estate and comprises 220ha of public open space, with the remaining 160ha being mainly in private ownership, along with a small section owned by the National Trust and a very small private garden. The area surrounding the site is heavily urbanised and densely populated with Beaconsfield and Gerrards Cross to the north and Slough and Burnham to the south.

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4.8.2 A report undertaken by Footprint Ecology in support of the HRA that was produced for the Chiltern and South Bucks Local Plan 203643,44 notes that, in terms of spatial planning and recreational impacts to Burnham Beeches SAC, consideration should focus on all development in areas directly adjacent to the SAC and within a 5.6km radius. It recommends that no development which would result in a net increase in housing takes place within 500m of this SAC. The Chiltern and South Bucks HRA concludes that any additional development within 5.6km of Burnham Beeches SAC is likely to result in a level of additional recreational visits which, without mitigation, would adversely affect the SAC.

4.8.3 One allocation in the BLPSV-PC (Site AL38, Land East of Strande Park, Cookham for 20 dwellings) is located within 5.6km of this buffer zone. It is situated approximately 5.5km to the west of Burnham Beeches SAC.

4.8.4 There are no allocations located within 500m of Burnham Beeches SAC, and therefore, it is considered unlikely that LSEs associated with urbanisation (lighting, noise, fly tipping etc.) will occur at this SAC.

4.8.5 Given the level of housing proposed at Site AL38 (20 dwellings) it is unlikely that the BLPSV-PC will have adverse impacts at Burnham Beeches SAC alone. However, it is concluded that a potential LSE in- combination with other plans and projects, in particular the proposals in the Chiltern and South Bucks Local Plan (see the in-combination assessment in Appendix G), in terms of recreational impacts at Burnham Beeches SAC may occur. This site has therefore been screened in for further assessment in the HRA process in terms of public access and disturbance.

43 Lepus Consulting. June 2019. Habitats Regulation Assessment of the Chiltern and South Bucks Local Plan. Available at: https://www.southbucks.gov.uk/planning/sustainability 44 Liley, D. (13.08.2019). Final. Impacts of urban development at Burnham Beeches SAC: update of evidence and potential housing growth, 2019. Unpublished report by Footprint Ecology for Chiltern and South Bucks Councils.

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4.9 Chilterns Beechwood SAC – public access and disturbance screening

4.9.1 Public access and associated disturbances have been recognised as a threat to the habitat and populations of stag beetle (Lucanus cervus) that are associated with Chilterns Beechwoods SAC. This is due to the removal of dead wood either by the public or in the name of safety or tidiness45.

4.9.2 Chilterns Beechwoods SAC comprises nine separate sites scattered throughout the Chilterns AONB. It is estimated that over 55 million visits were made to these sites in 200746. Despite the high visitor numbers, of the 29 SSSIs that intersect with the Chilterns Beechwoods SAC, 23 are in a ‘Favourable’ state of conservation whilst the remaining eight are in a state of ‘Unfavourable – recovering’ (Appendix E).

4.9.3 Two components of the Chilterns Beechwoods SAC lie within 5km of the BLPSV-PC boundary. These include Bisham Woods SSSI, which lies within the Plan area and Hollowhill and Pullingshill Woods SSSI, which lies approximately 1.4km to the north west of the Plan area. Only Bisham Woods SSSI is located within 5km of a BLPSV-PC allocated site. Allocations within 5km of the Chiltern Beechwoods SAC are shown in Table 4.2.

Table 4.2: Site allocations within 5km of the Chilterns Beechwoods SAC (Bisham Woods SSSI). Approximate distance from Site Allocation (code and Chilterns Beechwoods SAC Proposed development name) (Bisham Woods SSSI) Site AL37: Land north of Lower 1.6km 200 residential units Mount Farm, Long Lane, Cookham. Site AL36: Cookham Gas 1.7km 50 residential units holder, Whyteladyes Lane, Cookham. Site AL38: Land east of Strande 2.3km 20 residential units Park, Cookham.

Site AL25: Land known as 2.9km 330 residential units Spencer's Farm, North of Lutman Lane, Maidenhead. Site AL23: St. Marks Hospital, 3.0km 54 residential units Maidenhead.

45 Natural England. 2015. Site Improvement Plan Chilterns Beechwoods SAC. Available at: http://publications.naturalengland.org.uk/publication/6228755680854016 [Date Accessed: 09.10.19]. 46 Chilterns AONB (2007) www.chilternsaonb.org

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Approximate distance from Site Allocation (code and Chilterns Beechwoods SAC Proposed development name) (Bisham Woods SSSI) Site AL12: Land to east of 5.0km 50 residential units Braywick Gate, Braywick Road, Maidenhead. Site AL2: Land between High 5.0km Mixed use scheme with 300 Street and West Street, residential units Maidenhead. Site AL5: West Street. 4.4km Mixed use scheme with 240 residential units

Site AL9: Saint-Cloud Way. 4.4km Mixed use scheme with 550 residential units

Site AL1: Nicholsons Centre, 4.3km 22,000sqm of employment Maidenhead. space and 500 residential units

Site AL3: St Mary’s Walk, 4.4km Mixed use scheme with 120 Maidenhead. residential units

Site AL4: York Road. 4.5km Mixed use scheme with 450 residential units

Site AL7: Maidenhead Railway 4.6km Mixed use scheme for Station. 7,000sqm of employment space and 150 residential units

Site AL13 Desborough, Harvest 4.7km 2600 residential units Hill Road, South West Maidenhead. (the northern section of this site only). Site AL10: Stafferton Way Retail 4.8km Mixed use with 350 residential Park, Maidenhead. units

4.9.4 Bisham Woods SSSI comprises an extensive area of predominantly broad-leaved woodland situated on a steep north-west facing slope overlooking the River Thames at Marlow47. The SSSI consists of two units, one of which is classed as ‘Favourable’ and the second classified as ‘Unfavourable – Recovering’. The ‘Unfavourable – Recovering’ status is due to historical storm damage (in 1987 – 1990) and does not relate to human disturbance or removal of dead wood48.

47 Natural England. SSSI Citation. https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/1002835.pdf [Date Accessed: 09.10.19]. 48 Natural England. Condition of SSSI Unit for Bisham Woods SSSI. https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1002835&ReportTitle=Bisham %20Woods%20SSSI [Date Accessed: 09.10.19].

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4.9.5 The supplementary advice for the Chilterns Beechwoods SAC states that illumination from artificial lighting can have an LSE on natural phenological cycles and processes to the detriment of the H9130 (Beech forests on neutral to rich soils) and its typical species. However, given the distance of the BLPSV-PC allocations from Chilterns Beechwoods SAC (the closest being 1.6km to the south east, close to Cookham Rise), it is considered unlikely that LSEs associated with urbanisation (lighting, noise, fly tipping etc) will occur.

4.9.6 Due to the location of BLPSV-PC allocations in relation to the Chilterns Beechwoods SAC (i.e. within 5km) it is concluded that the BLPSV-PC has the potential to increase visitor numbers to the SAC both alone and in- combination with other plans and projects. An LSE as a result of development set out within the BLPSV-PC has therefore been screened in for further assessment in the HRA process in terms of public access and disturbance.

4.10 South West London Waterbodies SPA and Ramsar - public access and disturbance screening

4.10.1 The South West London Waterbodies SPA comprises a series of embanked water supply reservoirs and former gravel pits which support a range of man-made and semi-natural still, open-water habitats. The complex is situated on the broad floodplain of the River Thames49.

4.10.2 All qualifying features of South West London Waterbodies SPA and Ramsar, namely the habitats and non-breeding populations of Gadwall (Anas strepera) and Northern Shoveler (Anas clypeata), are recognised as being under threat from public access associated disturbances.

4.10.3 A key environmental condition of South West London Waterbodies SPA and Ramsar is a lack of disturbance during the winter months of October to March. Disturbances of sufficient extent, intensity or duration can cause the Gadwall and Shoveler populations to abandon the site.

49 Natural England. 2018. European Site Conservation Objectives: Supplementary Advice on Conserving and Restoring Site Features. South West London Waterbodies Special Protection Area (SPA) Site code: UK9012171. Available at: http://publications.naturalengland.org.uk/publication/4901473695563776. [Date Accessed: 10.10.19].

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4.10.4 Impacts associated with recreational disturbances vary between locations, seasons, species and individuals. Impacts may be direct, such as birds being forced to flee oncoming boats, or indirect, such as the destruction of habitats. Disturbances may lead to behavioural changes, such as the avoidance of particular areas or changes to feeding habits, and physiological changes, such as quicker heartbeat rates. Whilst recreational activities are reduced during winter, food is scarce at this time of year and so interruptions to foraging birds can be particularly damaging.

4.10.5 The adverse effects of unnecessary expenditure of energy by birds flying away from oncoming threats, coupled with the reduction in their intake of energy as a result of less time spent foraging, can be significant for the balance between birth/immigration and death/emigration.

4.10.6 Different waterbodies of the site offer different levels of access to the public, with some more restricted than others. Any operations that may undermine the integrity of the SSSIs require consent from Natural England.

4.10.7 South West London Waterbodies SPA and Ramsar are underpinned by a number of SSSIs. Wraysbury No. 1 Gravel Pit SSSI and Wraysbury and Hythe End Gravel Pits SSSI are located within the Plan area. Wraysbury Reservoir SSSI and Staines Moor SSSI are located immediately adjacent, but outside the Plan area. Thorpe Park Number 1 Gravel Pit SSSI, Kempton Park Reservoirs SSSI and Knight and Bessborough Reservoirs SSSI are located approximately 3.1km, 8.9km and 9.8km respectively to the south and south east of the Plan area.

4.10.8 Wraysbury No.1 Gravel Pit SSSI is a lowland lake that was excavated in the 1950s and is now almost fully mature, with most of the lake margins dominated by trees and scrub50. Consultation with Natural England indicates that this lake is privately owned by RK Leisure for fishing and has controlled access around its perimeter in the form of security fencing.

50 Natural England. Wraysbury Gravel Pit SSSI Citation. Available at: https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/2000381.pdf [Date Accessed: 10.10.19].

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4.10.9 Wraysbury and Hythe End Gravel Pits SSSI comprise a mosaic of open water, islands, grassland, scrub and woodland within an area of former gravel extraction51. It comprises a number of lakes under various ownerships. Consultation with Natural England indicates that Wraysbury No.2 Gravel Pit SSSI is under the same ownership as Wraysbury No 1. Gravel Pit SSSI (RK Leisure). There is limited public access to a small section of the lake edge where Wraysbury No. 7 Public Right of Way (PRoW) runs for approximately 280m along its northern perimeter. Natural England noted that the southern lake, known as Silverwings, is owned and managed by Affinity Water. It offers facilities for a private sailing club (Silverwings Sailing Club) and has secure fencing around its perimeter.

4.10.10 Wraysbury Reservoir SSSI is an artificially embanked reservoir constructed around 197052. Consultation with Natural England and a review of aerial photography indicates that this reservoir is managed by Thames Water and fenced (with a secure palisade fence). There is no access for recreational purposes due to health and safety considerations.

4.10.11 Staines Moor SSSI is part of the Colne Valley Regional Park, a 27,000 acre park managed by the Community Interest Company (CIC). The objectives of the CIC include safeguarding, conserving and enhancing the local landscape, countryside and biodiversity of the Park. This SSSI comprises three waterbodies; the two reservoirs which comprise Staines Moor Reservoir, and a third which comprises St George VI Reservoir, each of which is managed by Thames Water. A review of aerial photography indicates that these sites are secured for health and safety purposes with high level security fencing.

4.10.12 Thorpe Park No.1 Gravel Pit SSSI is in the immediate vicinity of Thorpe Park Resort. Public access is limited and therefore recreational pressure is thought unlikely to increase as a result of the BLPSV-PC alone or in combination.

51 Natural England. Wraysbury and Hythe End Gravel Pit SSSI Citation. Available at: https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/1004168.pdf [Date Accessed: 10.10.19]. 52 Natural England. Wraysbury Reservoir SSSI Citation. Available at: https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/2000374.pdf [Date Accessed: 10.10.19].

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4.10.13 Kempton Park Reservoirs are not open to the public and locked fencing surrounds the site.

4.10.14 Knight and Bessborough Reservoirs and Wraysbury Reservoir are operational sites belonging to Thames Water and public access is limited. At Knight and Bessborough Reservoirs, a total of ten permits are available to bird watchers from recognised clubs.

4.10.15 There are a range of recreational activities available across the waterbodies. The effect of multiple and varied disturbances from different sources may have a cumulative effect on birds. Unlike many waterbodies, zonation of the reservoirs of South West London Waterbodies SPA and Ramsar has generally not occurred53.

4.10.16 Birds are more able to habituate to frequent and benign events, such as being interrupted by visitors, than major events such as disturbances by aeroplanes54. The qualifying features of the SPA (A051(NB) Gadwall, A056(NB) Shoveler) which are noted to be vulnerable to the impacts of public access and disturbance in the SIP are not considered to be highly sensitive to public disturbance and are readily able to habituate to the presence of shore-based human recreational activities without being disturbed. By comparison water-based activities may be a potential source of disturbance.

4.10.17 As shown in Table 4.3, Wraysbury No. 1 Gravel Pit SSSI, Wraysbury and Hythe End Gravel Pits SSSI, Wraysbury Reservoir SSSI and Staines Moor SSSI are located within 5km of allocations set out in the BLPSV-PC. All other areas of the South West Waterbodies SPA and Ramsar are located more than 5km from the closest allocation, and therefore, are not considered further in this assessment.

53 Briggs, B. (2007) The use of waterbodies in South-West London by Gadwall and Shoveler; implications for nature conservation. Degree of Doctor in Philosophy in Biological Sciences Thesis submitted to University of Oxford Department of Zoology 54 Hill, D., Hockin, D., Price, D., Tucker, G., Morris, R., & Treweek, J. (1997). Bird disturbance: improving the quality and utility of disturbance research. Journal of Applied Ecology, 275-28

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Table 4.3: Site allocations within 5km of the South West London Waterbodies SPA and Ramsar Approximate distance from Site Allocation (code and South West London Proposed development name) Waterbodies SPA and Ramsar Site AL40: Land east of Queen Wraysbury No. 1 Gravel Pit SSSI Residential development for Mother Reservoir, Horton. 2.2km to the south. 100 units.

Wraysbury and Hythe End Gravel Pits SSSI 2.9km to the south. Wraysbury Reservoir SSSI 1.5km to the south. Staines Moor SSSI 3.4km to the south.

Site AL39: Land at Riding Court Wraysbury No. 1 Gravel Pit SSSI Residential development for 80 Road and London Road 2km to the south. units. Datchet Wraysbury and Hythe End Gravel Pits SSSI 3.4km to the south. Wraysbury Reservoir SSSI 3.3km to the south.

Site AL30: Windsor and Eton Wraysbury No. 1 Gravel Pit SSSI Residential development for 30 Riverside Station Car Park. 3.8km to the north west. units.

Wraysbury and Hythe End Gravel Pits SSSI 4.9km to the north west.

Site AL29: Minton Place, Wraysbury No. 1 Gravel Pit SSSI Mixed use – residential, Victoria Street, Windsor. 3.7km to the north west. employment, retail and leisure.

Wraysbury and Hythe End 100 units. Gravel Pits SSSI 4.7km to the north west.

Site AL31: King Edward VII Wraysbury No. 1 Gravel Pit SSSI Residential development for 47 Hospital, Windsor. 3.7km to the north west. units. Wraysbury and Hythe End Gravel Pits SSSI 4.5km to the north west.

4.10.18 There is restricted public access at Wraysbury Reservoir SSSI, Wraysbury No. 1 Gravel Pit SSSI, Wraysbury and Hythe End Gravel Pits SSSI and Staines Moor SSSI, due to health and safety and private ownership considerations. It is therefore concluded that development at the above allocated sites will have no LSE at these components of the SPA and Ramsar as a result of increased recreation and disturbance.

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4.10.19 In addition to recreational disturbance, other sources of disturbance associated with urban development can include noise, visual and vibration. This has the potential to disturb species for which the South West London Waterbodies SPA and Ramsar is designated. Given the distance of the potential site allocations in the BLPSV-PC from the SPA and Ramsar, (the closest site (AL40) being located 1.5km to the north of the SPA and Ramsar), it is considered unlikely that disturbance associated with noise, visual and vibration pollution will have an adverse impact on the integrity of this designation.

4.10.20 Due to the location of the BLPSV-PC allocations from the South West London Waterbodies SPA and Ramsar and access restrictions at each site, an LSE as a result of development set out within the BLPSV-PC, alone and in-combination is considered unlikely. This site has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

4.11 Thames Basin Heaths SPA - public access and disturbance screening

4.11.1 The qualifying features of the Thames Basin Heaths SPA, which are recognised as being under threat from public access and disturbance, are the European Nightjar (Caprimulgus europaeus), Woodlark (Lullula arborea) and Dartford Warbler (Sylvia undata).

4.11.2 As noted above (paragraph 4.13.4 to 4.13.5) the Thames Basin Delivery Framework makes recommendations for accommodating development while also protecting the SPA's features interest. This includes the recommendation of implementing a series of zones within which varying constraints would be placed upon development. The zone extending 400m from the SPA is an area where no new housing is to be located due to the potential impacts associated with urbanisation.

4.11.3 In terms of recreational impacts, the Thames Basin Heaths SPA Delivery Framework states that within a 400m to 5km zone from the perimeter of a European Site, avoidance measures are considered necessary to avoid recreational impacts. It also notes that applications for large scale development (i.e. those comprising more than 50 houses which are located between 5-7km from the edge of the European site) would be considered on a case-by- case basis.

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4.11.4 The Thames Basin Heaths SPA is located immediately adjacent to the Plan boundary and approximately 430m from the nearest allocation within the BLPSV-PC (Site AL33). In line with the buffer zones set out in the Thames Basin Heaths SPA Delivery Framework, Table 4.4 summarises the distance of each allocation that is situated within 5km of the Thames Basin Heaths SPA and each allocation comprising more than 50 homes between 5-7km of the SPA.

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Table 4.4: Site allocations within 5km of the Thames Basin Heaths SPA Site Allocation (code and Approximate distance from Proposed development name) Thames Basin Heaths SPA AL33 430m A mixed-use scheme including Broomhall Car Park, approximately 30 residential Sunningdale units, retail, employment and public car parking.

AL34 560m 10 residential units. White House, London Road, Sunningdale AL35 1.6km Approximately 230 residential Sunningdale Park, Sunningdale units which may include specialist accommodation for older people.

AL17 3.5km 131 residential units. Shorts Waste Transfer Station and Recycling Facility, St Georges Lane, Ascot AL18 3.7km A mixed-use scheme providing Ascot Station Car Park approximately 50 residential units, public car parking and ancillary retail/cycle hub (up to 280 sqm).

AL16 3.75km A mixed-use development Ascot Centre, Ascot providing approximately 300 residential units, 900 sqm of offices, public open space, community uses (including cultural/leisure) and retail/cafes/restaurants.

AL20 4.7km A mixed-use development Heatherwood Hospital, Ascot including approximately 250 residential units, retained health uses and ancillary offices.

AL19 5.0km 10 residential units. Englemere Lodge, Ascot

4.11.5 The Thames Basin Heaths Delivery Framework sets out a zone extending 400m from the SPA boundary within which LSEs associated with urbanisation (particularly predation of the chicks of ground-nesting birds by domestic cats) are likely to occur. No allocation is located within this 400m zone and it can therefore be concluded that no LSEs from urbanisation are likely to occur as a result of the BLPSV-PC.

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4.11.6 Given the location of the Thames Basin Heaths SPA from the BLPSV-PC allocations, it is considered that there may be LSEs associated with public access and disturbance (in terms of recreational impact) from the BLPSV-PC both alone and in-combination. This site has therefore been screened in for further assessment in the HRA process in terms of public access and disturbances.

4.12 Windsor Forest and Great Park SAC – public access and disturbance

4.12.1 Windsor Forest and Great Park SAC is designated for its ancient lowland oak woodland on acidic, sandy or gravelly substrates and Beech (Fagus sylvatica) forests with Holly (Ilex aquifolium). It also supports a diverse community of internationally rare invertebrates, in particular the Violet Click Beetle (Limoniscus violaceus).

4.12.2 Whilst the SIP55 does not identify public access and disturbance as a threat or pressure for Windsor Forest and Great Park, the supplementary advice from Natural England states that “unless carefully managed, activities such as construction, forestry management and trampling by grazing livestock and human feet during recreational activity may all contribute to excessive soil compaction around ancient trees”56. It is noted that the Violet Click Beetle has highly specific habitat requirements, being strongly associated with large-diameter veteran trees with internal cavities containing large quantities of slowly- decaying wood in the form of moist humus-rich compost.

4.12.3 Taking into consideration the information contained in Natural England’s supplementary advice, public access and disturbance impacts on the qualifying features of this SAC are likely to be associated with recreational activity. Other impacts associated with urbanisation are not considered further in this assessment.

55 Natural England. 2014. Site Improvement Plan: Windsor Forest and Great Park. Available at: http://publications.naturalengland.org.uk/publication/6221375450644480. [Date Accessed: 10.10.19]. 56 Natural England. 2019. European Site Conservation Objectives: Supplementary advice on conserving and restoring site features. Windsor Forest and Great Park Special Area of Conservation (SAC). Site code: UK0012586. Available at: http://publications.naturalengland.org.uk/publication/5175000009015296. [Date Accessed: 10.10.19].

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4.12.4 Windsor Forest and Great Park SAC is managed by The Crown Estate in partnership with Natural England and Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust (BBOWT). Natural England’s supplementary advice notes that "the main land uses in the area are mixed farming, timber production and grassland management for horse grazing. Parts of Windsor Forest and Great Park are open to the public and it is a very popular facility for walkers, cyclists and horse-riders. Together with Windsor Castle to the north, and Runnymede to the east the site is a very popular tourist destination. The high amenity and landscape value of Windsor Great Park makes it a significant boost to the local economy, reflected in high property values”.

4.12.5 This SAC is comprised of 22 SSSI units and in 2019, Natural England classified all of these as being a favourable condition.

4.12.6 Windsor Forest and Great Park SAC is located within the Plan area. Table 4.5 lists each allocation that is situated within 5km of this designation.

Table 4.5: Site allocations within 5km of Windsor Forest and Great Park SAC Approximate distance Site Allocation (code and name) from Windsor Forest and Proposed development Great Park SAC AL33 1.7km A mixed-use scheme including Broomhall Car Park, Sunningdale approximately 30 residential units, retail, employment and public car parking.

AL34 2.3km 10 residential units. White House, London Road, Sunningdale AL35 1.3km Approximately 230 residential Sunningdale Park, Sunningdale units which may include specialist accommodation for older people.

AL17 2.6km 131 residential units. Shorts Waste Transfer Station and Recycling Facility, St Georges Lane, Ascot AL18 2.9km A mixed-use scheme providing Ascot Station Car Park approximately 50 residential units, public car parking and ancillary retail/cycle hub (up to 280 sqm).

AL16 2.3km A mixed-use development Ascot Centre, Ascot providing approximately 300 residential units, 900 sqm of offices, public open space,

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Approximate distance Site Allocation (code and name) from Windsor Forest and Proposed development Great Park SAC community uses (including cultural/leisure) and retail/cafes/restaurants.

AL20 3.0km A mixed-use development Heatherwood Hospital, Ascot including approximately 250 residential units, retained health uses and ancillary offices.

AL19 3.3km 10 residential units. Englemere Lodge, Ascot

AL32 3.2km 25 residential units. Sandridge House, London Road, Ascot AL39 3.3km 80 residential units. Land at Riding Court Road and London Road Datchet AL30 2.2km 30 residential units. Windsor and Eton Riverside Station Car Park AL29 1.4km Mixed use – residential, Minton Place, Victoria Street, employment, retail and leisure. Windsor 100 units.

AL31 550m 47 residential units. King Edward VII Hospital, Windsor

AL21 1.2km Approximately 450 residential Land west of Windsor, north and units on Green Belt land, south of the A308, Windsor strategic public open space, formal pitch provision for football and rugby, multi- functional community hub and educational facilities.

AL22 1.8km 29 residential units. Squires Garden Centre Maidenhead Road Windsor AL26 3.1km 100 residential units. Land between Windsor Road and Bray Lake, south of Maidenhead AL13 4.3km Approximately 2,600 Desborough, Harvest Hill Road, residential units on Green Belt South West Maidenhead land. Educational facilities including primary and secondary schools Strategic public open space, formal play and playing pitch provision Multi-functional community hub as part of a Local Centre

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4.12.7 Due to the location of a number of allocations within 5km of Windsor Forest and Great Park SAC, it is concluded that the BLPSV-PC has the potential to increase visitor numbers to the SAC both alone and in- combination with other plans and projects. An LSE as a result of development set out within the BLPSV-PC, alone and in-combination is considered likely. This site has therefore been screened in for further assessment in the HRA process in terms of public access and disturbances.

4.13 Hydrology

4.13.1 Potential hydrological effects of urbanisation within European sites can be associated with an alteration in water balance and a reduction in water quality. Urban development can reduce catchment permeability and the presence of drainage networks may be expected to remove runoff from urbanised catchments. This may result in changes in run-off rates from urbanised areas to European sites or watercourses which run through them. Water mains leakage and sewer infiltration may also affect the water balance. In addition, the impact of climate change has the potential to exacerbate these impacts, with drier summers and wetter winters.

4.13.2 Urbanisation also has the potential to reduce the quality of water entering a catchment during the construction of a development through processes, such as sedimentation, accidental spillage of chemicals and materials, and operational sources of diffuse pollution, such as drainage from housing estates and run off from roads. Water quality may also be reduced through increased wastewater flow into collection systems which can overload the waste water treatment network, increasing the risk of sewer flooding and discharges from overflows. An overall increase in the volume of wastewater sent to waste water treatment works (WwTW), even with treatment, could also increase the pollution load to receiving watercourses.

4.13.3 As noted in Table 4.1, hydrology has been identified as a threat or pressure for qualifying features of the following European sites within the relevant SIPs:

• Thames Basin Heaths SPA; and • Thursley, Ash, Pirbright and Chobham SAC.

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4.13.4 A review of supplementary advice on conserving and restoring site features prepared by Natural England indicates that features within the following European sites are also sensitive to changes in hydrology, in particular, water quality and quantity:

• Burnham Beeches SAC; • Chilterns Beechwoods SAC; • South West London Waterbodies SPA; • South West London Waterbodies Ramsar; and • Windsor Forest and Great Park SAC.

4.13.5 In order to determine the potential LSEs of the BLPSV-PC (alone and in combination) an assessment has been made of the hydrological connectivity of European sites to development proposed as part of the BLPSV-PC.

4.13.6 RBWM is located within the Thames River Basin District57, which contains the River Thames and the River Cut, a tributary of the River Thames. Figure 4.3 and Figure 4.4 illustrate the surface water operational catchment zones and groundwater catchment zones58 within the Thames River Basin District for the BLPSV-PC and the surrounding area.

57 River Basin Districts are the main areas for the co-ordination and management of the water environment. They comprise river basins and their associated coastal waters. 58 Surface water and groundwater management catchments are units of geography for which action plans are drafted to implement the requirement of the Water Framework Directive.

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Figure 4.2: Surface Water Operational Catchment Zones within RBWM and the surrounding area.

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Figure 4.3: Groundwater Catchment Zones RBWM and surrounding area.

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4.13.7 Water supply services are provided by Affinity Water in the south and east of the Plan area (Ascot and Old Windsor), South East Water in the west (Maidenhead and Hurley) and Thames Water who supply the area around Windsor and Eton. Wastewater treatment services are provided by Thames Water.

4.13.8 Thames Water has prepared a Water Resources Management Plan (WRMP)59 which considers population growth, climate change and the environment in its operating area over the next 25 years. It uses census data and works with local authorities to understand planned development in the South East and promote water efficiency in new homes. The Thames Water Draft WRMP60 seeks to maintain levels of services for customers through enhanced resilience to severe drought from 2030 and water efficiency.

4.13.9 Thames Water undertook an HRA of the Draft WRMP in 201961. The HRA Stage 1 Screening assessment concluded that with the inclusion of mitigation measures, Thames Water’s revised draft WRMP19 would have no adverse effects on the integrity of any European site, either alone or in-combination with other plans or projects. It noted that the requirement for HRA would continue to apply to project level assessment.

59 Our current plan (2014) Thames Water Available at: https://corporate.thameswater.co.uk/About-us/our- strategies-and-plans/water-resources/our-current-plan-wrmp14 [Date Accessed: 15/07/19] 60 Thames Water Draft Water Resources Management Plan (2019) Available at: https://corporate.thameswater.co.uk/-/media/Site-Content/Your-water-future-2018/Statement-of- response/Statement-of-Response---Main-document.pdf?la=en [Date Accessed: 15/07/19] 61 Thames Water Revised Draft Water Resources Management Plan 2019 Habitat Regulations Assessment (2018) Ricardo, Available at: https://corporate.thameswater.co.uk/-/media/Site-Content/Your-water-future- 2018/Appendices/dWRMP19-Appendix-C---HRA---Stage-1-screening-151217.pdf [Date Accessed: 18/07/19]

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4.13.10 South East Water has also prepared a WRMP which sets out how they will secure water supplies from 2020 to 208062. During the period from 2025 to 2045, South East Water will continue to implement demand management initiatives to achieve further leakage and water efficiency savings. The South East WRWP was subject to an HRA in 201763. Following the screening stage, five options to achieve water resource management over the period of the plan were considered to have pathways which could result in LSEs to a European site, or sufficient uncertainty existing whereby the potential for LSEs could not be ruled out; these options were considered in terms of an appropriate assessment. Due to the complexity of modelling or studies required to assess the significance of impacts associated with all the options, a ‘down the line’ assessment was proposed in the HRA. In the event that no adverse effects on integrity cannot be concluded, South East Water commits to replacing these with suitable alternative options, with all options to be subject to an HRA. In addition, South East Water commits to undertake a final cumulative environmental assessment and an in- combination assessment which can feed into a final HRA for the adopted plan.

4.13.11 Affinity Water has prepared a revised draft WRMP (rdWRMP)64 which sets out how they plan to provide water over the period 2020 to 2080, whilst protecting the environment. This was subject to an HRA in 201965. Following screening and appropriate assessment, no pathways that would lead to the South East Strategic Reservoir having adverse effects on the South West London Waterbodies SPA and Ramsar site, alone or in-combination, subject to the application of mitigation, were identified.

62 South East Water (2017). Draft Water Resource Management Plan 2020-2080. Available at: https://corporate.southeastwater.co.uk/media/2219/draft-water-resources-management-plan-2019-main- document.pdf [Date accessed: 17/06/19] 63 South East Water (2017) Draft Water Resources Management Plan 2020-2080 Strategic Environmental Assessment: Environmental Report Appendices. Available at:https://corporate.southeastwater.co.uk/media/2199/dwrmp19-sea-report-appendices.pdf 64 Affinity Water (2019) Revised Draft Water Resources Water Management Plan, Available at: https://stakeholder.affinitywater.co.uk/docs/Affinity_Water_rdWRMP19_FOR_PUBLICATION_01.03.19.pdf [Date Accessed: 25/09/19] 65 AECOM (2019) Technical Report: 4.12 Habitats Regulations Assessment, Draft Final WRMP 2020-2080, Available at:https://stakeholder.affinitywater.co.uk/docs/4.12%20Habitat%20Regulations%20Assessment_draft%20final%20 WRMP19_June%202019.pdf [Date Accessed: 26/09/19]

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4.13.12 Thames Water, South East Water and Affinity Water are able to demonstrate sufficient supply options to ensure no adverse effect at a European site as a result of water quantity or a commitment to adopt suitable alternative options. Water quantity and resource issues have therefore been screened out of this assessment.

4.13.13 A Water Quality Impact Assessment was undertaken to support the development of the BLPSV-PC in March 2019. This was updated to reflect amended growth forecasts for the Plan area in September 2019. These impact assessments are presented in the following documents and form part of the BLPSV-PC evidence base:

• RBWM Water Quality Impact Assessment. Draft Report. March 201966. • RBWM Water Quality Impact Assessment. Addendum to v4.0. September 201967.

4.13.14 These reports were informed through consultation with Thames Water, Affinity Water, South East Water and the Environment Agency. They considered growth within RBWM over the Plan period and also that within neighbouring Local Planning Authority areas within the Thames Water wastewater catchment boundary dataset. This ensured consideration of in-combination impacts (see Appendix G).

4.13.15 Thames Water undertook a high-level assessment of their wastewater treatment network. This indicated that the sewer network is most constrained in the Maidenhead wastewater catchment with Windsor wastewater catchment having more capacity. Thames water noted:

4.13.16 “The capacity of the network would not prevent the delivery of growth provided that any necessary network reinforcement works are delivered ahead of the occupation of development in order to prevent any adverse impact on the environment as a result of issues such as pollution and / or sewer flooding”.

66 JBA Consulting. March 2019. RBWM Water Quality Impact Assessment. Draft Report. 67 JBA Consulting. September 2019. RBWM Water Quality Impact Assessment. Addendum to v4.0. Final Report.

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4.13.17 There are four Wastewater Treatment Works (WwTW) in RBWM (Hurley, Maidenhead, White Waltham and Windsor) and a further three outside the Plan area (Ascot, Mogden and Slough) which are expected to serve growth over the BLPSV-PC period. The Water Quality Impact Assessment provided an analysis of WwTW capacity over the BLPSV-PC period. This indicated that there is capacity for growth over the BLPSV- PC period at Windsor, Hurley, Mogden and White Waltham. Thames Water are investigating upgrades at Maidenhead, Ascot and Slough.

4.13.18 The Water Quality Impact Assessment also provided an assessment of WwTW flow permits. It concluded that whilst Hurley, White Waltham and Windsow WwTW have capacity to serve growth over the Plan period, Ascot and Slough WwTW are close to exceeding their flow permits and Maidenhead is likley to exceed its flow permit over the Plan period. It concluded that upgrades may be required in order to serve the proposed growth. Increased waste water discharges at WwTW servicing growth in RBWM has the potential to impact downstream water quality in the receiving watercourses.

4.13.19 The Water Framework Directive (WFD) was published in 2000 and transposed into English and Welsh law in 2013. It provides an indication of the health of the water environment and whether a waterbody is at good status or potential. This is determined through an assessment of a range of elements relating to the biological and chemical quality of surface waters and quantitative and chemical quality of groundwater. To achieve good ecological status or potential, good chemical status or good groundwater status, every element assessed must be at good status or better. If one element is below its threshold for good status, then the whole water body’s status is classed below good. Surface water bodies can be classed as high, good, moderate, poor or bad status.

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4.13.20 River Basin Management Plans (RBMP) are required under the WFD. These document the baseline classification of each waterbody in a RBMP area, the objectives and programme of measures to achieve those objectives. RBWM is located in the Thames River Basin District. Development in the Plan area must be planned to contribute towards achieving the WFD and objectives of the RBMP68. An HRA of the RBMP for Thames River Basin District was carried out by the Environment Agency, in consultation with Natural England69. It concluded that, at the strategic plan level, taking into consideration a range of potential mitigation options the RBMP would have no LSE on any European sites, alone or in combination with other plans or projects. It noted that HRA requirements will continue to apply for lower tier plan and project level assessments.

4.13.21 The WFD sets out areas which require special protection. These include areas designated for “the protection of habitats or species where the maintenance or improvement of the status of water is an important factor in their protection including relevant Natura 2000 sites designated under Directive 92/43/EEC (the Habitats Directive) and Directive 79/409/EEC (the Birds Directive)”70.

4.13.22 The seven WwTW serving RBWM discharge into a number of watercourses. The WFD classification at each of these watercourses was analysed in the Water Quality Impact Assessment and an assessment made as to whether development over the BLPSV-PC period could prevent these watercourses from achieving Good (or High) class. The results of this assessment are summarised in Table 4.2 below.

68 Environment Agency. 2015. Thames River Basin Management Plan. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/718342/Tham es_RBD_Part_1_river_basin_management_plan.pdf [Date Accessed: 15/07/19] 69 Environment Agency. 2015. River basin management plan for the Thames River Basin District Habitats Regulations Assessment Updated December 2015. 70 Official Journal of the European Communities. Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy. https://eur- lex.europa.eu/resource.html?uri=cellar:5c835afb-2ec6-4577-bdf8-756d3d694eeb.0004.02/DOC_1&format=PDF

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Table 4.6: Summary of Water Quality Assessment for RBWM Classification in Cycle 2 of the Waterbody WFD and Discharging Findings of Water Quality Assessment name reasons for not WwTW achieving good status Bull Brook Moderate Ascot Proposed growth over the BLPSV-PC (tributary to the period would not prevent good class River Cut). Sewage being achieved. discharge (phosphate)

The Cut Moderate Bracknell and Deterioration could be prevented by White Waltham tightening effluent discharges and potential infrastructure improvements. Sewage Proposed growth over the BLPSV-PC discharge and period would not prevent good class transport being achieved. drainage (phosphate)

Maidenhead Moderate Maidenhead There is currently a scheme aimed at Ditch improving the hydrological regime to meet the WFD. Proposed growth over Sewage the BLPSV-PC period would not prevent discharge and good class being achieved. transport drainage (phosphate)

Roundmoor Moderate Slough There are several schemes aimed at Ditch and improving the hydrological regime to Boveney Ditch meet the WFD. Proposed growth over Sewage the BLPSV-PC period would not prevent discharge good class being achieved. (ammonia and phosphate)

River Thames Moderate Hurley and Good status could be achieved if Windsor, as well upstream water quality were improved. as inputs from Proposed growth over the BLPSV-PC Sewage Roundmoor Ditch period would not prevent good class discharge, and the River Cut. being achieved. transport and poor nutrient management from agriculture (phosphate)

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4.13.23 The Water Quality Impact Assessment concluded that “the planned growth over the Local Plan period, and that within neighbouring authorities, can be accommodated without causing a deterioration in water quality … so long as timely interventions to prevent deterioration are implemented by Thames Water and the Environment Agency. The planned growth within RBWM and its neighbouring authorities would not prevent Good class from being achieved”.

4.13.24 The Water Quality Impact Assessment however concluded that increasing wastewater effluent volumes discharged as a result of growth could constitute a potential point-source of pollution. In addition, it noted that development sites may be potential sources of diffuse pollution from surface water runoff. These sources could cause a deterioration in surface and ground water quality. This screening assessment therefore provides further assessment in terms of surface and groundwater quality impacts at European sites.

4.14 Burnham Beeches SAC – hydrology screening

4.14.1 Natural England’s supplementary advice indicates that hydrological processes are important to the maintenance of the ‘beech forests on acid soils’ at Burnham Beeches SAC71.

71 Natural England. 2017. European Site Conservation Objectives: Supplementary advice on conserving and restoring site features. Burnham Beeches Special Area of Conservation (SAC). Site code: UK0030034. Available at: http://publications.naturalengland.org.uk/publication/6014456282742784 [Date Accessed: 08.10.19].

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4.14.2 South Buckinghamshire District Council, the local authority area within which Burnham Beeches SAC lies, has provided planning guidance notes for the consideration of hydrology impacts at this European site. This guidance note advocates the use of sensitive construction practices within 10m of a watercourse within the catchments of Burnham Beeches SAC and the adoption of the principles of Sustainable Urban Drainage Systems (SuDS)72. The catchments that feed into Burnham Beeches SAC are illustrated in Appendix 1 of the planning guidance note and include the Portman Estate Stream, Unnamed Stream, Nile Stream and Withy Stream catchments. The planning guidance note draws on the findings of the Burnham Beeches Hydrology Study73. This study assessed the impact of development on the catchment of Burnham Beeches generally and proposed mitigation. The Plan area is not located within 10m of one of the catchments which connect with Burnham Beeches SAC (see Appendix 1 of the Guidance Note).

4.14.3 Burnham Beeches SAC is located within the Lower Thames (Maidenhead and Sunbury) operational catchment (Figure 4.3). A stream (unnamed) flows in a southerly direction from Burnham Beeches towards the Plan area. This stream feeds into the Jubilee River flowing north, before it converges with the River Thames, north west of Datchet. As Burnham Beeches SAC is located upstream from the Plan area, and no allocation is located in one of its catchments, there will be no LSE on water quality as a result of the BLPSV-PC.

4.14.4 In addition, the Water Quality Assessment indicates that, whilst point sources of pollution from WwTW are unlikely to compromise the ability of watercourses to meet a good classification under the WFD, development at allocations within the RBWM could potentially contribute to sources of pollution from surface water run-off. Burnham Beeches SAC is located approximately 5.4km upstream of the closest allocations at Cookham Rise and is therefore not considered to be hydrologically linked to the Plan area via surface or groundwater receptors. This site has therefore been screened out for further assessment in the HRA process in terms of hydrology.

72 South Buckinghamshire (2014). Development Management Guidance Note. Hydrology in Burnham Beeches. http://www.southbucks.gov.uk/planning/policyguidance [Date Accessed: 08.10.19]. 73 Wallingford Hydro-Solutions Limited (2013). Burnham Beeches Hydrology Study. Available at: https://www.southbucks.gov.uk/planning/policyguidance. [Date Accessed: 08.10.19].

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4.15 Chilterns Beechwoods SAC – hydrology screening

4.15.1 Hydrological changes have been identified as a threat to the qualifying feature ‘beech forests on neutral to rich soils’ at Chilterns Beechwoods SAC.

4.15.2 Chilterns Beechwoods SAC is located within the South Chilterns and Lower Thames operational catchment (Figure 4.3). This SAC is underlain by a number of SSSI designations. Bisham Woods SSSI is located within the Plan area, to the south east of the River Thames. A small watercourse flows along the western boundary of this SSSI in a north easterly direction towards the River Thames (known as Reading to Cookham section). All allocations within the BLPSV-PC are located downstream of the Chilterns Beechwoods SAC or are located outside a connecting operational catchment.

4.15.3 The Water Quality Assessment indicates that, whilst point sources of pollution from WwTW are unlikely to compromise the ability of watercourses to meet a good classification under the WFD, development sites within RBWM could potentially contribute to pollution from surface water runoff. Given the location of the SAC in relation to the closest allocation (approximately 1.6km to its south east in Cookham Rise) and the fact that this SAC is located upstream of development in the BLPSV- PC, this site has been screened out of further assessment in the HRA process in terms of hydrology.

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4.16 South West London Waterbodies SPA/Ramsar – hydrology screening

4.16.1 Water quality and quantity have been identified as a threat to the Gadwall and Shoveler qualifying features of the South West London Waterbodies SPA. Of particular concern are chemical or physical pollutants which negatively impact the natural flora and fauna of the waterbodies and are likely to be damaging to the value of the sites as a habitat for Gadwall and Shoveler. Poor water quality may significantly reduce habitat quality and also reduce food availability for the qualifying features. The SIP for South West London Waterbodies SPA notes that water quality is determined by “a range of factors including the quality of groundwater supply, water quality in feeder streams, the quantity of aquatic plants present, the amount of mixing taking place in the water column and the amount of disturbance of accumulated sediment taking place, as well as inputs from surrounding vegetation (particularly trees) and nutrients in rainfall”74. Water supply and management of water levels are also important considerations.

4.16.2 A number of the reservoirs that constitute the South West London Waterbodies SPA are used for operational water supply by Thames Water. As noted in Paragraph 4.19.10, Thames Water is one of the Statutory water companies for RBWM, alongside Affinity Water and South East Water. An increase in the population of the borough over the BLPSV-PC period could have a potential effect on water supply and quality at the South West London Waterbodies and their ability to support qualifying features. However, a review of the Thames Water draft WRMP19 and accompanying HRA (reviewed in paragraph 4.19.11) concludes that no adverse effects on the integrity of any European site, either alone or in-combination with other plans or projects, would occur as a result of water supply.

74 Natural England. 2018. European Site Conservation Objectives: Supplementary advice on conserving and restoring site features. South West London Waterbodies Special Protection Area (SPA) Site code: UK9012171. Available at: http://publications.naturalengland.org.uk/publication/4901473695563776 [Date Accessed: 02/10/19].

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4.16.3 South West London Waterbodies SPA and Ramsar is located within the same operational catchments as the Plan area is located. These are Colne, Lower Thames and Wey operational catchments (as shown in Figure 4.3). The general direction of flows of the operational catchments are in an easterly direction feeding into the River Thames. South West London Waterbodies SPA and Ramsar are located within and downstream of the Plan area. Water quality was raised as an issue within all three of the operational catchments within the Thames RBMP, in particular pollution from wastewater, phosphorous, sediment and pesticides.

4.16.4 South West London Waterbodies SPA and Ramsar is underpinned by a number of SSSIs. Wraysbury No. 1 Gravel Pit SSSI and Wraysbury and Hythe End Gravel Pits SSSI are located within the Plan area. Wraysbury Reservoir SSSI and Staines Moor SSSI are located immediately adjacent but outside the Plan area. These SSSIs are located within the Lower Thames and Colne operational catchment areas. The section of the River Thames that flows through this section of the BLPSV-PC is known as Cookham to Egham, and in 2016 had an overall ‘moderate’ classification under the WFD75. The reasons for not achieving ‘good’ status included sewage discharge and transport drainage. Development within the BLPSV-PC therefore has the potential to have an LSE on the water quality of the South West London Waterbodies SPA and Ramsar.

4.16.5 Thorpe Park Number 1 Gravel Pit SSSI, Kempton Park Reservoirs SSSI and Knight and Bessborough Reservoirs SSSI are located approximately 3.1km, 8.9km and 9.8km respectively to the south and south east of the BLPSV-PC boundary. These SSSIs are also located within the Lower Thames, Wey and Colne operational catchment areas. This stretch of the Thames (Egham to Teddington) was classed as ‘poor’76 in 2016 due to sewage discharge, transport drainage and poor nutrient management.

4.16.6 The South West London Waterbodies and the Plan area coincide with the Thames groundwater management catchment (Figure 4.4).

75 Environment Agency, Catchment Data Explorer Thames (Cookham to Egham) Available at: https://environment.data.gov.uk/catchment-planning/WaterBody/GB106039023231 [Date Accessed: 25/09/19] 76 Environment Agency, Catchment Data Explorer Thames (Egham to Toddington) Available at: https://environment.data.gov.uk/catchment-planning/WaterBody/GB106039023232 [Date Accessed: 25/09/19]

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4.16.7 The South West London Waterbodies SPA and Ramsar are considered to potentially be hydrologically linked to the RBWM Plan area via surface and groundwater pathways, as the European designated sites are located downstream of the Plan area and within the same operational water catchment zones. Therefore, this site has been screened in for further assessment in the HRA process in terms of hydrology.

4.17 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC – hydrology screening

4.17.1 Hydrological changes have been identified as a threat to the ‘wet heathland with cross-leaved heath’ and ‘depressions on peat substrates’ qualifying features of the Thames Basin Heaths SPA. Areas of wet heath on low-lying shallow slopes and bogs within valleys support important breeding bird populations77. Changes to hydrology can have a direct impact on the wet heath habitat.

4.17.2 The SIP for the Thames Basin Heaths SPA provides further, more detailed, information on hydrological links at this designated site. It notes that “part of Thursley, Ash, Pirbright and Chobham SAC (Elstead Common) has evidence of damaging impacts due to drainage. Drains are also present on Thursley and Ockley Commons but it is not clear whether these are having adverse impacts”78.

4.17.3 This screening assessment therefore focuses on the section of the Thames Basin Heaths SPA that is also designated as the Thursley, Ash, Pirbright and Chobham SAC.

4.17.4 Thursley, Ash, Pirbright and Chobham SAC and Thames Basin Heaths SPA is located immediately adjacent to the south eastern boundary of the borough, extending into the Plan area along the Waterloo to Reading railway line. The closest allocations to these designations include Site AL34 and Site AL33, which are located approximately 564m to the west and 430m to the north west, respectively, from the SAC and SPA.

77 JNCC Thames Basin Heaths SPA description. Available at: http://archive.jncc.gov.uk/default.aspx?page=2050 [Date Accessed:05/08/19] 78 Natural England. 2014. Site Improvement Plan Thames Basin. Available at: http://publications.naturalengland.org.uk/publication/6249258780983296 [Date Accessed: 02/10/19].

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4.17.5 Both the Plan area and Thursley, Ash, Pirbright and Chobham SAC are located within the Wey operational catchment (Figure 4.3). The Environment Agency provides details of the habitats within the Wey operational catchment noting that “the Wey Valley contains valuable floodplain grazing marsh, a priority UK Biodiversity Action Plan habitat that provides feeding opportunities for wintering wading birds. The Wey catchment also contains large areas of lowland heathland, which is important internationally”79.

4.17.6 Thursley, Ash, Pirbright and Chobham SAC is not located within the Thames groundwater management catchment which links to the Plan area (Figure 4.4).

4.17.7 Based on the distance of the SAC and SPA in relation to BLPSV-PC allocations and a review of hydrological baseline information, it is considered that potential hydrological links via surface water may be present.

4.17.8 The Water Quality Impact Assessment indicates that, whilst point sources of pollution from WwTW are unlikely to compromise the ability of watercourses to meet a good classification under the WFD, development sites within RBWM could potentially contribute to pollution from surface water runoff. Given the location of the SAC in relation to the closest allocation (430m to the north west in Sunningdale) it is concluded that development proposed in the BLPSV-PC could potentially have an adverse impact on water quality. As such, these European sites have therefore been screened in for further assessment in the HRA process in terms of hydrology.

4.18 Windsor Forest and Great Park SAC – hydrology screening

4.18.1 Hydrological changes have been identified as a threat to the ‘Beech forests on acid soils’ and ‘dry Oak-dominated woodland’ qualifying features of Windsor Forest and Great Park SAC. It is necessary that the natural hydrological processes are maintained to sustain the qualifying features of this European site.

79 Environment Agency. Catchment Data Explorer. Wey and Trib Summary Data. https://environment.data.gov.uk/catchment-planning/ManagementCatchment/3114/Summary. [Date Accessed: 08.10.19].

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4.18.2 Windsor Forest and Great Park SAC is located within the Plan area and shares the same operational catchment; namely the Lower Thames and Wey (Figure 4.3). The north of Windsor Forest and Great Park SAC is located within the Lower Thames operational catchment. Battle Bourne and Bourne ditch flow in a northerly direction away from the SAC and feed into the River Thames. The south of Windsor Forest and Great Park SAC is located in the Wey operational catchment. Streams flow from the SAC in a southerly direction towards Virginia Water before joining the Thames.

4.18.3 This site is not located within the Thames groundwater management catchment (Figure 4.4).

4.18.4 A number of allocations are located within close proximity to Windsor Forest and Great Park SAC, with the closest (Site AL31) being 540m to the north east (see Table 4.5). This SAC has the potential to therefore be hydrologically linked via surface water impact pathways to these developments. This site has therefore been screened in for further assessment in the HRA process in terms of hydrology.

4.19 Habitat fragmentation and loss

4.19.1 Habitat fragmentation has been identified as a threat or pressure to the qualifying features of the following European sites within the relevant SIPs (see Table 4.1):

• Burnham Beeches SAC; • Thames Basin Heaths SPA; and • Thursley, Ash, Pirbright and Chobham SAC.

4.19.2 The BLPSV-PC will not result in the direct loss of land within an area designated as a European site. However, there is potential for the BLPSV- PC to result in the loss of habitat outside a European site which may be supporting habitat. Supporting habitat, also referred to as functionally linked habitat80, may be located some distance from the European site. The fragmentation of habitats through the loss of connecting corridors would hinder the movement of qualifying species.

80 “The term ‘functional linkage’ refers to the role or ‘function’ that land or sea beyond the boundary of a European site might fulfil in terms of ecologically supporting the populations for which the site was designated or classified. Such land is therefore ‘linked’ to the European site in question because it provides an important role in maintaining or restoring the population of qualifying species at favourable conservation status”. Source: Natural England. 2016.

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4.19.3 Lepus Consulting undertook a detailed desk study as part of this screening exercise. This drew on Natural England SSSI IRZ data, IUCN data, Defra data, priority habitat inventory data and aerial photography.

4.19.4 Areas of potentially functionally linked habitat likely to be lost to development have been determined. These parcels of land were analysed in the context of their potential to provide suitable habitat to support the qualifying features of the relevant European site. Where suitable habitat has been identified, its likelihood to provide an important role in maintaining or restoring the qualifying features at a favourable conservation status was taken into consideration.

4.20 Burnham Beeches SAC – habitat loss and fragmentation screening

4.20.1 The SIP for Burnham Beeches notes that there is high pressure for new housing development within the vicinity of Burnham Beeches SAC which risks isolating the site from the surrounding countryside81. There will be no direct loss of habitat within Burnham Beeches SAC attributed to the BLPSV-PC with the closest allocation being located 5.5km to the west of Burnham Beeches SAC.

4.20.2 Burnham Beeches SAC is designated for its Beech forests on acid soils. Land at the allocations set out in the BLPSV-PC are not considered to provide an important role in maintaining or restoring the population of qualifying features at ‘favourable’ conservation status. This site has therefore been screened out from further assessment in the HRA process in terms of habitat loss and fragmentation threats / pressures.

Commissioned Report. NECR207. Functional linkage: How areas that are functionally linked to European sites have been considered when they may be affected by plans and projects - a review of authoritative decisions. 81 Natural England. 2014. Burnham Beeches SAC Site Improvement Plan. Available at: http://publications.naturalengland.org.uk/publication/5689860228644864. [Date Accessed: 10.10.19].

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4.21 Thames Basin Heaths SPA – habitat loss and fragmentation screening

4.21.1 There will be no direct loss of habitat within the Thames Basin Heaths SPA as a result of allocations in the BLPSV-PC. The Thames Basin Heaths SPA is designated for the populations of breeding birds that it supports namely, European Nightjar, Woodlark and Dartford Warbler. Table 4.7 outlines habitat requirements for these qualifying features.

Table 4.7: Thames Basin Heaths SPA qualifying features and their suitable habitats82. Species Habitat Population status European nightjar This species nests on bare or sparsely Declining due to (Caprimulgus europaeus) vegetated ground. It uses mainly dry, open ongoing habitat country including lowland heaths with scattered destruction. trees and bushes, commons and moorland, forests and woodland. Woodlark (Lullula arborea) This species inhabits a variety of open and Increasing semi-open habitats. It favours unmanaged and poorly managed habitats such as abandoned farmland, heathland, young forestry plantations, recently felled woodland and scrub, orchards, woodland edges and clearings. Dartford warbler (Sylvia It favours dense, homogenous scrub, that is Declining undata) dominated by species such as Gorse (Ulex), Heath (Erica), Brooms (Genista) and Oak (Quercus).

4.21.2 The Thames Basin Heaths SPA is located immediately adjacent to the Plan area boundary and approximately 430m from the nearest allocation within the BLPSV-PC (Site AL33). Table 4.8 provides a summary of the habitats likely to be lost as a consequence of development proposed in the BLPSV-PC at all allocations located within 5km.

Table 4.8: Allocation site habitat to be lost to development Approximate Site Allocation (code and distance from Existing land use name) Thames Basin Heaths SPA AL33 430m Previously developed land (car park and Broomhall Car Park, house). Sunningdale AL34 560m Previously developed land (home with White House, London Road, garden). Sunningdale

82 The IUCN Red List, Available at: https://www.iucnredlist.org/ [Date Accessed: 26.07.19]

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Approximate Site Allocation (code and distance from Existing land use name) Thames Basin Heaths SPA AL35 1.6km Previously developed land, with a small Sunningdale Park, Sunningdale area of deciduous woodland priority habitat.

AL17 3.5km Previously developed land (industrial and Shorts Waste Transfer Station scrap yard). Small area of deciduous and Recycling Facility, St Georges Lane, Ascot woodland priority habitat on site margins. AL18 3.7km Previously developed land (car park). Ascot Station Car Park

AL16 3.75km Partially previously developed land. Small Ascot Centre, Ascot fragmented section of deciduous woodland priority habitat on the site boundary.

AL20 4.7km Previously developed site (hospital). Heatherwood Hospital, Ascot

AL19 5.0km Previously developed site (apartment Englemere Lodge, Ascot complex).

AL32 5.0km Previously developed site (home with Sandridge House, London garden). Road, Ascot

4.21.3 The desk-based review indicates that none of the allocations will result in the loss of suitable functionally linked habitat for the qualifying features of the Thames Basin Heaths SPA. This site has therefore been screened out from further assessment in the HRA process in terms of habitat loss and fragmentation threats / pressures.

4.22 Thursley, Ash, Pirbright and Chobham SAC – habitat loss and fragmentation screening

4.22.1 Thursley, Ash, Pirbright and Chobham SAC form part of the Thames Basin Health complex, overlapping with the SPA designation. There will be no direct loss of habitat within the Thursley, Ash, Pirbright and Chobham SAC as a result of allocations in the BLPSV-PC.

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4.22.2 The qualifying features of the SAC comprise depressions on peat substrates of the Rhynchosporion, European dry heaths and Northern Atlantic wet heaths with Erica tetralix. As shown in Table 4.8, land at the allocations set out in the BLPSV-PC does not provide an important role in maintaining or restoring the population of qualifying features at favourable conservation status at this SAC. This site has therefore been screened out from further assessment in the HRA process in terms of habitat loss and fragmentation threats / pressures.

4.23 Arson and Wildfire

4.23.1 Uncontrolled fires can have profound impacts on plant diversity and can result in significant habitat loss.

4.23.2 As noted in Table 4.1, arson and wildfire has been identified as a threat or pressure for qualifying features of the following European sites within the relevant SIPs:

• Thames Basin Heaths SPA; and • Thursley, Ash, Pirbright and Chobham SAC.

4.24 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC – arson and wildfire screening

4.24.1 The SIP for the Thames Basin Heaths complex (which includes the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC) notes that “uncontrolled fires are very damaging as they can have profound impacts on reptile populations, inverts and plant diversity and can result in significant habitat loss for annex 1 birds. They can affect forestry areas as well as open heath. Damaging impacts can last for many years for example by the wholesale removal of all gorse from a site. Strategies are in place in parts of the complex to reduce risk but more attention is needed to properly address this issue. Increasing threat of extensive fires is of great concern to the fire services and there is a desire for greater link up between efforts to protect property and roads from fire, and habitat management”. It goes on to note that fire strategies and management plans for all sites are to be agreed and implemented in order to reduce fire risk.

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4.24.2 The Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC is located immediately adjacent to the Plan area boundary and approximately 430m from the nearest allocation within the BLPSV-PC (Site AL33).

4.24.3 The qualifying features likely to be affected by wildlife and arson include the European nightjar, Woodlark, Dartford Warbler, wet heathland with cross-leaved heath, European dry heaths and depressions on peat substrates

4.24.4 The BLPSV-PC is not expected to affect the frequency or nature of wildfires, as this is dependent on the existing site management regime and climatic factors. Any increase in the risk of arson arising from the BLPSV-PC is deemed to be negligible.

4.24.5 In addition, the SAC and SPA fall outside of the Thames Basin Heaths Delivery Framework 400m buffer distance designed to eliminate impacts caused by urbanisation effects, of which wildfire and arson are included. Therefore, the policies or developments set out within the Plan are not considered to have an adverse impact in terms of wildfire / arson on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC either alone or in combination. These sites have therefore been screened out from further assessment in the HRA process in terms of arson and wildfire.

4.25 In-combination screening

4.25.1 As set out in Section 3.6, and in compliance with Regulation 105 of the Habitats Regulations, an in-combination assessment has been undertaken as part of the screening exercise (see Appendix G). This provides a summary of the quantum of development proposed in other plans and projects and the findings of supporting HRA work that has been undertaken.

4.25.2 It is noted that a number of the plans and projects analysed as part of the in-combination assessment are in their early stages of development and information is not currently available to allow a detailed assessment within this report.

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4.25.3 The assessment of potential in-combination effects has not resulted in additional impact pathways being screened in, however, a number of links between other plans and projects and the BLPSV-PC have been identified. Air quality in-combination impacts are addressed in the Ricardo Air Quality report at Appendix I.

• Development proposed in neighbouring authority local plans has the potential to act in-combination with the BLPSV-PC and therefore, increase public access and disturbance threats at European sites. • Development proposed in neighbouring authority local plans has the potential to act in-combination with the BLPSV-PC and increase development related diffuse sources of pollution with adverse effects on water quality at a European sites.

4.26 Policy screening

4.26.1 Each BLPSV-PC policy has been appraised against the screening criteria taking into consideration case law and best practice. Appendix A details the output of this screening exercise. Table 4.9 provides a summary of policies that have been screened in.

4.26.2 It is concluded that LSEs, either from the BLPSV-PC alone or in- combination with other plans or projects, could be screened out for most policies. This is because the policies fell into the following categories:

• Category D: Environmental protection / site safeguarding; and • Category F: Policies or proposals that cannot lead to development or other change.

4.26.3 A number of policies were considered likely to have an LSE. On the basis of this assessment, the following LSEs are explored in the appropriate assessment in more detail (see Sections 5 to 7).

• Air quality impacts; • Public access and disturbance; and • Hydrological impacts.

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Table 4.9: Summary of screened in policies.

Policy Number Policy Name Screening decision

SP1 Spatial Strategy for the Royal Borough of Windsor and Screened in Maidenhead

QP1a Maidenhead Town Centre Strategic Placemaking Area Screened in

QP1b South West Maidenhead Strategic Placemaking Area Screened in

QP1c Ascot Centre Strategic Placemaking Area Screened in

HO1 Housing Development Sites Screened in

ED1 Economic Development Screened in

NR4 Thames Basin Heaths Special Protection Area Screened in

IF4 Open Space Screened in

4.27 Sites screening

4.27.1 Potential site allocations have also been appraised against the screening criteria (Appendix B).

4.27.2 All potential site allocations within the BLPSV-PC have also been screened in under Categories I and L: proposals which might be likely to have a significant effect alone or in-combination. This conclusion has been reached as all site allocations, in-combination with other plans and projects (Appendix G), have the potential to contribute to the following LSEs:

• Air quality; • Public access and disturbance; and • Hydrology.

4.28 Screening conclusion

4.28.1 The screening exercise was unable to rule out LSEs at the following European sites:

• Burnham Beeches SAC –public access and disturbance LSEs;

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• Chilterns Beechwoods SAC - air quality and public access and disturbance LSEs; • South West London Waterbodies SPA – air quality, public access and disturbance and hydrology LSEs; • South West London Waterbodies Ramsar – air quality, public access and disturbance and hydrology LSEs; • Thames Basin Heaths SPA - air quality, public access and disturbance and hydrology LSEs; • Thursley, Ash, Pirbright and Chobham SAC - air quality and hydrology LSEs; and • Windsor Forest and Great Park SAC - air quality, public access and disturbance and hydrology LSEs.

4.28.2 As such, and in line Regulation 105 of the Habitats Regulations 2017, the Council must therefore “make an appropriate assessment of the implications for the site in view of that site’s conservation objectives”. This assessment must consider the effects of the BLPSV-PC both alone and in-combination with other plans and projects.

4.28.3 The conservation objectives of each European site are provided at Appendix D. In general, these aim to ensure that the integrity of each European site is maintained or restored as appropriate, and to ensure that each site contributes to achieving the Favourable Conservation Status of its Qualifying Features, or in the case of the SPA designations, the aims of the Wild Birds Directive through maintenance or restoration.

4.28.4 The appropriate assessment is presented in Chapters 5 to 7.

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5.1.1 The screening concluded that the following policies have the potential to result in LSEs at a number of European sites as a result of air quality:

• Policy SP1 - Spatial Strategy for the Royal Borough of Windsor and Maidenhead; • Policy QP1a - Maidenhead Town Centre Strategic Placemaking Area; • Policy QP1b - South West Maidenhead Strategic Placemaking Area; • Policy QP1c - Ascot Centre Strategic Placemaking Area; • Policy HO1 - Housing Development Sites; and • Policy ED1 – Economic Development.

5.1.2 In addition, all housing, employment and green space allocations were considered to have the potential to cause LSEs in terms of air quality (see allocations screening summary in Appendix B).

5.1.3 The Ricardo Energy & Environment air quality work (Appendix I) screened in LSEs at the following European sites:

• Chilterns Beechwoods SAC; • South West London Waterbodies SPA; • South West London Waterbodies Ramsar; • Thames Basin Heaths SPA; • Thursley, Ash, Pirbright and Chobham SAC; and • Windsor Forest and Great Park SAC.

5.1.4 As part of the air quality appropriate assessment Ricardo Energy & Environment undertook further analysis in the form of consultation with Natural England, site visits and consideration of pollution increases in the context of European site conservation objectives. This was based on modelled air quality results as presented in the Air Quality Report. The outputs of this work are presented in Appendix I.

5.1.5 The Ricardo Energy & Environment work concluded that there will be no adverse impact on site integrity (AIOSI) at any European site from the BLPSV-PC (either alone or in-combination) due to changes in air quality.

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6.1.1 The HRA screening process concluded that the following policies have the potential to result in LSEs at a number of European sites as a result of public access and disturbance:

6.1.2 In addition, a number of housing allocations were considered to have the potential to cause LSEs in terms of public access and disturbance (see allocations screening summary in Appendix B). The only exception is Site AL24 which is located over 5km from any European site.

6.1.3 European sites where public access and disturbance LSEs are considered likely include the following:

• Burnham Beeches SAC; • Chilterns Beechwoods SAC; • Thames Basin Heaths SPA; and • Windsor Forest and Great Park SAC.

6.2 Existing mitigation provided by the BLPSV-PC

6.2.1 It is anticipated that the following policies which comprise the BLPSV-PC will have a positive impact and contribute towards the mitigation of public access and disturbance threats at European sites.

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• Policy NR2 – Nature Conservation. This policy notes that “designated sites of international and national importance, will be maintained, protected and enhanced”. • Policy NR4 – Thames Basin Heaths Special Protection Area. This is a positive policy which seeks to specifically mitigate public access and disturbance threats at the Thames Basin Heaths SPA. Its requirements are summarised in Box 4. • Policy IF4 – Open Space. This policy seeks to protect, manage and enhance open space in the Plan area. It allocates three sites as part of its green infrastructure network, AL15, AL27 and AL28. It also sets out requirements for new development to provide new open space and play facilities, or provide a financial contribution towards improving existing provision. This policy has the potential to divert recreational pressure away from European sites. • Policy QP2 – Green and Blue Infrastructure. This policy seeks to secure the borough’s green and blue infrastructure network and ensure that future development contributes to this. This policy has the potential to divert recreational pressure away from European sites. • Policy QP3 – Character and Design of New Development. This policy sets out the requirement for new development to provide adequate measures for the storage of waste, including recycling waste bins. This will have a positive contribution towards the reduction of fly tipping incidents from new residential development.

Box 4: Policy NR4 – Thames Basin Heaths Special Protection Area

1. New residential development which is likely to have significant effects on its purpose and integrity will be required to demonstrate that adequate mitigation measures are put in place to avoid any potential adverse effects. The measures will have to be agreed with Natural England who will help take a strategic approach to the management of the Special Protection Area (SPA). 2. A precautionary approach to the protection and conservation of the SPA will be taken and development will only be permitted where the Council is satisfied that this will not give rise to significant adverse effects upon the integrity of the SPA: • No sites will be allocated nor planning permission granted, for a net increase in residential development within the 400 metres exclusion zone of the Thames Basin Heath SPA because the impacts of such development on the SPA cannot be fully mitigated. • New residential development beyond 400 metres threshold but within five kilometres linear distance of the SPA boundary (the SPA zone of influence) will require appropriate mitigation and will need to make an appropriate contribution towards the provision of Suitable Alternative Natural Greenspace (SANG) and the Strategic Access Management and Monitoring (SAMM). • Development proposals between five to seven kilometres linear distance from the SPA boundary, for 50 or more residential units, will be assessed on an individual basis to ascertain whether the proposal would have a significant adverse impact on the SPA. This assessment will involve a screening of the likely significant effects of

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the development and, where the screening suggests it is necessary, an Appropriate Assessment. Where a significant adverse impact is identified then mitigation measures will be required to be delivered prior to occupation and implemented in perpetuity. 3. The following sites are defined on the Policies Map and allocated as SANG: a. Land south of Allen’s Field (extension to Allen’s Field strategic SANG) b. Land at Heatherwood Hospital and Sunningdale Park (bespoke SANGs which may also have a strategic role) Future SANG provision 4. It is likely that new strategic SANG land will need to be identified in the future to provide appropriate mitigation in the area of influence of the SPA. The Council will continue to work with partner organisations to deliver an appropriate level of SANG mitigation to mitigate the impact of new development. If insufficient SANG is available for future developments requiring mitigation, then planning permission will be refused. 5. A minimum of eight hectares of SANG land (after discounting to account for current access and capacity) should be provided per 1,000 new occupants. SANG must be secured in perpetuity. 6. An applicant may wish to provide a bespoke SANG as part of development. Such bespoke SANG provision will usually be necessary only for larger developments of 50 or more dwellings. Where that is the case, all relevant SANG standards, including standards recommended by Natural England, should be met and a contribution will have to be made towards SAMM. Access management measures will be provided strategically through cooperation between local authorities.

6.2.2 In addition, reference is made to the Thames Basin Heaths SPA SPD (Part 1)83. Policy NR4 reflects the requirements of this SPD.

6.2.3 The above policies have been taken into consideration during the examination of LSEs in the following appropriate assessment.

6.3 Burnham Beeches SAC

6.3.1 Public access and associated disturbances have been recognised as a threat to the veteran trees at Burnham Beeches SAC. This is because these are noted to be vulnerable to damage as a result of soil compaction due to trampling or vehicle movements in their root zone84.

83 RBWM. 2010. Thames Basin Heaths Special Protection Area Supplementary Planning Document (Part 1). Available at: https://www3.rbwm.gov.uk/downloads/file/3227/thames_basin_heaths_special_protection_area_spd [Date Accessed: 14.10.19]. 84 Natural England. 2014. Site Improvement Plan Burnham Beeches SAC. Available at: http://publications.naturalengland.org.uk/publication/5689860228644864 [Date Accessed: 17.10.19].

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6.3.2 As noted in Section 4.14, the work undertaken to inform the HRA for the Chiltern and South Bucks Local Plan notes that, in terms of spatial planning and recreational impacts to Burnham Beeches SAC, consideration should focus on all development in areas directly adjacent to the SAC and within a 5.6km zone of influence. It recommends that no development which would result in a net increase in housing takes place within 500m of this SAC. The Chiltern and South Bucks HRA concludes that any additional development within 5.6km of Burnham Beeches SAC has the greatest potential to increase recreational visits to the SAC.

6.3.3 One site allocation is located within 5.6km of Burnham Beeches SAC. This is Site AL38, Land East of Strande Park in Cookham and is allocated for 20 residential units. It is situated approximately 5.5km to the west of Burnham Beeches SAC. There are no allocations located within 500m of Burnham Beeches SAC.

6.3.4 There are a number of factors which will reduce recreational disturbance from Site AL38 in-combination with other plans and projects at Burnham Beeches SAC.

6.3.5 Burnham Beeches SAC is managed by the City of London. The Local Management Plan 2010 to 202085 sets out provisions to manage recreational access across the SAC and associated impacts alongside its conservational interests. This plan will help to ensure the long-term health of the veteran trees within the SAC, and in particular protection of the SACs qualifying feature - H9120 beech forests - and therefore, ensure maintenance of site integrity.

6.3.6 Each site allocation has an accompanying site proforma which can be found in Appendix C of the BLPSV-PC. The site proforma for Site AL38 indicates that development will provide a “generous network of green and blue infrastructure across the site that connects to surrounding GI networks”. This will provide on-site natural open space and links to adjoining green infrastructure for new residents.

85 City of London. 2010. Local Management Plan 2010 – 2020. Available at: https://www.cityoflondon.gov.uk/things-to-do/green-spaces/burnham-beeches-and-stoke- common/Documents/Burnham-beeches-management-plan.pdf [Date Accessed: 16.10.19].

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6.3.7 A green infrastructure site is allocated approximately 770m to the south of Site AL38 under Policy IF4 and comprises 6.43ha. This is located at Lutman Lane, Spencer’s Farm, known as Site AL28, and will comprise sports facilities, public open space and a habitat area. The site proforma notes that this site will “also link into and help extend the wider strategic green infrastructure / nature recovery network linking Maidenhead with Cookham via an alternative route to the Thames path”. This allocation will provide local open space / recreational resource for new residents.

6.3.8 Taking into consideration the positive contribution of policies in the BLPSV-PC (see Section 6.2), the location of Site AL38 at 5.5km from the SAC and the small number of dwellings proposed (20 units), it is considered that there will be no AIOSI at Burnham Beeches SAC from the BLPSV-PC (either alone or in-combination) due to public access and disturbance pressures.

6.4 Chilterns Beechwoods SAC

6.4.1 As noted in Section 4.15, public access and associated disturbances have been recognised as a threat to the habitat and populations of stag beetle (Lucanus cervus) that are associated with Chilterns Beechwoods SAC. This is due to the removal of dead wood either by the public or in the name of safety or tidiness86.

6.4.2 As set out in Table 4.2 there are fifteen residential housing allocations located within 5km of the Bisham Woods SSSI component of the Chilterns Beechwoods SAC. In total there will be 5,964 new residential units provided within 5km of the Chilterns Beechwoods SAC as a result of the BLPSV-PC 87. There are no allocations located within 500m of the SAC.

86 Natural England. 2015. Site Improvement Plan Chilterns Beechwoods SAC. Available at: http://publications.naturalengland.org.uk/publication/6228755680854016 [Date Accessed: 09.10.19]. 87 It is noted that only the northern portion of Site AL13 will be located within 5km of Bisham Woods SSSI. However, taking a precautionary approach, the development has been taken into consideration in its entirety for the purposes of this assessment.

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6.4.3 Other development within 5km of the Bisham Woods SSSI component of the Chilterns Beechwoods SAC is likely to include development specified in adjoining authority areas. The Chilterns and South Bucks Local Plan sets out provisions for 15,260 new homes between 2016-2036, with 11,000 homes to be provided within its Plan area and the remaining provision provided by Aylesbury Vale District Council (5,750 homes). The Wycombe Local Plan sets a target for 13,200 homes for the period 2013-2033 (660 homes per year). Wycombe is proposing to accommodate 10,925 homes within its Plan area, with the ‘unmet need’ provided by Aylesbury Vale District Council (see Appendix G for more information).

6.4.4 There are a number of factors which will reduce public access and disturbance from the BLPSV-PC in-combination with other plans and projects at Chilterns Beechwoods SAC.

6.4.5 Bisham Woods SSSI is managed by the Woodland Trust. The woods contain a number of public rights of way, including restricted byways, bridleways and footpaths serving pedestrians, horse riders and cyclists. There is limited parking in the form of pull-ins along Quarry Wood Road, Grubswood Lane and Marlow Road which limits access to this site88. The Woodland Trust have prepared a Management Plan for the woodland covering the period from 2018 to 202389 and actively manage this habitat. This Management Plan recognises the potential threats associated with increased public access pressure at the woodland and, as such, maintains a well-managed network of paths and signage. It states that “deadwood will be allowed to accumulate wherever possible, with all windblown trees and the majority of trees felled for safety reasons left to decompose naturally. In this way the deadwood habitat will continue to support a viable population of stag beetles, as well as many other invertebrates and fungi”.

88 The Woodland Trust. Bisham Woods. Available at: https://www.woodlandtrust.org.uk/visiting- woods/woods/bisham-woods/ [Date Accessed: 17.10.19]. 89 Woodland Trust. 2018. Bisham Woods Woodland Management Plan. Available at: https://www.woodlandtrust.org.uk/media/44628/4424-bisham-woods.pdf [Date Accessed: 17.10.19].

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6.4.6 The site proformas (provided in Appendix C of the BLPSV-PC) for the allocations located within 5km of Bisham Woods SSSI contain a requirement for development to provide a network of green and blue infrastructure across the site that connects to surrounding GI networks, and for the larger sites, a requirement to include on-site public open space and leisure facilities. In addition, Policy IF4 sets out allocations for strategic green infrastructure sites. Together, these will provide on and off-site natural open spaces for new residents with links to adjoining green infrastructure.

6.4.7 A review has been undertaken to determine the existing recreational resource in RBWM and the immediate surrounding area. This is provided at Appendix H. There are a number of existing recreational resources with similar character types to Bisham Woods SSSI in and adjacent to the Plan area. These include Cliveden, Park Wood, High Wood, Goulding's Wood, Carpenters Wood, Dungrovehill Wood and Great Thrift Wood. These areas are likely to provide recreational destinations for residents at allocations provided in the BLPSV-PC.

6.4.8 Taking into consideration the management of Bisham Woods SSSI, the availability of existing recreational resource and the positive contribution of policies in the BLPSV-PC (see Section 6.2), it is considered that there will be no AIOSI on Chilterns Beechwoods SAC from the BLPSV-PC (either alone or in-combination) due to public access and disturbance pressures.

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6.5 Thames Basin Heaths SPA

6.5.1 As noted in Section 4.17, public access and associated disturbances have been recognised as a threat to the qualifying features of the Thames Basin Heaths SPA: European Nightjar, Woodlark and Dartford Warbler. The SIP notes that “parts of Thames Basin Heaths are subject to high levels of recreational use and dog walkers make up a large proportion of visitors. This is likely to be affecting the distribution and overall numbers of ground-nesting Annex 1 birds (and breeding success). An 'avoidance strategy' is in place to help manage this pressure, including the provision of Suitable Accessible Natural Green Space (SANGS). However, recreational pressure may be hampering the potential for the sites to achieve their full contribution to sustainable national populations”90.

6.5.2 As set out in Table 4.4, there are eight residential housing allocations located within 5km of the Thames Basin Heaths SPA. In total there will be 781 new residential units provided within 5km of the site as a result of the BLPSV-PC. There are no allocations located within 500m of the SAC. There are no allocations located between 5-7km of the SAC for 50 houses or more.

6.5.3 Other development in neighbouring authorities which also lie within 5km of the components of the Thames Basin Heath SPA closest to the BLPSV- PC boundary have the potential to result in an in-combination effect. These are likely to include development set out in the Bracknell Forest Local Plan (12,060 homes for the period 2016/17 to 2033/34) and the Surrey Heath District Local Plan (4,901 new homes between 2016 and 2032) – see Appendix G for more information.

90 Natural England. 2014. Site Improvement Plan Thames Basin. Available at: http://publications.naturalengland.org.uk/publication/6249258780983296 [Date Accessed: 09.10.19].

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6.5.4 Following the advice of the Assessor for the South East Plan91 a Joint Strategic Partnership Board was set up in 2006. The membership of the group consists of representatives from all the eleven local authorities affected by the SPA, including RBWM. The purpose of the group was to discuss and develop a strategic approach to manage issues at the Thames Basin Heaths SPA. This resulted in the development of the Thames Basin Heaths SPA Delivery Framework. The details of this are set out in Section 4.13. This framework guides local authorities in preparing their own detailed mitigation strategies. RBWM have an SPD in place to deal with associated mitigation. This is also set out in a bespoke policy in the BLPSV-PC; Policy NR4 – Thames Basin Heaths Special Protection Area (see Box 4).

6.5.5 Development specified in the BLPSV-PC (and that specified in neighbouring authority plan areas) will be required to comply with the Thames Basin Heaths SPA Delivery Framework (provided for in RBWM under Policy NR4). It will be required to, where necessary, provide SANGS and contributions towards the provision of the Strategic Access Management and Monitoring Strategy (SAMMS). It can therefore be concluded that there will be no AIOSI at Thames Basin Heaths SPA (either alone or in-combination) due to public access and disturbance pressures.

6.6 Windsor Forest and Great Park SAC

6.6.1 As noted in Section 4.18, whilst the SIP92 does not identify public access and disturbance as a threat or pressure for Windsor Forest and Great Park, the supplementary advice from Natural England notes that ancient trees are vulnerable to soil compaction around the root zone. Natural England’s supplementary advice states that “the location of host trees supporting this species at Windsor Forest and Great Park is known from capture records. However, given the elusive nature of the species it is possible that it may be more widespread or at least present in other locations at the site. Therefore, the same principles applied for the protection of the veteran tree element of the site should be applied in relation to violet click beetle”.

91 The South East Plan was revoked on 06 July 2010 and no longer forms part of the development plan for the region. 92 Natural England. 2014. Site Improvement Plan: Windsor Forest and Great Park. Available at: http://publications.naturalengland.org.uk/publication/6221375450644480. [Date Accessed: 10.10.19].

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6.6.2 As set out in Table 4.5, there are seventeen allocations located within 5km of Windsor Forest and Great Park SAC. In total there will be 4,472 new residential units provided within 5km of the site as a result of the BLPSV-PC.

6.6.3 Other development in neighbouring authorities which also lies within 5km Windsor Forest and Great Park SAC has the potential to result in an in- combination effect. These are likely to include development set out in the Bracknell Forest Local Plan (12,060 homes for the period 2016/17 to 2033/34) and the Runneymede Local Plan (7,480 additional homes in the period 2015-2030) – see Appendix G for more information.

6.6.4 There are a number of factors which will reduce public access and disturbance from the BLPSV-PC in-combination with other plans and projects at Windsor Forest and Great Park SAC.

6.6.5 Windsor Forest and Great Park SAC is managed by The Crown Estate. It manages tourism and recreation at four key sites (listed below) within the Windsor Great Park Estate93, with a range of parking, eating and shopping facilities provided at each. These main attractions are located outside the SAC designated area. However, there are a number of well signed and managed footpaths which are located within the SAC e.g. a lakeside path around Virginia Water.

• The Savill Garden - a garden and woodland site; • Virginia Water – lake and woodland; • The Valley Gardens – formal gardens; and • The Long Walk and Deer Park – tree lined avenue.

6.6.6 The site proformas (provided in Appendix C of the BLPSV-PC) for the allocations located within 5km of Windsor Forest and Great Park SAC contain a requirement for development to provide a network of green and blue infrastructure across the site that connects to surrounding GI networks and for the larger sites, a requirement to include on-site public open space and leisure facilities. In addition, Policy IF4 sets out allocations for strategic green infrastructure sites. Together these will provide on and off-site natural open spaces for new residents with links to adjoining green infrastructure.

93 Windsor Great Park Interactive Map. https://www.windsorgreatpark.co.uk/en/interactive- map?s=0,0,1,0,0,0,0,0,0,0,0,0,0,1,0,0,0,1,0,0,1,1,1&map=51.4184482,-0.6200220,15 [Date Accessed: 23.10.19].

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6.6.7 A review has been undertaken to determine the existing recreational resource in RBWM and the immediate surrounding area. This is provided at Appendix H. There are a number of existing recreational resources with similar character types to Windsor Forest and Great Park SAC. These include Cliveden, Home Park, Ockwells Park, Allens Field and areas of the Windsor Forest and Great Park Estate which do not comprise part of the SAC; Savill Garden, The Valley Gardens, Virginia Water and The Long Walk and Deer Park. These areas are likely to also provide recreational destinations for residents at allocations provided in the BLPSV-PC.

6.6.8 Taking into consideration the management of Windsor Forest and Great Park, availability of existing recreational resource and the positive contribution of policies in the BLPSV-PC (see Section 6.2) it is considered that there will be no AIOSI at Windsor Forest and Great Park SAC from the BLPSV-PC (either alone or in-combination) due to public access and disturbance pressures.

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7.1.1 The following policies were deemed to have the potential to result in an LSEs at a number of European sites as a result of hydrological change:

7.1.2 In addition, a number of housing allocations were considered likely to have the potential to cause LSEs in terms of hydrological change (see allocations screening summary in Appendix B).

7.1.3 The European sites where hydrology related LSEs were deemed possible included:

• South West London Waterbodies SPA; • South West London Waterbodies Ramsar; • Thames Basin Heaths SPA; • Thursley, Ash, Pirbright and Chobham SAC; and • Windsor Forest and Great Park SAC.

7.2 Existing mitigation provided by the BLPSV-PC

7.2.1 It is anticipated that the following policies which comprise the BLPSV-PC will have a positive impact and contribute towards the mitigation of hydrology threats at European sites.

• Policy NR2 – Nature Conservation. This policy notes that “designated sites of international and national importance, will be maintained, protected and enhanced”. • Policy IF7 – Utilities. This policy states that development should demonstrate adequate water supply and sewerage infrastructure capacity both on and off site in liaison with water / wastewater companies. This is a positive policy as it aims to ensure that the

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sewerage network has sufficient capacity to serve existing and new development, therefore preventing a reduction in water quality. • Policy NR1 – Managing Flood Risk and Waterways. This policy notes that development proposals should incorporate Sustainable Urban Drainage Systems (SuDS). SuDS aim to result in a positive overall improvement in water quality discharge to the sewer network, surface water run-off and ground water infiltration.

7.2.2 The above policies have been taken into consideration during the examination of LSEs in the following appropriate assessment.

7.3 South West London Waterbodies SPA and Ramsar

7.3.1 As noted in Section 4.22, the SIP for the South West London Waterbodies SPA notes that water quality is determined by a range of factors associated with the quality of surface water feeder streams and groundwater supply94.

7.3.2 The South West London Waterbodies SPA and Ramsar were considered during the HRA screening process to potentially be hydrologically linked to the RBWM Plan area via surface and groundwater pathways. This is due to the location of South West London Waterbodies SPA and Ramsar within the same operational catchments as allocations proposed in the Plan. In addition, surface water was noted to flow in an easterly direction from the Plan area towards the River Thames and these designated sites. Both the Plan area and South West London Waterbodies SPA and Ramsar are also located within the Thames groundwater management catchment.

7.3.3 As noted in Section 4.19, the Water Impact Assessment undertaken by JBA concludes that increasing wastewater effluent volumes discharged as a result of growth could constitute a potential point-source of pollution. In addition, the assessment noted that development sites may be sources of diffuse pollution from surface water runoff. These sources could cause a deterioration in surface and ground water quality.

94 Natural England. 2018. European Site Conservation Objectives: Supplementary advice on conserving and restoring site features. South West London Waterbodies Special Protection Area (SPA) Site code: UK9012171. Available at: http://publications.naturalengland.org.uk/publication/4901473695563776 [Date Accessed: 02/10/19].

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7.3.4 Recommendations as set out in the Water Quality Impact Assessment have been incorporated into Policies IF7 and NR1. These will ensure that diffuse and point-source pollution associated with development as set out in the Plan would be mitigated through the consideration of sewerage capacity and incorporation of SuDS.

7.3.5 Taking into consideration the positive contribution of policies in the BLPSV-PC, it is considered that there will be no AIOSI at South West London Waterbodies SPA and Ramsar from the BLPSV-PC (either alone or in-combination) due to hydrology issues.

7.4 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC

7.4.1 As noted in Section 4.23, hydrological changes have been identified as a threat to the Thursley, Ash, Pirbright and Chobham SAC (Elstead Common and Thursley and Ockley Commons) due to drainage. The habitat particularly vulnerable to changes in hydrology is the wet heath habitat.

7.4.2 The closest allocations to the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC include Site AL34 and Site AL33. These are located approximately 564m to the west and 430m to the north west, respectively, from the SAC and SPA.

7.4.3 Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC were considered during the HRA screening process to potentially be hydrologically linked to the RBWM Plan area via surface and groundwater pathways. This is due to the location of the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC within the same operational catchments as allocations proposed in the BLPSV-PC and the proximity of the allocations to the closest component of this designation.

7.4.4 As noted in Section 4.19, the Water Impact Assessment undertaken by JBA concludes that increasing wastewater effluent volumes discharged as a result of growth could constitute a potential point-source of pollution. In addition, the assessment noted that development sites may be sources of diffuse pollution from surface water runoff. These sources could cause a deterioration in surface and ground water quality.

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7.4.5 Recommendations as set out in the Water Quality Impact Assessment have been incorporated into Policies IF7 and NR1. These will ensure that diffuse and point-source pollution associated with development set out in the Plan would be mitigated through the consideration of sewerage capacity and incorporation of SuDS.

7.4.6 Taking into considered the positive contribution of policies in the BLPSV- PC, it is considered that there will be no AIOSI at Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC from the BLPSV-PC (either alone or in-combination) due to hydrology issues.

7.5 Windsor Forest and Great Park SAC

7.5.1 As noted in Section 4.24, the SIP for Windsor Forest and Great Park SAC notes that hydrological change is a threat to the beech forest and oak dominated woodlands. It is necessary that the natural hydrological processes are maintained to sustain the qualifying features of this European site.

7.5.2 The closest allocations, which are located upstream and have the potential to be hydrologically linked to the SAC, include those located in Windsor and Ascot. The closest allocation (Site AL31) is situated 540m to the north east of Windsor Forest and Great Park SAC. Streams from Ascot flow in a southerly direction towards Virginia Water before joining the River Thames. The SAC is not connected with the Thames groundwater management catchment.

7.5.3 As noted in Section 4.19, the Water Impact Assessment undertaken by JBA concludes that increasing wastewater effluent volumes discharged as a result of growth could constitute a potential point-source of pollution. In addition, the assessment noted that development sites may be sources of diffuse pollution from surface water runoff. These sources could cause a deterioration in surface and ground water quality.

7.5.4 Recommendations as set out in the Water Quality Impact Assessment have been incorporated into Policies IF7 and NR1. These will ensure that diffuse and point-source pollution associated with development set out in the Plan would be mitigated through the consideration of sewerage capacity and incorporation of SuDS.

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7.5.5 Taking into considered the positive contribution of policies in the BLPSV- PC, it is considered that there will be no AIOSI at Windsor Forest and Great Park SAC from BLPSV-PC (either alone or in-combination) due to hydrology issues.

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8.1 Summary

8.1.1 Following consideration of the nature and extent of potential impact pathways from the BLPSV-PC and their relationship to European sites, seven SACs, SPAs and Ramsar sites have been considered in the HRA process. These include the following:

8.1.2 The HRA screening exercise outlined the threats and pressures that have the potential to undermine the conservation objectives of each European site.

8.1.3 Where LSEs were identified further, more detailed, assessment was undertaken in the form of the HRA appropriate assessment. The appropriate assessment identified potential adverse effects on site integrity at a number of European sites as a result of the BLPSV-PC alone and/or in-combination with other plans and programmes:

• Burnham Beeches SAC in relation to public access and disturbance pressures and threats; and • Chiltern Beechwoods SAC in relation to air quality and public access and disturbance pressures and threats. • South West London Waterbodies SPA in relation to air quality, hydrology pressures and threats. • South West London Waterbodies Ramsar in relation to air quality, hydrology pressures and threats. • Thames Basin Heaths SPA in relation to air quality, public access and disturbance and hydrology pressures and threats. • Thursley, Ash, Pirbright and Chobham SAC in relation to air quality and hydrology pressures and threats. • Windsor Forest and Great Park SAC in relation to air quality, public access and disturbance and hydrology pressures and threats.

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8.1.4 The appropriate assessment considered mitigation set out in both the BLPSV-PC and within other plans and projects. It has concluded that, following the application of this mitigation, the BLPSV-PC would have no AIOSI at any European site either alone or in-combination.

8.2 Next steps

8.2.1 The purpose of this report is to inform the HRA of the BLPSV-PC using best available information.

8.2.2 The Council, as the Competent Authority, has a responsibility to carry out the Integrity Test, which can be undertaken in light of the conclusions set out in this report.

8.2.3 This report will be submitted to Natural England, the statutory nature conservation body, for formal consultation. The Council must ‘have regard’ to their representations under the provisions of Regulations 63(3) and 105(2) prior to making a final decision as to whether they will ‘adopt’ the conclusions set out within this report as their own.

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Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion

Spatial Strategy

SP1 Spatial Strategy for the LSEs Screened in Royal Borough of Whilst this policy will not lead to development in itself, it sets out the intended spatial Windsor and Maidenhead distribution of development over the Plan period. It will therefore trigger development in the Plan area through other policies and allocations set out within the Local Plan. Dependent on the location and types of development (assessed in detail in Appendix B), this policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 – 4.28 of the Report to Inform the HRA). LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

SP2 Climate Change No LSEs. Screened out This policy relates to design. It is a positive policy that includes text to incorporate measures to adapt to climate change. This policy itself does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category B.

Quality of Place QP1 Sustainability and No LSEs. Screened out Placemaking This policy relates to design. It is a positive policy as it includes text relating to place making for development within the Plan. This policy itself does not trigger change or

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category B.

QP1a Maidenhead Town Centre LSEs Screened in Strategic Placemaking This policy sets out the location of allocated sites. Area This policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 and 4.30 of the Report to Inform the HRA). LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

QP1b South West Maidenhead LSEs Screened in Strategic Placemaking Area This policy sets out the location of allocated sites. This policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 and 4.30 of the Report to Inform the HRA). LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

QP1c Ascot Centre Strategic LSEs Screened in Placemaking Area This policy sets out the location of allocated sites.

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion This policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 and 4.30 of the Report to Inform the HRA). LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

QP2 Green and Blue No LSEs. Screened out Infrastructure This is a positive policy as it provides for the retention and extension of green infrastructure which has potential to divert recreational pressure away from European sites. It also provides for the restoration of water features including SuDS which have positive effects on water quality and quantity. This policy does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Categories B and F.

QP3 Character and Design of No LSE. Screened out New Development This policy relates to the character and design of new development. It is a positive policy as it includes text relating to sustainable high-quality design. This policy does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Categories B and F.

QP3a Building Height and Tall No LSE. Screened out Buildings This policy relates to building height and tall buildings. This policy does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

QP4 River Thames Corridor No LSE. Screened out This policy relates to the protection of the character and setting of the River Thames. It is

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion a positive policy as it includes text relating to the conservation of the ecological value of the river in line with the River Basin Management Plan (RBMP). This policy does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

QP5 Rural Development No LSE. Screened out This policy relates to the protection of the Green Belt and rural uses. It does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Housing

HO1 Housing Development LSE. Screened in Sites This policy identifies a quantum of new homes (with reference to allocation sites on the Policies Map) to be provided during the Plan period. Dependent on the location and types of development (assessed in detail in Appendix B) this policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 and 4.30 of the Report to Inform the HRA). LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

HO2 Housing Mix and Type No LSE. Screened out This policy sets out requirements for the mix and types of homes but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion

HO3 Affordable Housing No LSE. Screened out This policy sets out requirements for affordable housing but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

HO4 Gypsies and Travellers No LSE. Screened out This policy sets out design requirements for gypsies and travellers’ sites but does not trigger change or development within the Plan area itself. The quantum and location of gypsy and traveller sites will be set out in the separate Traveller Local Plan which will be subject to HRA. This policy on its own would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

HO5 Loss and Subdivision of No LSE. Screened out Dwellings This policy sets out requirements for loss and subdivision of dwellings but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Economy

ED1 Economic Development LSE. Screened in This policy identifies a quantum and location of employment development (referencing allocation sites on the Policies Map) to be provided during the Plan period. Dependent on the location and types of development (assessed in detail in Appendix B) this policy is likely to result in the following impact pathways at European sites: - Air Quality; - Public Access and Disturbance; and - Hydrology. The screening assessment has indicated that there are unlikely to be pathways associated with wildfire and arson or habitat loss / fragmentation (see Sections 4.26 and 4.30 of the Report to Inform the HRA).

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

ED2 Protected Employment No LSE. Screened out Sites This policy sets out protections for employment sites but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

ED3 Other Sites and Loss of No LSE. Screened out Employment Floorspace This policy sets out requirements for other employment sites and loss of employment floorspace but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

ED4 Farm Diversification No LSE. Screened out This policy sets out requirements for farm diversification but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Town Centres and Retail

TR1 Hierarchy of Centres No LSE. Screened out This policy sets out the hierarchy of town centres but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR2 Windsor Town Centre No LSE. Screened out This policy sets out retail design requirements for Windsor Town Centre but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR3 Maidenhead Retail Centre No LSE. Screened out This policy sets out retail design requirements for Maidenhead Retail Centre but does not

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR4 District Centres No LSE. Screened out This policy sets out retail requirements for the District Centres but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR5 Local Centres No LSE. Screened out This policy sets out retail requirements for the Local Centres but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR6 Strengthening the Role of No LSE. Screened out Centres This policy sets out retail requirements for the strengthening the role of centres but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR7 Shops and Parades No LSE. Screened out Outside Defined Centres This policy sets out retail requirements for the shops and parades outside defined centres but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

TR8 Markets No LSE. Screened out This policy sets out retail requirements for markets but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Visitors and Tourism VT1 Visitor Development No LSE. Screened out This policy sets out design requirements for visitor development but does not trigger

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Historic Environment

HE1 Historic Environment No LSE. Screened out This is a policy relating to heritage assets. These spaces have the potential to act in a way that may divert recreational pressure away from European sites. The policy is positive in nature, does not trigger any development or change and can therefore be screened out under Category F.

HE2 Windsor Castle and Great No LSE. Screened out Park This is a policy relating to safeguarding the architectural and historical significance of Windsor Castle and Great Park. This asset has the potential to act in a way that may divert recreational pressure away from the qualifying features of the Windsor Forest and Great Park SAC. The policy is positive in nature, does not trigger any development or change and can therefore be screened out under Category F.

Natural Resources NR1 Managing Flood Risk and No LSE. Screened out Waterways This policy sets out the sequential approach to be adopted for developments in terms of flood risk. It sets out the requirement for developments to consider the inclusion of SuDS in terms of flood risk. This would have secondary positive impacts in terms of improving water quality. The policy is positive in nature, does not trigger any development or change and can therefore be screened out under Category F.

NR2 Nature Conservation & No LSE. Screened out Biodiversity This policy relates to the protection of designated sites and protected species and improving biodiversity. It includes text that states, ‘designated sites of international and national importance, will be maintained, protected and enhanced.’ This policy will have positive effects for the protection of European sites and their qualifying features and has therefore been screened out under Category D.

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion

NR3 Trees, Woodlands and No LSE. Screened out Hedgerows This policy relates to the protection trees, woodlands and hedgerows in the Plan area. It will have positive effects for ecological receptors and has therefore been screened out under Category D.

NR4 Thames Basin Heaths LSE. Screened in Special Protection Area This policy requires new residential development to provide adequate mitigation measures to avoid any potential adverse effects on the Thames Basin Heaths SPA. This policy is a bespoke policy intended to avoid or reduce harmful effects on a European site and has therefore been screened in under Category M.

NR5 Renewable Energy No LSE. Screened out This policy relates to the production of renewable energy in the Plan area. It does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Environmental Protection

EP1 Environmental Protection No LSE. Screened out This policy relates to environmental protection trees in terms of landscape, pollution, contamination and environmental enhancement. It will have positive effects for ecological receptors in the Plan area and has therefore been screened out under Category D.

EP2 Air Pollution No LSE. Screened out This policy relates to minimising air pollution, with a particular focus on human health. It will have knock-on positive impact at ecological receptors in the Plan area and has therefore been screened out under Category D.

EP3 Artificial Light Pollution No LSE. Screened out This policy relates to minimising artificial light pollution. It will have positive impacts at

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion ecological receptors in the Plan area and has therefore been screened out under Category D.

EP4 Noise No LSE. Screened out This policy relates to minimising noise pollution. It will have positive impacts at ecological receptors in the Plan area and has therefore been screened out under Category D.

EP5 Contaminated Land and No LSE. Screened out Water This policy relates to contaminated land and water pollution. It will have positive impacts on water quality in the Plan area and has therefore been screened out under Category D.

Infrastructure

IF1 Infrastructure and No LSE. Screened out Developer Contributions This policy sets out requirements for infrastructure and development contributions but does not trigger change or development within the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

IF2 Sustainable Transport No LSE. Screened out This policy sets out requirements for delivery of a modal shift to more sustainable forms of transport, development of transport assessments and plans. This will have positive air quality impacts. It does not trigger change or development within the Plan area. Whilst reference is not specifically made to water quality, this policy requires that SuDS are incorporated into transport infrastructure. This will have secondary benefits in terms of safeguarding water quality. It is therefore screened out under Category F.

IF3 Local Green Space No LSE. Screened out This policy sets out protections for local green space. It does not trigger change or development within the Plan area. It is therefore screened out under Category F.

IF4 Open Space LSE. Screened in This policy sets out protections for existing open space and allocations of new and upgraded open space. In addition, it sets out requirements in terms of open spaces at

Policy Number Policy Justification: Activities that may result in a LSE on a European site. Screening conclusion new residential developments which will have positive impacts for European sites by providing alternative recreational provision. Given this policy proposes new areas of open space, it has been screened in the assessment under Category M.

IF5 Rights of Way and Access No LSE. Screened out to the Countryside This policy sets out requirements for the protection and improvement of the existing rights of way network. This will encourage walking and cycling with positive air quality impacts. It does not trigger change or development within the Plan area. It is therefore screened out under Category F.

IF6 Community Facilities No LSE. Screened out This policy sets out requirements for community facilities. It does not trigger change or development within the Plan area. It is therefore screened out under Category F.

IF7 Utilities No LSE. Screened out This policy sets out requirements for utilities. In particular, it notes that development should demonstrate that adequate water supply and sewerage infrastructure exists to serve that development. It also notes that new water resource schemes which meet current and future water supply needs will be supported. This will have a positive impact on water resources at European sites. It does not trigger change or development within the Plan area. It is therefore screened out under Category F.

Appendix B: Allocations Screening Summary

Figure B.1: Allocation Locations: Figure 1 of 3

Figure B.2: Allocation Locations: Figure 2 of 3

Figure B.3: Allocations Location: Figure 3 of 3

Table B.1: Screening summary of allocations in the Local Plan

AL1 Nicholsons Mixed use 2.47 500 units In-combination Located within This allocation is No No LSE Centre, impact (Chiltern 5km of Chiltern located in the same 22,000 sqm Screened Maidenhead Beechwoods SAC, Beechwoods SAC operational in South West (Bisham Woods catchment (the London SSSI) Lower Thames) as Category L Waterbodies SPA sections of the and Ramsar, South West Thames Basin London Heaths SPA, Waterbodies SPA Thursley, Ash, and upstream of Pirbright and this designation. Chobham SAC and Windsor Forest and Great Park SAC).

AL2 Land Mixed use 0.96 300 units (32 In-combination Located within This allocation is No No LSE already in impact (as above). 5km of Chiltern located in the same between Screened commitments) Beechwoods SAC operational in High Street (Bisham Woods catchment (the and West SSSI) Lower Thames) as Category L Street, sections of the Maidenhead South West London Waterbodies SPA and upstream of this designation.

AL3 St Mary’s Mixed use 0.32 120 units In-combination Located within This allocation is No No LSE Walk, impact (as above). 5km of Chiltern located in the same Screened Maidenhead Beechwoods SAC operational in (Bisham Woods catchment (the SSSI) Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL4 York Road Mixed use 2.51 450 units In-combination Located within This allocation is No No LSE (340 already impact (as above). 5km of Chiltern located in the same Screened in Beechwoods SAC operational in commitments) (Bisham Woods catchment (the SSSI) Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL5 West Street Mixed use 0.96 240 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chiltern located in the same Screened Beechwoods SAC operational in (Bisham Woods catchment (the SSSI) Lower Thames) as Category L sections of the

AL6 Methodist Mixed use 0.20 50 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chiltern located in the same Church, High Screened Beechwoods SAC operational in Street, (Bisham Woods catchment (the Maidenhead SSSI) Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL7 Maidenhead Mixed use 3.11 150 units In-combination Located within This allocation is No No LSE Railway impact (as above). 5km of Chiltern located in the same 7,000 sqm Screened Station Beechwoods SAC operational in (Bisham Woods catchment (the SSSI) Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL8 St Cloud Employment 0.19 3,500 sqm In-combination Employment – n/a This allocation is No No LSE Gate, impact (as above). located in the same Screened Maidenhead operational in (air catchment (the quality Lower Thames) as only) sections of the South West Category L London Waterbodies SPA and upstream of this designation.

AL9 Saint-Cloud Mixed use 2.52 550 units In-combination Located within This allocation is No No LSE Way impact (as above). 5km of Chiltern located in the same Screened Beechwoods SAC operational in (Bisham Woods catchment (the SSSI) Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL10 Stafferton Mixed use 1.89 350 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chiltern located in the same Way Retail Screened Beechwoods SAC operational in Park, (Bisham Woods catchment (the Maidenhead SSSI) Lower Thames) as Category L sections of the

AL11 Crossrail Employment 1.17 4,500 sqm In-combination Employment – n/a This allocation is No No LSE impact (as above). located in the same West Outer Screened operational in (air Depot, catchment (the quality Maidenhead Lower Thames) as only) sections of the South West Category L London Waterbodies SPA and upstream of this designation.

AL12 Land to east Residential 0.47 50 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chiltern located in the same of Braywick Screened Beechwoods SAC operational in Gate, (Bisham Woods catchment (the Braywick SSSI) Lower Thames) as Category L Road, sections of the Maidenhead South West London Waterbodies SPA and upstream of this designation.

AL13 Desborough, Mixed use 89.93 2,600 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chiltern located in the same Harvest Hill Screened Beechwoods SAC operational in Road, South (Bisham Woods catchment (the West SSSI) Lower Thames) as Category L Maidenhead sections of the South West London Waterbodies SPA and upstream of this designation.

AL14 The Triangle Employment 25.70 25.70ha In-combination Employment – n/a This allocation is No No LSE impact (as above). located in the same Site (land Screened operational in (air south of the catchment (the quality Lower Thames) as A308(M) only) west of sections of the South West Category L Ascot Road London and north of Waterbodies SPA the M4), and upstream of this designation. Maidenhead

AL15 Braywick Green 54.1 Strategic In-combination No No No No Screened Park, infrastructure green impact (as above). in Maidenhead infrastructure Category L site and M

AL16 Ascot Centre, Mixed use 12.30 300 units In-combination Located within Located upstream No No LSE Ascot impact (as above). 5km of Thames of Windsor Forest 900 sqm Screened Basin Heaths SPA, and Great Park in Thursley, Ash, SAC and within the Pirbright and same operational Category L Chobham Common catchment, the SAC and Windsor Wey. Forest and Great Park SAC.

AL17 Shorts Residential 5.80 131 units In-combination Located within Located upstream No No LSE impact (as above). 5km of Thames of Windsor Forest Waste Screened Basin Heaths SPA, and Great Park in Transfer Thursley, Ash, SAC and within the Station and Pirbright and same operational Category L Recycling Chobham Common catchment, the Facility, St SAC and Windsor Wey. Forest and Great Georges Park SAC. Lane, Ascot

AL18 Ascot Station Mixed use 1.14 50 units In-combination Located within Located upstream No No LSE Car Park impact (as above). 5km of Thames of Windsor Forest Screened Basin Heaths SPA, and Great Park in Thursley, Ash, SAC and within the Pirbright and same operational Category L Chobham Common catchment, the SAC and Windsor Wey. Forest and Great Park SAC.

AL19 Englemere Residential 0.65 10 units In-combination Located within No No No LSE Lodge, Ascot impact (as above). 5km of Thames Screened Basin Heaths SPA, in Thursley, Ash, Pirbright and Category L Chobham Common SAC and Windsor Forest and Great Park SAC.

AL20 Heatherwood Mixed use 6.95 250 units In-combination Located within Located upstream No No LSE Hospital, impact (as above). 5km of Thames of Windsor Forest Screened Ascot Basin Heaths SPA, and Great Park in Thursley, Ash, SAC and within the Pirbright and same operational Category L Chobham Common catchment, the SAC and Windsor Wey. Forest and Great Park SAC.

AL21 Land west of Mixed use 22.76 450 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Windsor located in the same Windsor, Screened Forest and Great operational in north and Park SAC. catchment (the south of the Lower Thames) as Category L A308, sections of the Windsor South West London Waterbodies SPA.

AL22 Squires Residential 0.74 39 units In-combination Located within No No No LSE impact (as above). 5km of Windsor Garden Screened Forest and Great in Centre Park SAC. Maidenhead Category L Road Windsor

AL23 St. Marks Residential 1.55 54 units In-combination Located within This allocation is No No LSE Hospital, impact (as above). 5km of Chilterns located in the same Screened Maidenhead Beechwoods SAC operational in (Bisham Woods catchment (the SSSI). Lower Thames) as Category L sections of the South West London Waterbodies SPA and upstream of this designation.

AL24 Land East of Mixed use 16.69 300 units In-combination No This allocation is No No LSE impact (as above). located in the same Woodlands Screened operational in (air Park Avenue catchment (the quality and North of Lower Thames) as only) Woodlands sections of the Category L Business South West London Park, Waterbodies SPA Maidenhead and upstream of this designation.

AL25 Land known Mixed use 13.51 330 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chilterns located in the same as Spencer's Screened Beechwoods SAC operational Farm, North in (Bisham Woods catchment (the of Lutman SSSI). Lower Thames) as Category L Lane, sections of the Maidenhead South West London Waterbodies SPA and upstream of this designation.

AL26 Residential 3.99 100 units In-combination Located within This allocation is No No LSE Land impact (as above). 5km of Windsor located in the same Screened between Forest and Great operational in Windsor Park SAC. catchment (the Category L Road and Lower Thames) as sections of the

Bray Lake, South West London south of Waterbodies SPA Maidenhead and upstream of this designation.

AL27 Land south Green 2.29 Green In-combination No No No No Screened infrastructure infrastructure impact (as above). in of Ray Mill site Category L Road East, and M Maidenhead

AL28 Land north Green 6.43 Green In-combination No No No No Screened infrastructure infrastructure impact (as above). in of Lutman site Category L Lane, and M Spencer’s Farm, Maidenhead

AL29 Minton Mixed use 0.53 100 units In-combination Located within No No No LSE impact (as above). 5km of Windsor Place, Screened Forest and Great in Victoria Park SAC and Street, South West Category L Windsor London Waterbodies SPA.

AL30 Windsor and Residential 0.85 30 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Windsor located in the same Eton Screened Forest and Great operational in Riverside Park SAC and catchment (the Station Car South West Lower Thames) as Category L Park London sections of the Waterbodies SPA. South West London Waterbodies SPA. Slough WwTW is located upstream from the South West London Waterbodies SPA on the River Thames. This development will feed into this WwTW (the Water Quality Impact Assessment notes that this WwTW serves Eton and Datchet).

AL31 King Edward Residential 0.72 47 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Windsor located with 540m VII Hospital, Screened Forest and Great of Windsor Forest in Windsor Park SAC and

Site Site Address Site use Area Housing Air quality Impact Recreation Impact Hydrological link to Habitat Wildfire / Screening Reference (ha) number / a European site loss / arson risk conclusion Number employment fragmentat sqm. (if ion? applicable) South West and Great Park Category L London SAC. Waterbodies SPA. Sandridge AL32 Residential 0.49 25 units In-combination Located within No No No LSE House, impact (as above). 5km of Thames London Screened Basin Heaths SPA, Road, Ascot in Thursley, Ash, Pirbright and Category L Chobham Common SAC and Windsor Forest and Great Park SAC.

AL33 Broomhall Mixed use 1.45 30 units In-combination Located within Located upstream No No LSE impact (as above). 5km of Thames of Windsor Forest Car Park, Screened Basin Heaths SPA, and Great Park in Sunningdale Thursley, Ash, SAC and within the Pirbright and same operational Category L Chobham Common catchment, the SAC and Windsor Wey. Forest and Great Park SAC.

AL34 White Residential 0.82 10 units In-combination Located within Located upstream No No LSE impact (as above). 5km of Thames of Windsor Forest House, Screened Basin Heaths SPA, and Great Park in London Thursley, Ash, SAC and within the Road, Pirbright and same operational Category L Sunningdale Chobham Common

AL35 Residential 4.83 230 units No No LSE Sunningdale In-combination Located within Located upstream impact (as above). 5km of Thames of Windsor Forest Screened Park, Basin Heaths SPA, and Great Park in Sunningdale Thursley, Ash, SAC and within the Pirbright and same operational Category L Chobham Common catchment, the SAC and Windsor Wey. Forest and Great Park SAC.

AL36 Cookham Residential 1.25 50 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chilterns located in the same Gas holder, Screened Beechwoods SAC operational in Whyteladyes (Bisham Woods catchment (the Lane, SSSI). Lower Thames) as Category L Cookham sections of the South West London Waterbodies SPA and upstream of this designation.

AL37 Land north Residential 8.78 200 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chilterns located in the same of Lower Screened Beechwoods SAC operational in Mount Farm, catchment (the

Long Lane, (Bisham Woods Lower Thames) as Category L SSSI). sections of the Cookham South West London Waterbodies SPA and upstream of this designation.

AL38 Land east of Residential 0.90 20 units In-combination Located within This allocation is No No LSE impact (as above). 5km of Chilterns located in the same Strande Park, Screened Beechwoods SAC operational in Cookham (Bisham Woods catchment (the SSSI) and within Lower Thames) as Category L 5.6km of Burnham sections of the Beeches SAC. South West London Waterbodies SPA and upstream of this designation.

AL39 Land at Residential 3.92 80 units In-combination Located within This allocation is No No LSE impact (as above). 5km of South West located in the same Riding Court Screened London operational in Road and Waterbodies SPA catchment (the London Road and Windsor Lower Thames) as Category L Forest and Great sections of the Datchet Park SAC. South West London Waterbodies SPA.

Site Site Address Site use Area Housing Air quality Impact Recreation Impact Hydrological link to Habitat Wildfire / Screening Reference (ha) number / a European site loss / arson risk conclusion Number employment fragmentat sqm. (if ion? applicable) Slough WwTW is located upstream from the South West London Waterbodies SPA on the River Thames. This development will feed into this WwTW (the Water Quality Impact Assessment notes that this WwTW serves Eton and Datchet).

AL40 Land east of Residential 4.44 100 units In-combination Located within Site located within No No LSE impact (as above). 5km of South West the Colne surface Queen Screened London water operation in Mother Waterbodies SPA. catchment. Reservoir, Surface water Category L Horton course links to Wraysbury No. 1 Gravel Pit SSSI and Wraysbury and Hythe End Gravel Pits SSSI. Windsor WwTW is located to the immediate north

Appendix C: Natural England Consultation

RBWM BOROUGH LOCAL PLAN EXAMINATION HEARINGS

MATTER 1: LEGAL COMPLIANCE, EXCLUDING DUTY TO CO-OPERATE

ISSUE 4: … OPTIONS FOR FUTURE PROVISION OF SANG AND WILL IT DELAY LARGER DEVELOPMENTS COMING FORWARD?

SUITABLE ALTERNATIVE NATURAL GREENSPACE

1. The Council has already set out in response to ID/01 that the borough has a remaining SANG capacity of 205 dwellings as at 4 April 2018. In the table provided it is estimated that in the five years 2018-2023 503 dwellings would be brought forward that would require mitigation. Of those 503 dwellings, 205 would be mitigated on site through SANG provision leaving 298 units to be mitigated through Allen’s Field and its extension and any other SANG. Of those 298 dwellings only 205 could be mitigated at Allen’s Field plus 84 from the extension to Allen’s Field leaving a potential deficit in SANG of 9 dwellings.

2. The Council has done some further work to demonstrate that SANG will be brought forward in advance of dwellings on allocated sites and windfall sites being occupied. This is set out in table 1 below:

5 year period (financial year) Likely dwellings to be occupied SANG capacity available 2018-2023 397 1288 2023-2028 601 320 2028-2033 293 600 TOTAL 1291 2208 Table 1; SANG delivery to meet BLP housing trajectory

3. The table previously provided by the Council in is response to ID/01 assigned only 177 units to be completed at HA34 Sunningdale Park, this was based on the current planning application. The site HA34 is proposed for allocation for around 230 units and it is this figure which informs table 1.

4. Based on the likely delivery in the first five years it is noted that SANG would be required to be provided at HA32, HA33 and HA34. Boyer consulting obo of Sunningdale Park in their matter 1 hearing statement indicates that the proposed 13.79 hectare SANG at Sunningdale Park has a capacity of around 718 units. This figure has been used by the Council. The SANG approved at Heatherwood Hospital under application 16/03115/OUT has a capacity of 290 units. Allen’s field and its extension has been included in the available capacity in this first five years. It can be seen that there would be a significant surplus of SANG to 2023. 5. The Council anticipated that the new Strategic SANG it is currently pursuing with landowners as set out in the report to RBWM Cabinet on 28 June (attached as Appendix 1 to this note) would come forward early in the plan period. This could be revised to bring forward the capacity for mitigation of an estimated 320 units in the second 5 year period with the further extension of that SANG in the third 5 year period, giving a further mitigation for around 600 units. It should be noted that no capacity testing work has been conducted for this new Strategic SANG.

6. In addition to the capacity set out in table 1 for SANG to mitigate some 2,208 dwellings there is additional potential to access private SANG in a neighbouring borough to mitigate up to 300 units. If this were to be pursued it would provide a SANG capacity for 2,508 units against the likely delivery in the plan period of 1,291 dwellings within the 5km zone of the SPA. There is a significant buffer should sites deliver above the estimated capacity. It is clear that there is no likelihood of sites stalling through lack of SANG capacity.

7. At the current time there is a risk that a large SANG does not come forward in the first 5 years, for example, at HA34 Sunningdale Park. Firstly the units on that site would not require mitigation and secondly there is demonstrably a number of other options available that the Council could chose to bring forward to meet the requirement.

Agenda Item 7vii)

Report Title: Infrastructure: Suitable Alternative Natural Greenspace capacity and Suitable Alternative Natural Greenspace (SANG) delivery to support the BLP Contains Confidential or NO – Part I Exempt Information? Member reporting: Councillor Coppinger, Lead Member for Planning Meeting and Date: Cabinet 28 June 2018 Responsible Officer(s): Russell O’Keefe Executive Director & Jenifer Jackson, Head of Planning Wards affected: Ascot & Cheapside, Sunninghill & South Ascot and Sunningdale

REPORT SUMMARY

1. RBWM provides Strategic Suitable Alternative Natural Greenspace (SANG) capacity for relevant housing developments to enable them to proceed. This fulfils statutory obligations to protect the integrity of the Thames Basin Heaths Special Protection Area; and to provide new and enhanced open spaces (SANGs) for the residents of the borough to enjoy. 2. The BLP Submission Version (BLPSV) contains additional allocation for Suitable Alternative Natural Greenspace through an extension at Allen’s Field. This would meet the requirements for mitigation in the first 5 years of the plan period. 3. Strategic SANG capacity is under particular pressure from unplanned developments outside of defined settlements and developments proposing to bring forward a greater amount of development than the BLP SV allocates placing a strain on existing and future Strategic SANG capacity. 4. The council is proactively progressing options to ensure that additional SANG comes forward through to 2033 to assist in mitigating the impact of new residential development. There are a number of opportunities currently available and the council is investigating them all in consultation with Natural England.

1 DETAILS OF RECOMMENDATION(S)

RECOMMENDATION:

That Cabinet notes the report and:

i) Gives authority to the Executive Director, Place to pursue negotiations on behalf of the council with landowners, to enter into lease agreements or other legal agreements with landowners and to make a planning application for the purposes of providing SANG to meet BLP requirements to 2033.

ii) Gives authority to the Head of Planning not to provide capacity in the council’s Strategic Suitable Alternative Natural Greenspaces (SANGs) for large prior approval schemes or other unplanned large applications located beyond the defined settlements Ascot, Sunninghill and Sunningdale or on

97 allocated sites where the proposals are in excess of the BLPSV allocation by more than 9 additional units which are considered to undermine the Council’s Thames Basin Heaths Special Protection Area Avoidance and Mitigation Strategy.

iii) Gives authority to the Executive Director, Place to pursue negotiations on behalf of the council with any other council which may have surplus SANG capacity and to authorise the Executive Director to enter into any necessary legal or lease agreement with that council for the purposes of securing SANG capacity to support the BLPSV.

2 REASON(S) FOR RECOMMENDATION(S) AND OPTIONS CONSIDERED

2.1 The Thames Basin Heaths, which cover parts of Surrey, Hampshire and Berkshire, comprise a rare example of lowland heathland. It is home to three important bird species, (the Dartford Warbler, the Nightjar and the Woodlark) and protected by international law (the EU Birds Directive and the EU Habitats Directive), national legislation (the Conservation of Species and Habitats Regulations 2010 (as amended)) and by planning policy as a 'Special Protection Area' (SPA). The heaths, and the birds that nest and breed there, are easily disturbed by people and their dogs.

2.2 To comply with legislation the council must ascertain that any development in the borough would not harm the integrity of the SPA either by itself or in combination with all other applications in the other 11 local authorities affected by the SPA. An Appropriate Assessment is undertaken on all relevant planning applications (and development plans). This involves: Predicting the likely effects of the development. Assessing whether the predicted effects are likely to have an adverse effect on the integrity of the SPA. Proposing avoidance and mitigation measures. Consulting conservation bodies, where required.

2.3 The council has identified an extension to the current Strategic SANG at Allen’s Field within the BLPSV. This provides sufficient capacity to meet the first five years of development in the plan (allocated sites and windfalls). Additional capacity is required for the remainder of the plan period from 2023-2033 in order that residential development may be brought forward. Without that capacity planning permission should not be granted.

2.4 In order to allocate land for residential development and bring forward planned development, the council through the local plan process is required to demonstrate that sufficient SANG capacity is available to be able to mitigate the impacts of proposed residential development. This process is required to support the Borough Local Plan Submission Version (BLPSV) to provide SANG for planned development coming forward to 2033. Each SANG has its own capacity and, depending on its size, also its own catchment within which it can mitigate residential development. At the current time the south west extent of the parish of Sunningdale is not mitigated by the Allen’s Field SANG for development which is for 10 or more units.

Types of SANGs 2.5 There are two types of SANGs:

98 Strategic SANGs which are open space land owned or managed by the council to which developments pay financial contributions towards their enhancement to SANG status and long term management. These are mainly for smaller or urban developments which cannot realistically provide their own land for SANGs. Bespoke SANGs which are new open spaces provided mostly for large developments where the developer upgrades the land to SANG status and then usually transfers the land to council ownership with maintenance sums to guarantee its long term management.

Strategic SANGs 2.6 Development of nine or fewer dwellings can make a contribution to any SANG irrespective of catchment distances. Developments of 10 or more dwellings have to be located within the catchment of a SANG. The council currently operates and manages a Strategic SANG at Allen’s Field in South Ascot. The council is intending to extend this SANG through allocation via the borough local plan process to give capacity for future developments and enable them to proceed.

Bespoke SANGs 2.7 There is currently no bespoke SANG operating within the Borough: bespoke in this case means to serve a particular development. A bespoke SANG arrangement has been agreed for land at Heatherwood Hospital and planning consent granted. Other sites allocated in the BLP have been identified as requiring a bespoke SANG arrangement, for example, Sunningdale Park.

Table 1: Options Option Comments The council pursues the Strategic and bespoke SANG opportunities open to create arrangements are possible given the additional Strategic and Bespoke opportunities currently before the SANG capacity with landowners council; this would give a clear strategy and other council’s with the sole for SANG delivery to support BLPSV purpose of securing SANG development for the plan period. capacity to meet the requirements of the BLP SV at least to 2033. The recommended option. The council pursues only one This option would come with the risk option to secure additional SANG that this is not achieved and the capacity. requirement to mitigate the impact of Not the recommended option. residential development cannot be met which results in a moratorium on development in the part of the Borough within 5km of the TBH SPA until an alternative solution is found. The council does not pursue any This option would introduce some option to secure additional SANG uncertainty around the delivery of capacity. development within the 5km zone from Not the recommended option. 2023 onwards and could result in a moratorium on development in this part of the Borough until an alternative solution is found.

99 2.8 In addition to the SANG capacity to be provided at Allen’s Field through the BLPSV the council is seeking further capacity for developments allocated in the plan from year five onwards. Discussions with landowners are taking place on this basis, in confidence. The larger the land area then the greater amount of development that could potentially be mitigated (assuming very limited existing public access), also the greater the extent of influence (catchment) from the SANG which would mitigate schemes over 10 dwellings wherever these are in RBWM. If the influence of the SANG extended beyond the Borough boundary it might also be possible to consider releasing capacity to adjoining Boroughs.

2.9 Natural England has set locational and design criteria, including essential and desirable requirements, for the provision of SANG given that the purpose is to attract dog walkers away from the Thames Basin Heaths Special Protection Area. These are set out in sections 2.10 to 2.12 below.

Locational criteria 2.10 Essential: A wholly new site or an enhancement of existing public open space if the site is currently underused and has substantial capacity to accommodate additional recreational activity or could be expanded, taking into account the availability of land and its potential for improvement. Be in a location where it will divert visitors especially dog walkers away from sections of SPA coast which are sensitive to additional human disturbance and where a significant increase in visitors is predicted. Be large enough to include a variety of paths which enable at least one circular walk of at least 5 km (approx. a 60 min walk). Be in a location where a SANG would be acceptable in terms of planning policy and traffic generation, and would not have an unacceptable impact on biodiversity e.g. a nature conservation site protected under a local or national designation. Be sufficiently large to be perceived as a cohesive semi-natural space, offering tranquillity, with little intrusion of artificial structures (except in the immediate vicinity of car parks) and with no unpleasant intrusions of other kinds e.g. wastewater treatment odours.

Criteria for design and facilities 2.11 Essential Includes a variety of paths which enable at least one circular walk of at least 2k. Includes adequate car parking for visitors with that car parking being well located in relation to the road network. Be clearly signed at access points and at key junctions on the surrounding road network, with an information panel at each access point which explains the layout of the SANG and the routes available to visitors. Access points for visitors arriving on foot must be well located in relation to nearby residential areas. Designed so that the SANG is perceived by users as a cohesive semi-natural space which is safe and easily navigable. Paths must be clearly discernible, well signposted/waymarked, and have firm, level, well drained surfaces (albeit unsealed to avoid any 'urban feel') in order to be useable throughout the winter.

100 Movement within the SANG must be largely unrestricted, with plenty of space away from road traffic. Dogs are welcome and the majority of the sites is suitable for safe off-lead dog exercise.

2.12 Desirable: Car parking would be free of charge in the winter and preferably all year round. Has multiple access points and with car parking at each rather than in a single location. Incorporates innovative and attractive dog walking facilities such as dog activity trails, agility courses, enclosed off-lead training/exercise areas, dog washing facilities.

Practical arrangements Allen’s Field 2.13 The current strategic SANG at Allen’s Field is leased to the council by a charitable trust on a 99 year lease to meet the requirements from Natural England that the SANG is secured in perpetuity. The council is responsible for the maintenance and management of the SANG and also bore the capital cost of the initial works required to layout the land to meet Natural England’s requirements for a SANG. The freeholder receives payments from the council on the basis of a fixed sum per dwelling allocated to the SANG paid quarterly. There is a finite capacity, this is monitored by the council. The remaining capacity is around 210 dwellings. This capacity takes account of hard and soft commitments including applications already before the council but not yet determined but excluding developments over 50 units. The alternative approach would be to enter into a lease based on an external valuation of the land.

2.14 The council would anticipate an initial capital outlay and ongoing management costs for any new strategic SANG provision. This would need to be calculated. The council would then be required to establish the carrying capacity of the SANG by conducting a survey of usage of the land currently and an assessment of its capacity for recreational activity; this would be funded through capital in 2018/19. This would give the capacity of the SANG for the purposes of mitigating the impact of dwellings. The council would then be able to work out the income generated through contributions from developers which are paid on commencement. Subtracting the outlay and maintenance costs from the income would give a residual sum which would be allocated to the landowner. As this is at very early stages this information has not yet been collected, further work will continue following the cabinet decision. Planning permission would be required for the change of use of land to SANG and this report seeks authority to make a planning application in advance of the council securing any lease agreement together with covering the costs of making such an application.

Adjoining authorities 2.15 SANGs have a catchment area which extends beyond administrative boundaries which mean that development in some areas of the borough could be mitigated through alternative provision outside the borough. Officers are in contact with adjoining authorities to discuss this option and delegated authority is sought to pursue this arrangement including any legal, financial or lease agreements which the council would be required to be entered into to secure the arrangement.

Bespoke SANG opportunities

101 2.16 In relation to bespoke arrangements; permission for a bespoke SANG has already been given as part of the Heatherwood Hospital development in order to mitigate the residential development granted in outline as part of that planning consent. There is additional capacity to that required by the outline consent, the council sought to secure this additional capacity as part of the negotiation on the planning application; notwithstanding that the council does not control the capacity it is still available for a separate and private arrangement to be reached with the landowner. There is a current planning application at Sunningdale Park where a bespoke SANG is proposed which has significantly more capacity than that site alone requires and the council would want to secure that the additional SANG capacity may be controlled by the council through an appropriate mechanism.

2.17 The council, as local planning authority, currently has planning applications and appeals for sites located in the south of the Borough which require SANG mitigation. Developments which can pay financial contribution to strategic SANGs are usually under 109 dwellings but there are some exceptions. Development of 9 or fewer dwellings can make a contribution to any SANG irrespective of catchment distances. Developments of 10 or more dwellings have to be located within the catchment of a SANG. In the case of sites allocated for residential development in the BLPSV the planning application proposals seek a significant uplift above the site capacity allocated in the BLP.

3 KEY IMPLICATIONS

3.1 If the council was to continue to allow the use of strategic SANG capacity to mitigate these developments above plan allocation and unplanned development of over 10 dwellings located outside the defined settlement boundary then the available strategic SANG capacity would be significantly further reduced. The impact could be that Strategic SANG capacity which has been safeguarded for allocated sites in the BLPSV could be used up. This could result in sustainably located plan–led developments being put at risk of not being implemented in a timely manner or not at all.

3.2 Equally if a large number of SANGs were to come forward within the borough at a capacity which exceeded the required level of mitigation to 2033 there is a risk that the SANGs could not be appropriately managed in perpetuity as the monies collected would not cover the ongoing costs. Clearly there is a balance to be struck and the council is being proactive in SANG delivery.

Table 2: Key implications Outcome Unmet Met Exceeded Significantly Date of Exceeded delivery Lease January Lease 30 1November December arrangement 2019 signed by November 2018 2018 to secure 31 2018 further December Strategic 2018 SANG in RBWM in addition to Allen’s Field extension.

102 Outcome Unmet Met Exceeded Significantly Date of Exceeded delivery Capital Works January 31 30 1November December identified to 2019 December November 2018 2018 lay out land 2018 as Strategic SANG and SANG management plan produced. Consultant October 1 1 August 1 July 2018 September procured to 2018 September 2018 2018 advise on 2018 SANG capacity. Additional January December November October December Bespoke 2019 2018 2018 2018 2018 SANG secured through planning process. Arrangements January December November October December in place with 2019 2018 2018 2018 2018 adjoining council to access additional strategic or bespoke SANG capacity.

4 FINANCIAL DETAILS / VALUE FOR MONEY

4.1 The initial work can be met from existing budgets. The next stage is commissioning consultants to carry out work to identify SANG capacity, set out a SANG proposal, cost it and then prepare a SANG management plan. The work would be conducted in year using capital funds for infrastructure delivery. The cost of any valuations required would be met from the same capital fund.

4.2 The expected income from the provision of SANG would be either passed on to the landowner or retained by the council in order to fund the ongoing management and maintenance of the land as SANG in perpetuity. A planning application would need to be made for any land proposed as new Strategic SANG which would involve a cost in preparing a planning application and paying the required fee, it is anticipated that this would also be met from capital funds.

4.3 At this stage it is anticipated that forward funding of the laying out of the land as SANG would be required. This aspect of the project will require a capital bid in 2019/20 or

103 necessitate forward funding from an alternative source: it is estimated that a new strategic SANG could involve a capital outlay of up to £250,000.

Table 3: Financial impact of report’s recommendations REVENUE 2018/19 2019/20 2020/21 Addition £0 £0 £0 Reduction £0 £0 £0 Net impact £0 £0 £0

CAPITAL Addition £0 £250,000 £0 Reduction £0 £0 £0 Net impact £0 £250,000 £0

5 LEGAL IMPLICATIONS

5.1 The council is able to set up and manage strategic and bespoke SANG to mitigate the impact of residential development within 5km of the TBH SPA, this is achieved through the planning process using section 106 agreements. In addition the council is required to demonstrate how the BLP SV will be supported in its delivery through the provision of SANG to meet capacity needed from 2023 onwards.

6RISKMANAGEMENT

Table 4: Impact of risk and mitigation Risks Uncontrolled Controls Controlled Risk Risk The council is HIGH The council LOW unable to secure pursues more additional SANG than one option capacity. to provide SANG capacity within the borough and alternative options outside the borough. The council MEDIUM Officers are LOW refuses planning authorised to act applications in this way and to which seek to rely support the BLP on SANG SV. capacity thus preventing allocated sites from coming forward. The council has MEDIUM The council LOW costs awarded pursue the against it at

104 Risks Uncontrolled Controls Controlled Risk Risk appeal for failing provision of to bring forward additional SANG. SANG capacity. Appeals for MEDIUM The council LOW housing within actively pursues the 5km zone are all options for the allowed which provision of utilise more additional SANG. SANG capacity than planned for in the BLPSV thus reducing the ability to meet the needs of allocated and windfall sites which the Inspector identifies as a soundness issue.

7 POTENTIAL IMPACTS

7.1 Should the council secure land as SANG through a lease agreement there will be an addition to the assets that the souncil manages and maintains and there will be a requirement to manage the land in accordance with a SANG management plan. Monies secured through Section 111 agreement under the Local Government Act will have to be monitored to ensure that payments are made at the appropriate time in the planning process and that the necessary payments are passed to the landowner and SAMM payments to Hampshire County Council for wider monitoring of the SPA. This introduces additional work for the section 106 monitoring officer.

7.2 An EQIA scoping assessment has been completed, an EQIA is not required.

8 CONSULTATION

8.1 The report will be considered by Planning and Housing Overview and Scrutiny Panel in June 2018, comments will be reported to Cabinet.

9 TIMETABLE FOR IMPLEMENTATION

9.1 The council has more than one opportunity currently for ensuring delivery of SANG to mitigate the impact of residential development in the borough: as this report sets out all available opportunities are being explored, not all will be needed.

105 Table 5: Implementation timetable

Date Details By 30 June 2018 Initial meetings with all landowners to be held to establish basis of work, in principle before costs are incurred. To be Consultant procured to advise on SANG capacity. commissioned by 1September 2018 to undertake work by 31 December 2018. By 1 August Meeting with adjoining authority. 2018. By 31 March Planning application to be prepared, including plans and 2019 SANG management plan, and submission made for new SANG (if required)

9.2 Implementation date if not called in: Immediately.

10 APPENDICES

None.

11 BACKGROUND DOCUMENTS

11.1 The Council has an adopted Supplementary Planning Document on this matter which can be found at https://www3.rbwm.gov.uk/info/201039/non- development_plan/494/supplementary_planning_documents/1

11.2 Further relevant documents are contained in the BLP Submission section on the website including the BLPSV, the Sustainability Appraisal and the Habitat Regulations Assessment. https://www3.rbwm.gov.uk/info/200209/planning_policy

12 CONSULTATION (MANDATORY)

Name of Post held Date Date consultee issued for returned comment with comments Cllr Coppinger Lead Member for Planning 25.05.18 29.5.18 Alison Alexander Managing Director 25.05.18 30.05.18 Russell O’Keefe Executive Director 25.05.18 26.05.18 Andy Jeffs Executive Director 25.05.18 30.05.18 Rob Stubbs Section 151 Officer 18.05.18 24.05.18 Nikki Craig Head of HR and Corporate 25.05.18 29.05.18 Projects Louisa Dean Communications 25.05.18 29.05.18 Marc Turner Natural England 18.05.18 29.05.18

106 REPORT HISTORY

Decision type: Urgency item? To Follow item? Key decision No No Report Author: Jenifer Jackson, Head of Planning

107 Report to inform the HRA of the BLPSV-PC March 2020 LC-575_RBWM Council_HRA_Appendix D_3_Conservation Obj_030320SC.docx

Appendix D: European Site Conservation Objectives

Burnham Beeches SAC Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring: • The extent and distribution of the qualifying natural habitats; • The structure and function (including typical species) of qualifying natural habitats; and • The supporting processes on which qualifying natural habitats rely. Qualifying Features: • H9120: Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quericon robori-petraeae or Ilici-Fagenion); Beech forests on acid soils.

Chilterns Beechwoods SAC Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring: • The extent and distribution of the qualifying natural habitats and habitats of qualifying natural species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and the function of the habitats of the qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying Features: • H6120: Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia); Dry grasslands and scrublands on chalk or limestone; • H9130: Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils; and • S1083: Lucanus cervus; Stag beetle.

South West London Waterbodies SPA Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring: • The extent and distribution of the habitats of the qualifying features; • The structure and function of the habitats of the qualifying features; • The supporting processes on which the habitats of the qualifying features rely; • The population of each of the qualifying features; and

• The distribution of the qualifying features within the site. Qualifying features: • A051: Anas strepera; Gadwall (Non-breeding); and • A056: Anas clypeata; Northern shoveler (Non-breeding).

South West London Waterbodies Ramsar Ramsar sites do not have the Conservation Objectives in the same way as SPAs and SACs. Information regarding the designation of Ramsar sites is contained in INCC Ramsar Information Sheets. Ramsar Criteria are the criteria for identifying Wetlands of International Importance. The relevant criteria and ways in which this site meets the criteria are presented in the table below.

Ramsar Justification for the application of each criterion Criterion

6 Ramsar criterion 6 – species/populations occurring at levels of international importance.

Qualifying species/populations (as identified at designation): Species with peak counts in spring/autumn:

Northern shoveler, Anus 397 individuals, representing an average of 2.6% of the GB population clypeata, Northwest and (5 year peak mean 1998/9- 2002/3) Central Europe

Species with peak counts in winter: Gadwall, Anas strepera 487 individuals, representing an strepera, Northwest average of 2.8% of the GB population Europe (5 year peak mean 1998/9- 2002/3)

Thames Basin Heaths SPA Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of the habitats of the qualifying features; • The structure and function of the habitats of the qualifying features; • The supporting processes on which the habitats of the qualifying features rely; • The population of each of the qualifying features; and • The distribution of the qualifying features within the site. Qualifying features: • A224: Caprimulgus europaeus; European nightjar (Breeding); • A246: Lullula arborea; Woodlark (Breeding); and • A302: Sylvia undata; Dartford warbler (Breeding).

Thursley, Ash, Pirbright and Chobham SAC Conservation objectives:

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of qualifying natural habitats; • The structure and function (including typical species) of qualifying natural habitats; and • The supporting processes on which qualifying natural habitats rely. Qualifying Features: • H4010: Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross- leaved heath; • H4030: European dry heaths; and • H7150: Depressions on peat substrates of the Rhynchosporion.

Windsor Forest and Great Park SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of qualifying natural habitats and habitats of qualifying species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and function of the habitats of qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying Features: • H9120: Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrub layer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils; • H9190: Old acidophilous oak woods with Quercus robur on sandy plains; Dry oak- dominated woodland; and • S1079: Limoniscus violaceus; Violet click beetle.

Appendix E: Site of Special Scientific Interest Condition Data

European Site No. of SSSI Units Conservation Status of SSSI Units1

3/4 Favourable Burnham Beeches SAC 4 1/4 Unfavourable – recovering 23/31 Favourable Chilterns Beechwoods SAC 31 8/31 Unfavourable – recovering South West London Waterbodies SPA 14/18 Favourable

18 3/18 Unfavourable – recovering South West London Waterbodies Ramsar 1/18 Unfavourable - declining

55/126 Favourable 59/126 Unfavourable – recovering Thames Basin Heaths SPA 126 7/126 Unfavourable – no change 5/126 Unfavourable – declining 58/94 Favourable 32/94 Unfavourable – recovering Thursley, Ash, Pirbright & Chobham SAC 94 2/94 Unfavourable – no change 2/94 Unfavourable – declining

Windsor Forest & Great Park SAC 22 22/22 Favourable

1 Natural England. IRX https://designatedsites.naturalengland.org.uk/. Site condition data is provided for the SSSIs which legally underpin the European designation [Date Accessed: 23.09.19].

Report to inform the HRA of the BLPSV-PC March 2020 LC-575_RBWM Council_HRA_Appendix F_3_Threats and Pressures_030320SC.docx Appendix F: Threats and Pressures

Table F.1: Pressures and threats for European sites that may be affected by the Local Plan. Boxes with a cross indicate the site is vulnerable to that particular threat/pressure, but the individual qualifying features under threat/pressure have not been identified (applicable to data provided by Natura 2000 data forms). European sites

South West Chilterns Thursley, Ash, Burnham London Thames Basin Windsor Forest & Beechwoods Pirbright & Beeches (SAC) Waterbodies (SPA Heaths (SPA) Great Park (SAC) (SAC) Chobham (SAC) & Ramsar)

H9120 Beech forests All qualifying All qualifying on acid soils, H9190 All qualifying All qualifying Air Pollution features (SIP + features (SIP + Dry oak-dominated features (SIP) features (SIP + N2K) N2K) N2K) woodland (SIP + N2K)

Changes in species S1083 Stag All qualifying Data from distributions beetle (SIP) features (SIP) SIPs and H9130 Beech Natura All qualifying forests on Deer 2000 features (SIP) neutral to rich (NK2) soils (SIP) data H9130 Beech forms H9190 Dry oak- forests on Disease dominated neutral to rich woodland (SIP) soils (SIP)

Feature location/ All qualifying extent/ condition features (SIP) unknown

All qualifying Fisheries: Fish features (SIP + stocking N2K)

H9130 Beech H4010 Wet Forestry and forests on All qualifying heathland with All qualifying woodland neutral to rich features (SIP + cross-leaved heath, features (SIP + N2K) management soils (SIP + N2K) H4030 European N2K) dry heaths (SIP)

All qualifying All qualifying Habitat fragmentation All qualifying features (SIP) features (SIP) features (SIP)

H4010 Wet heathland with cross-leaved heath, Hydrological changes H7150 Depressions on peat substrates (SIP)

H4010 Wet heathland with Inappropriate scrub All qualifying cross-leaved heath, control features (SIP) H4030 European dry heaths (SIP)

Inappropriate weed All qualifying

control features (SIP)

H9130 Beech H4010 Wet H9190 Dry oak- forests on All qualifying heathland with dominated Invasive species All qualifying neutral to rich features (SIP + cross-leaved heath, woodland, S1079 features (SIP) soils (SIP + N2K) H4030 European Violet click beetle N2K) dry heaths (SIP) (SIP + N2K)

All qualifying All qualifying Military features (SIP) features (SIP)

Natural changes to All qualifying

site conditions features (SIP)

Public access/ S1083 Stag All qualifying All qualifying

disturbance All qualifying beetle (SIP) features (SIP) features (SIP) features (SIP)

Species decline All qualifying

features (SIP)

H4010 Wet heathland with All qualifying Undergrazing cross-leaved heath, features (SIP) H4030 European dry heaths (SIP)

All qualifying All qualifying Wildfire/ arson features (SIP) features (SIP)

Abiotic (slow) natural x processes

Biocenoitic evolution x x succession

Changes in biotic x x conditions

Grazing x

Data Human induced x from changes in hydraulic

Natura conditions 2000 data Interspecific floral x forms relations x

only Other ecosystem x modifications Other human intrusions and x x disturbances

Outdoor sports and leisure activities, x x x recreational activities

Problematic native x x species

© Lepus Consulting for Royal Borough of Windsor and Maidenhead Council F5 Report to inform the HRA of the BLPSV-PC March 2020 LC-575_RBWM Council_HRA_Appendix G_7_In-combination Assessment_040320SC.docx Appendix G: In-Combination Assessment

Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Bracknell Forest The Draft Bracknell Existing Target: Draft HRA of Draft Bracknell Forest Local Plan2 Local Plan1 Forest Local Plan (BFLP) is currently at Provision will be made for at least an Outcome: The draft HRA concludes LSEs of the BFLP on the integrity of consultation for additional 12,060 homes in Bracknell Forest Thames Basin Heaths SPA from urbanisation, recreational pressures and additional growth Borough for the period 2016/17 to 2033/34. air quality, and LSEs on Windsor Forest Great Park SAC due to air quality. options (autumn 2019). Following the adoption of mitigation, including SANGs and SAMMs, it was Local Plan due for concluded that there will be no significant adverse urbanisation and submission in summer recreational disturbance effects upon the integrity of the Thames Basin 2020. Heaths SPA. Additional work needs to be undertaken to establish likely air quality effects.

The LSE of the BLPSV-PC in-combination with the Bracknell Forest Local Plan and other neighbouring authority plans, in terms of public access and disturbance and air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I).

Chiltern and South The Chiltern and South Existing Target: Report to Inform the HRA of the Chiltern and South Bucks Local Plan Buckinghamshire Bucks Local Plan 2036 (June 2019)4 Local Plan3 was submitted for Provision for 15,260 new homes over the independent period of 2016-2036 (11,000 homes within the Plan area, with the Vale of Aylesbury

1 Bracknell Forest Council (2018) Draft Bracknell Forest Local Plan. Available at: https://democratic.bracknell-forest.gov.uk/documents/s117177/Appendix%20A%20- %20Draft%20Bracknell%20Forest%20Local%20Plan.pdf [Date Accessed: 16/10/19] 2 Bracknell Forest Council (2018) Draft Habitats Regulations Assessment Draft Bracknell Forest Local Plan. Available at: https://consult.bracknell-forest.gov.uk/file/4860916 [Date Accessed: 16/10/19] 3 Chiltern and South Bucks District Councils (2019) Draft Chiltern and South Bucks Local Plan 2036 – Publication Version. Available at: https://www.southbucks.gov.uk/media/13855/Draft-Chiltern-and-South-Bucks-Local-Plan- 2036/pdf/draft_Chiltern_and_South_Bucks_Local_Plan_2036_F.pdf?m=637063941586370000 [Date Accessed: 16/10/19] 4 Lepus Consulting (2019) Habitats Regulations Assessment of the Chiltern and South Bucks Local Plan. Available at: https://www.southbucks.gov.uk/media/13815/HRA-June- 2019/pdf/HRA_June_2019.pdf?m=637063903392230000 [Date Accessed: 16/10/19]

© Lepus Consulting for the Royal Borough of Windsor and Maidenhead Council G1 Report to inform the HRA of the BLPSV-PC March 2020 LC-575_RBWM Council_HRA_Appendix G_7_In-combination Assessment_040320SC.docx

Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects examination on 26th Local Plan making provision for 5,750 Outcome: The Screening Assessment concludes LSEs in terms of air September 2019. homes). quality at Burnham Beeches SAC and Chilterns Beechwoods SAC, and Delivering an average of 763 net new homes public access and disturbance and hydrology at Burnham Beeches SAC. a year for the next 20 years. LSEs on South West London Waterbodies SPA/Ramsar, Thames Basin Heaths SPA, Thursley, Ash, Pirbright and Chobham SAC and Windsor Forest and Great Park SAC ruled out. Following consideration of mitigation at the Appropriate Assessment stage, no adverse effects as a result of the Local Plan (alone or in- combination) were concluded. Mitigation included consideration of policies, development of an air quality mitigation strategy, policy in neighbouring authority plans, an access management scheme for Burnham Beeches SAC and implementation of hydrology development management guidance. Addendum to the Regulation 19 HRA Report (September 2019)5 Outcome: Addendum identified additional uncertainties in terms of potential air quality impacts at Burnham Beeches SAC, which will need to be explored further to inform the HRA of the Local Plan.

The LSE of the BLPSV-PC in-combination with the Chiltern and South Bucks Local Plan and other neighbouring authority plans, in terms of public access and disturbance and air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I). .

London Borough of London Borough of Existing Target: Screening for Appropriate Assessment (2014)8 Hillingdon Local Hillingdon Local Plan Plan6 Part 2 submitted to the To provide a minimum of 6,375 dwellings Outcome: The Screening concluded that no LSEs were anticipated to Secretary of State on between 2011 and 2026, and to provide 358 occur at European sites, and therefore, an Appropriate Assessment was 18th May 2018. hectares of designated employment land. not required.

Proposed Main Modifications to the

5 Lepus Consulting (2019) Habitats Regulations Assessment of the Chiltern and South Bucks Local Plan – Addendum to the Regulation 19 HRA Report. Available at: https://www.southbucks.gov.uk/media/13816/HRA-Addendum-4/pdf/LC-584_HRA_Addendum_4_270919SC.pdf?m=637063903863700000 [Date Accessed 16/10/19] 6 Hillingdon Council (2015) London Borough of Hillingdon Local Plan: Part 2. Available at: https://www.hillingdon.gov.uk/lpp2 [Date Accessed 16/10/19] 8 Hillingdon Council (2014) Screening for Appropriate Assessment – 2014 Local Plan Part 2. Available at: https://archive.hillingdon.gov.uk/media/32185/Part-2---Appropriate- Assessment-Screening---Final-Version-1/pdf/Part_2_-_Appropriate_Assessment_Screening_-_Final_Version_1.pdf [Date Accessed: 22/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Local Plan Part 2 – Hillingdon’s housing targets are also included Screening for Appropriate Assessment Update 20199 awaiting Inspector’s within the London Plan. The proposed Main Modifications were reviewed and determined that the Report (October 2019). 7 original conclusions remain valid. (Awaiting response from Natural The London Plan : England). 10-year housing target for net housing completions in the London Borough of Hillingdon (2019/20 – 2028/29) = 15,530. The LSE of the BLPSV-PC in-combination with the London Borough of Hillingdon Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I).

Reading Borough The Local Plan was Existing Target: At present an HRA has not been found to be publicly available. Available Local Plan10 submitted to the findings are presented below. Secretary of State on Provision will be made for at least an Thursday 29th March additional 15,433 homes (averaging 671 HRA of the options, screening level (Appendix 3 within SA of the Local 2018. homes per annum) in Reading Borough for Plan Issues and Options January 2016)11 the period 2013 to 2036. Outcome: The HRA screening identified potential LSEs from proposed Following Main Provision will be made for a net increase of housing on the Thames Basin Heaths SPA in terms of air quality, habitat Modifications and the loss and degradation and recreational pressures, and potential LSEs from Inspector’s Report 53,000-112,000 sq m of office floorspace and 148,000 sq m of industrial and/or warehouse employment and housing on Chilterns Beechwoods SAC and Thames (September 2019), the Basin Heaths SPA in terms of noise, disturbance and air quality. Local Plan was adopted space in Reading Borough for the period on 4th November 2019. 2013 to 2036. The LSE of the BLPSV-PC in-combination with the Reading Borough Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I).

7 Greater London Authority (2019) The Draft London Plan – Consolidated Changes Version. Available at: https://www.london.gov.uk/sites/default/files/draft_london_plan_- _consolidated_changes_version_-_clean_july_2019.pdf [Date Accessed: 22/10/19] 9 Hillingdon Council (2019) Screening for Appropriate Assessment Update 2019. Available at: https://archive.hillingdon.gov.uk/media/41074/Screening-for-Appropriate-Assessment- Update-2019/pdf/Screening_for_Appropriate_Assessment_Update_2019.pdf [Date Accessed: 22/10/19] 10 Reading Borough Council (2018) Submission Draft Reading Borough Local Plan. Available at: http://www.reading.gov.uk/media/8649/LP001-Submission-Draft-Local- Plan/pdf/LP001_Submission_Draft_Local_Plan.pdf [Date Accessed: 16/10/19] 11 Reading Borough Council (2016) Reading Borough Local Plan Sustainability Appraisal of the Issues and Options. Available at: http://www.reading.gov.uk/media/4529/Sustainability- Appraisal/pdf/Sustainability_Appraisal_of_Local_Plan_Issues_and_Options_0116.pdf [Date Accessed: 24/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Runnymede Local Runnymede Local Plan Existing Target: HRA Runnymede Local Plan: Main Modifications (December 2019)13 Plan12 submitted to Secretary of State on 31st July Delivery of at least 7,480 additional homes in Outcome: The HRA determined that the main modifications will not lead 2019. Runnymede in the period 2015-2030 (an to LSEs on the European sites and do not introduce impact pathways that average of 498 homes a year). were not already discussed in the previous HRA. Consultation on Proposed Main HRA Screening and Appropriate Assessment Report for Runnymede Modifications will run Council (May 2018)14 for 6 weeks from 10th st The HRA Screening report concludes that there will be no January until 21 Outcome: adverse effects to Thursley, Ash, Pirbright & Chobham SAC, South West February. London Waterbodies SPA/Ramsar or Windsor Forest and Great Park SAC. It also concluded that there would be no risk of an adverse effect on the Thames Basin Heaths SPA since the policy (developed under Preferred Approach EE10) requires the council to meet the SANG provision. Recommendations: Potential for further bespoke or strategic SANGs later in the Plan period is explored by the council in time for examination in Public.

The LSE of the BLPSV-PC in-combination with the Runnymede Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in- combination air quality assessment is presented in Appendix I).

12 Runnymede Borough Council (2018) Runnymede 2030 Submission Local Plan. Available at: https://www.runnymede.gov.uk/media/18640/CD-001-Runnymede-2030-Local- Plan/pdf/CD_001_FINAL_Submission_Local_Plan.pdf?m=636681345320870000 [Date Accessed: 16/10/19] 13 AECOM (2019) HRA Runnymede Local Plan Main Modifications. Available at: https://www.runnymede.gov.uk/media/22052/Proposed-Main-Modifications-Habitat-Regulations- Assessment/pdf/Proposed_Main_Modifications_Habitat_Regulations_Assessment.pdf?m=637142072186930000 [Date Accessed: 12/02/20] 14 HRA Screening and Appropriate Assessment Report for Runnymede Borough Council (2018) Available at: https://www.runnymede.gov.uk/media/18177/Runnymede-Local-Plan- Habitats-Regulations-Assessment-Main-Report-May-2018-/pdf/Runnymede_Local_Plan_HRA_May_2018.pdf?m=636613739377200000 [Date Accessed: 26/06/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Rushmoor Local Rushmoor Borough Existing Target: HRA – Rushmoor Local Plan Draft Submission (June 2017)16 Plan15 Council adopted the Rushmoor Local Plan The Rushmoor Local Plan seeks to address Outcome: The HRA concludes that the Local Plan policy framework on 21st February 2019. housing needs by planning for at least 7,850 delivers measures to avoid or mitigate the recreational, water resources new homes between 2014 and 2032. and water quality effects on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. Transport modelling and air quality analysis indicates no LSE on these two European sites. The HRA also concludes that the Local Plan policy framework will avoid or mitigate the likelihood of significant adverse recreational pressures on Windsor Forest and Great Park SAC.

The LSE of the BLPSV-PC in-combination with the Rushmoor Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in- combination air quality assessment is presented in Appendix I). 17 Slough Local Plan In preparation. The Local Plan Issues and Options HRA Screening Document (January 2017)18 Information is available Consultation Document is the first stage of Outcome: The HRA screening report concludes that LSEs on the on emerging preferred preparing the new Local Plan 2016-2036. spatial strategy. qualifying features of Burnham Beeches SAC in terms of public access and Existing Target: disturbance and air quality cannot be objectively ruled out based on the Slough’s Objectively Assessed Housing Need information currently available. over the plan period is 927 dwellings per LSEs on the Chilterns Beechwoods SAC, South West London Waterbodies year. SPA/Ramsar, Thames Basin Heaths SPA, Thursley, Ash, Pirbright and The plan seeks to provide for around 20,000 Chobham SAC and Windsor Forest and Great Park SAC can be objectively new houses in and around Slough over the ruled out based on the currently available information. plan period. The LSE of the BLPSV-PC in-combination with the Slough Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in- combination air quality assessment is presented in Appendix I).

15 Rushmoor Borough Council (2019) Rushmoor Local Plan 2014-2032. Available at: https://www.rushmoor.gov.uk/CHttpHandler.ashx?id=19935&p=0 [Date Accessed: 16/10/19] 16 Rushmoor Borough Council (2017) Rushmoor Local Plan Draft Submission - Habitat Regulations Assessment. Available at: https://www.rushmoor.gov.uk/CHttpHandler.ashx?id=17845&p=0 [Date Accessed: 16/10/19] 17 Slough Borough Council (2019) The Emerging Local Plan for Slough 2016-2036. Available at: http://www.slough.gov.uk/council/strategies-plans-and-policies/the-emerging-local- plan-for-slough-2016-2036.aspx [Date Accessed: 22/10/19] 18 Lepus Consulting (2017). Habitats Regulations Assessment of the Slough Local Plan - HRA Screening Document.

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects South Oxfordshire South Oxfordshire The Local Plan sets out provisions for 22,775 HRA of the South Oxfordshire Local Plan (January 2018)20 Local Plan19 District Council new homes to be delivered to meet the Outcome: The HRA concludes that the Plan would not have an adverse submitted the Local district’s own needs and those of Oxford City effect on European sites including Burnham Beeches SAC, Chilterns Plan 2034 to the Council’s needs during the plan period (2011 Beechwoods SAC, Thames Basin Heaths SPA, Thursley, Ash, Pirbright and Secretary of State on to 2034). th Chobham SAC or Windsor Forest and Great Park SAC, either alone or in- Friday 29 March 2019 In order to meet the South Oxfordshire combination with other plans and projects. for Independent Employment Requirement, the plan will Examination. identify 37.5ha of employment land over the Plan period. The LSE of the BLPSV-PC in-combination with the South Oxfordshire Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I).

Spelthorne Local New Local Plan under Existing Target: HRA has not been undertaken to date of the emerging New Local Plan. Plan21 preparation. The Plan will seek to deliver 3,320 homes to Spelthorne Local Plan Sustainability Appraisal / Strategic Environmental Public consultation of 22 Preferred Options in 2026 – Core Strategy and Policies Assessment Final Scoping Report (2017) October 2019. Development Plan Document adopted in The SA/SEA scoping report states that “The Borough Council also 2009. considers that the Local Plan requires an assessment as to its effect on European Designated sites of biodiversity importance such as the South West London Waterbodies SPA and international designations under the Ramsar convention. This will be outlined in a sperate HRA at Pre- submission/submission stage of the Local Plan”.

The LSE of the BLPSV-PC in-combination with the Spelthorne Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in- combination air quality assessment is presented in Appendix I).

19 South Oxfordshire District Council (2019). South Oxfordshire Local Plan 2011-2034. Available at: http://www.southoxon.gov.uk/ccm/support/dynamic_serve.jsp?ID=999354812&CODE=22D6A357E421757B45F1ABF8605F94B5 [Date Accessed 16/10/19] 20 Land Use Consultants (2018). South Oxfordshire Local Plan Habitat Regulation Assessment. http://www.southoxon.gov.uk/sites/default/files/South%20Oxfordshire%20HRA%20Report%20FINAL_0.pdf [Date Accessed: 16/10/19] 21 Spelthorne Borough Council Local Plan Update, Available at: https://www.spelthorne.gov.uk/article/17619/New-Local-Plan-for-Spelthorne [Date Accessed: 06/09/19] 22 Local Plan SA/SEA Final Scoping Report (2017) Spelthorne Borough Council, Available at: https://www.spelthorne.gov.uk/media/17471/Sustainability-Appraisal-Scoping- Report/pdf/Sustainability_Appraisal_Scoping_Report.pdf [Date Accessed: 09/08/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Surrey Heath Local Pre-submission version 23 Existing Target: HRA of the Draft Local Plan to 2032 Issues and Options Consultation (May Plan of the Draft Local Plan 2018)24 is under preparation, Over the period 2016 to 2032, the Council the timetable is will make provision for the delivery of circa Outcome: Windsor Forest and Great Park SAC – The HRA identified currently being 4,901 new homes in the Borough. potential recreational pressure and atmospheric pollution impacts. The updated. HRA concludes that the Plan is unlikely to lead to significant effects on the Windsor Forest and Great Park SAC and has therefore been screened out. Burnham Beeches SAC and the South West London Waterbodies SPA/Ramsar were also screened out. Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC – The HRA identified potential recreational pressure, urbanisation and atmospheric pollution impacts. Provided that the recommendation (below) is incorporated in the Plan document, the HRA concludes that the Plan is unlikely to lead to significant effects on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC, and they have been screened out. It is acknowledged that, at the time of the assessment (April 2018), traffic modelling was being undertaken. Upon completion of the traffic modelling, air quality assessment and subsequent ecological interpretation of the findings will be undertaken. Recommendations: To ensure no likely significant effects arise, the HRA recommended that development of policy wording ensures that increased accessibility to green infrastructure does not result in increased recreational pressures on the SPA and SAC.

The LSE of the BLPSV-PC in-combination with the Surrey Heath Local Plan and other neighbouring authority plans, in terms of public access and disturbance and air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I).

23 Surrey Heath Borough Council (2018) Issues and Options/Preferred Options Consultation Draft Local Plan to 2032. Available at: https://consult.surreyheath.gov.uk/gf2.ti/f/919106/36988421.1/PDF/-/Final_Draft_of_Issues_and_Options_Reg_18_Plan.pdf [Date Accessed: 16/10/19] 24 AECOM (2018) Draft Local Plan to 2032 Issues and Options Consultation (May 2018) Habitats Regulations Assessment. Available at: https://www.surreyheath.gov.uk/sites/default/files/documents/residents/planning/planning-policy/LocalPlan/EvidenceBase/shhabitatsregsassmnt2018.pdf [Date Accessed: 16/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Surrey Waste Local The new Surrey Waste Sites have been allocated to provide the land Surrey Waste Local Plan 2018-2033 HRA (January 2019)26 Plan25 Local Plan is currently necessary to meet the need for new waste Outcome: The assessment of the implications of the implementation of under review and due management facilities in Surrey up to 2035. to be adopted in 2019. the Surrey WLP for the ecological integrity of the South West London One of these sites is located in proximity to Waterbodies SPA/Ramsar, Thames Basin Heaths SPA, Thursley, Ash, RBWM; Oakleaf Farm, Stanwell Moor. Pirbright and Chobham SAC and Windsor Forest and Great Park SAC concludes that overall, there would be no potential for LSEs to arise, subject to the observation of a number of decision rules with reference to the development of thermal treatment facilities. Recommendations: In the interests of managing the risk of in-combination effects, certain locations have been deemed unsuitable for thermal treatment plants. The construction and operation of a large-scale thermal treatment facility is not recommended for the allocated site Oakleaf Farm, Stanwell Moor, subject to the outcome of detailed modelling and assessment at the planning application stage. This is due to its location within 10km of the Windsor Forest and Great Park SAC.

It is not considered that there will be LSE of the BLPSV-PC in-combination with the Surrey Waste Local Plan and other plans and projects. Wokingham Wokingham Borough The Local Plan Update will guide HRA of the Local Plan Update is not currently available. Available findings Borough Local Plan are presented below. 27 Council are currently development of homes, employment and Update preparing a Local Plan infrastructure within the borough up to Update. 2036. HRA Scoping Report of the August 2016 Issues and Options Consultation The second ‘Homes for Using the latest information available, the Document28 the Future’ public government’s current guidance expects consultation ran from

25 Surrey Waste Local Plan Part 2 – Sites and areas search (2019) Available at: https://www.surreycc.gov.uk/__data/assets/pdf_file/0020/186320/2019-01-25-Submission-SWLP-Part- 2-Sites-Final_NEW_2.8mb.pdf [Date Accessed: 22/10/19] 26 Surrey Waste Local Plan 2018-2033 Habitat Regulations Assessment Report (January 2019). Available at: https://www.surreycc.gov.uk/__data/assets/pdf_file/0011/187733/SWLP- HRA-Rpt-23-01-19-Final-ilovepdf-compressed.pdf [Date Accessed: 22/10/19] 27 Wokingham Borough Council (2018) Wokingham Borough Local Plan Update Consultation Document Nov 2018 – Feb 2019. Available at: https://www.wokingham.gov.uk/EasySiteWeb/GatewayLink.aspx?alId=467976 [Date Accessed: 23/10/19] 28 Wokingham Borough Council (2016) Local Plan Update Habitats Regulations Assessment Scoping Document August 2016. Available at: https://www.wokingham.gov.uk/EasySiteWeb/GatewayLink.aspx?alId=400047 [Date Accessed: 23/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects November 2018 – between 750 and 850 new homes to be built This Scoping Report focused on the Thames Basin Heaths SPA as a February 2019 and will each year in Wokingham Borough. proportion of Wokingham Borough lies within the identified buffer zones. inform the Draft Plan. In order to provide mitigation for the impact of new residential The Local Plan Update development on the Thames Basin Heaths SPA, the Council requires a is due for adoption in contribution to be made towards providing and maintaining SANGs as Spring 2022. well as SAMMS. This approach was agreed and endorsed by the Thames Basin Heaths Joint Strategic Partnership Board (which comprised members of the South East Regional Assembly and the SPA local planning authorities) in February 2009. At the Preferred Options stage the Council will undertake a further scoping exercise and determine whether an Appropriate Assessment is necessary.

The LSE of the BLPSV-PC in-combination with the Wokingham Local Plan and other neighbouring authority plans, in terms of air quality impacts, has been considered further in the appropriate assessment (the in- combination air quality assessment is presented in Appendix I). Wycombe District 30 29 Wycombe District’s Existing Target: Wycombe District Local Plan – Revised HRA (July 2018) Local Plan Local Plan was adopted th The housing need within Wycombe District is Outcome: Although risks to the SACs (including Burnham Beeches SAC on 19 August 2019. 13,200 homes for the period 2013-2033 (660 and Chilterns Beechwoods SAC) are identified, the HRA notes that homes per year). Wycombe is proposing to measures are in place to address these issues, or will be implemented, accommodate 10,925 homes, with the ‘unmet resulting in the integrity of the sites being conserved. This will be closely need’ provided by Aylesbury Vale District monitored by Natural England and its partners. Council. The HRA concludes that the Wycombe District Local Plan will not adversely affect, either alone or in-combination with other plans or projects, the integrity of these SACs.

29 Wycombe District Council (2019) Wycombe District Local Plan – Adopted August 2019. Available at: https://www.wycombe.gov.uk/uploads/public/documents/Planning/Adopted- Wycombe-local-plan/Wycombe-District-Local-Plan-Adopted-August-2019.pdf [Date Accessed: 22/10/19] 30 Wycombe District Council (2018) Wycombe District Local Plan – Revised Habitats Regulations Assessment Report. Available at: https://www.wycombe.gov.uk/uploads/public/documents/Planning/New-local-plan/WDLP-core-documents-2018/WDLP3A-Revised-Habitats-Regulations-Assessment-Screening- Report-July-2018.pdf [Date Accessed: 22/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects HRA of the proposed Main Modifications (February 2019)31 Outcome: This process indicated that the Main Modifications do not result in the identification of any new linking impact pathways beyond those which have previously been identified within preceding HRA work to support the development of the Plan.

The LSE of the BLPSV-PC in-combination with the Wycombe Local Plan and other neighbouring authority plans, in terms of public access and disturbance and air quality impacts, has been considered further in the appropriate assessment (the in-combination air quality assessment is presented in Appendix I). Royal Borough of The third Local LTP3 comprises the long-term strategy for Assessment under the Habitats Regulations Final Report (August 2012)33 Windsor and Transport Plan (LTP3) the period 2012 to 2026, covering all forms Outcome: The HRA considers that due to the mitigating impact of the Maidenhead Local for the Royal Borough of transport. There are five overarching aims: Transport Plan32 policies within the LTP3, and that the LTP3 contains a statement to the of Windsor and • To improve access to everyday services effect that any projects that would have a significant impact on European Maidenhead was and facilities for everyone; sites would not be supported by the LTP3, it can be concluded that the adopted in July 2012. • To improve road safety and personal LTP3 will not have a significant effect on the integrity of European sites security for all transport users; (Burnham Beeches SAC, Chilterns Beechwoods SAC, South West London • To support sustainable economic Waterbodies SPA/Ramsar, Thames Basin Heaths SPA, Thursley, Ash, growth; Pirbright and Chobham SAC and Windsor Forest and Great Park SAC). • To improve quality of life and minimise the social, health and environmental impacts of transport; and Measures set out in this LTP will have a positive contribution to air quality • To mitigate and adapt to the effects of at European sites by encouraging a modal shift from the private car and climate change. thus a reduction in vehicle emissions.

31 Wycombe District Council (2019) Habitats Regulations Assessment of the Proposed Main Modifications to the Wycombe District Local Plan. Available at: https://www.wycombe.gov.uk/uploads/public/documents/Planning/New-local-plan/Local-plan-examination-2018/WDLP3C-Habitats-Regulations-Assessment-of-the-Proposed- Main-Modifications.pdf [Date Accessed: 22/10/19] 32 Royal Borough of Windsor and Maidenhead (2012) Local Transport Plan 2012-2026. Available at: https://www3.rbwm.gov.uk/download/downloads/id/238/local_transport_plan_- _part_one.pdf [Date Accessed: 24/10/19] 33 WSP (2012) Third Local Transport Plan for the Royal Borough of Windsor and Maidenhead – Assessment under the Habitats Regulations Final Report. Available at: https://www3.rbwm.gov.uk/download/downloads/id/244/local_transport_plan_-_final_habitats_regulations_assessment.pdf [Date Accessed: 24/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects Central and Eastern The Central & Eastern The Joint Minerals & Waste Plan will build Joint Minerals and Waste Plan HRA Screening Report (June 2018)35 Berkshire Berkshire Authorities upon the formerly adopted minerals and Authorities Minerals (Bracknell Forest waste plans for the Berkshire area, and Outcome: The HRA Screening Report concludes that three policies within and Waste Plan34 Council, Reading improve, update and strengthen the policies the Plan and a number of sites have been screened in due to the potential Borough Council, The and provide details of strategic sites that are for LSEs on European sites, including South West London Waterbodies Royal Borough of proposed to deliver the vision. SPA/Ramsar and Windsor Forest and Great Park SAC. Windsor & Maidenhead and Wokingham Further iterations of screening will be undertaken as policy wording is Borough Council) are refined and further survey and analysis of minerals and waste sites is working in partnership undertaken. to produce a Joint

Minerals & Waste Plan. A draft plan was It is not considered that there will be LSE of the BLPSV-PC in-combination produced and with the Central and Eastern Berkshire Authorities Minerals and Waste consulted on in 2018. Plan and other plans and projects. Western Rail Link to 36 Responses from the The Western Rail Link to Heathrow would A full Environmental Impact Assessment (EIA) will be presented in an Heathrow second round of leave the Main Line between Langley and Environmental Statement as part of the application for consent. In consultation (11 May - Iver, descend underneath the main railway addition, there will be a requirement for a HRA. No detail was available at 22 June 2018) have line into a cutting before entering a 5km the time of writing. been analysed, and tunnel passing under Richings Park and It is anticipated that likely in-combination effects will be associated with public information Colnbrook before merging with existing rail construction traffic and a temporary increase in HGV numbers. The long- events will be held in lines underground at Heathrow Terminal 5. term impacts of the scheme on European sites will be positive in nature by November 2019. The proposed rail link would: encouraging a modal shift to public transport and away from a reliance on Following this, a road transport. • Reduce rail journey times between Development Consent Reading and Heathrow by delivering a The potential for in-combination impacts between the Local Plan and the Order application will new, faster, frequent, more reliable western rail access to Heathrow project should be kept under review. be finalised and direct train service to Heathrow with However, it is considered that this project will have a positive contribution submitted to the four trains per hour in each direction. All to air quality by encouraging the use of more sustainable modes of Planning Inspectorate. trains would call at Reading and Slough transport.

34 Central and Eastern Berkshire (2019) Joint Minerals and Waste Plan. Consultation Summary Report: Post Regulation 18 – Draft Plan. Available at: https://documents.hants.gov.uk/environment/JCEBDraftPlanConsultationSummaryReport.pdf [Date Accessed: 22/10/19] 35 Hampshire County Council (2018) Joint Minerals and Waste Plan Habitats Regulations Assessment Screening Report. Available at: https://documents.hants.gov.uk/environment/JCEBHabitatsRegulationsAssessmentScreeningReport-June2018FINAL.pdf [Date Accessed: 24/10/19] 36 Network Rail (2019) Western Rail Link to Heathrow. Available at: https://www.networkrail.co.uk/our-railway-upgrade-plan/key-projects/heathrow-rail-link/ [Date Accessed: 22/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects and alternate trains at Twyford and Maidenhead. • Significantly improve rail connectivity to Heathrow from the Thames Valley, South Coast, South West, South Wales and West Midlands. • Provide an alternative form of transport for passengers and the large number of people who work at the airport who are currently travelling by road. • Ease congestion on roads, including the M4, M3 and M25 resulting in lower CO2 emissions equivalent to approximately 30 million road miles per year. • Generate economic growth and new jobs across the Thames Valley and surrounding areas. • Reduce passenger congestion at London Paddington. M4 Junctions 3 to Highways England will Development will include: At present, an HRA or full Environmental Impact Assessment have not 12 Smart Motorway be improving the M4 been found to be publicly available. Available findings are presented 37 • An additional lane for traffic increasing improvements between junction 3 at below. capacity to reduce congestion; Hayes and junction 12 • More technology on the road to smooth 38 at Theale by upgrading Environmental Impact Assessment Scoping Report (August 2014) flows and manage incidents; and it to a ‘Smart • More reliable journeys. Motorway’. During consultation, NE noted some concerns over potential effects of the Current phase (between junctions 8/9 at proposals on the Thames Basin Heaths SPA and the South West London Scheme development Maidenhead and 4b at M25): Waterbodies SPA/Ramsar. Slough Borough Council, West Berkshire commenced in 2010. Council and Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust • Recreation Ground overbridge – The confirmed that they will provide relevant information and data to further pedestrian and cycle route linking Autumn 2019 – Bridge investigate these effects. Datchet to Upton Court Park will be replacement work demolished, and the new bridge in place by Summer 2020. Public access to the

37 Highways England (2019) M4 junctions 3-12: smart motorway. Available at: https://highwaysengland.co.uk/projects/m4-junctions-3-12-smart-motorway/ [Date Accessed: 22/10/19] 38 Highways Agency (2014) M4 Junctions 3 to 12: Smart Motorway. Environmental Impact Assessment Scoping Report. Available at: https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR010019/TR010019-000152- 140811_TR010019_%202649169_Revised%20Scoping%20Report%20-%20Version%202%20Final.pdf [Date Accessed: 22/10/19]

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Plans and Policies Plan Status Proposed development – Key elements Summary of HRA findings of the Plan that could cause in- combination effects between junctions 8/9 bridge will be removed from 9th The Scoping Report states that it is considered unlikely that the Scheme and 4b. September 2019 and is expected to be will have any impacts on any sites designated under the Habitats reinstated as soon as possible after the Directive. However, this will be confirmed through a formal screening Smart Motorway due new bridge is complete. process, in accordance with DMRB Section 4 Part 1, Assessment of for completion in spring • Marsh Lane overbridge (just west of the Implications on European Sites. 2022. Jubilee River near Dorney) - This will be demolished in mid-November. Local traffic will be diverted via Lake End Road overbridge until the new Marsh Lane bridge is complete in 2020. • Monkey Island Lane overbridge (just west of the River Thames also near Dorney) - Preparation work is underway, and new bridge beams will be lifted in mid-November. The existing bridge will remain in place until the replacement is ready. • Huntercombe Spur overbridge at junction 7 - This will be demolished in late November. A temporary overbridge will be installed in advance and will be in place throughout the construction process. The motorway will need to be closed during weekends to complete the necessary demolition and construction.

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Existing recreational resource in Existing recreational resource character type Access, parking and facilities etc RBWM and surrounding area Battlemead Common Habitats include areas of floodplain grazing marsh and Managed by RBWM. deciduous woodland Priority Habitats. Links to Thames Path. Currently no car parking facilities. A small car park is planned for visitors to Battlemead Common, off Lower Cookham Road, subject to planning permission. The site sits alongside the National Trust Widbrook Common.

Cliveden Woodland and formal parks and gardens. Located within South Buckinghamshire, but on the Plan boundary. Managed by the National Trust. Car parking, shop, café, restaurants and spa. Signposted public footpaths and walks. Children’s play area.

Maidenhead and Cookham Maidenhead and Cookham Commons are a series of 900 acres managed by The National Trust. Common commons, stretching from Cookham in the east, An area of Cock Marsh is designated as as a SSSI. Maidenhead Thicket in the west, and to North Town Moor Parking at Cookham Moor National Trust car park for on the northern edge of Maidenhead. Cookham Common. Free parking at Pinkneys Green. There are also free car parks (for Maidenhead Common). Designated walking trails. Public toilets are located behind the Stanley Spencer Gallery (Cookham) and in Maidenhead town centre. Facilities provided at several public houses, cafes and shops in Cookham and along the routes.

The Thames Path National trail along the River Thames. National Trail. Section within the Plan area managed by RBWM. The Thames Path runs from Kemble in Gloucestershire, to the Thames Barrier in Charlton, south

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Existing recreational resource in Existing recreational resource character type Access, parking and facilities etc RBWM and surrounding area east London, with a 23-mile stretch linking Henley and Windsor in RBWM. It flows along the boundary of RBWM and South Buckinghamshire Council. Accessible from various public car parks along its route.

The Queen Mother’s Reservoir Waterbody. Managed by Thames Water. Restrictions in access due to health and safety concerns. Datchet Water Sailing Club. Designated as a Local Wildlife Site. Permits issued to bird watching clubs. Car park and facilities only at the sailing club.

Dorney Lake Waterbody and arboretum. Owned and managed by Eton College Services. Purpose built rowing lake. Parking on site. Footpaths across site. Restaurant and toilet facilities on site.

Home Park Parkland. Managed by The Crown Estate. Lies on the eastern side of Windsor Castle. 31 hectare site. Pay and display car park on site and children’s play area.

The Savill Garden Woodland and gardens. Managed by the Crown Estate. Parking on site. Playground, Savill Garden Kitchen and toilet facilities on site. Footpaths across the site. 14 hectare site.

The Valley Gardens Woodland. Managed by the Crown Estate. Parking on site. Footpaths across the site. 100 hectare site. Café and toilet facilities on site.

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Existing recreational resource in Existing recreational resource character type Access, parking and facilities etc RBWM and surrounding area

Virginia Water Waterbody and woodland. Managed by the Crown Estate. Parking on site. Restaurant and toilet facilities on site. Footpaths across the site.

The Long Walk & Deer Park Tree-lined avenue. Managed by the Crown Estate. Parking located within 1km on the site. Footpaths across the site.

Park Wood, High Wood, and Woodland. Woodland to the south of Bisham Woods SSSI (also a Goulding's Wood, Carpenters component of the Chiltern Beechwoods SAC). Wood and Dungrovehill Wood Designated as a Local Wildlife Site. Woods contain a number of public rights of way. Limited parking in the form of pull-ins along Quarry Wood Road, Grubswood Lane and Marlow Road.

Summerleaze Gravel Pit Gravel pit. Home to Maidenhead Sailing Club.

Dorney Wood Garden Formal gardens. Managed by The National Trust. 1930’s Garden.

Great Thrift Wood Woodland. Designated as a SSSI. Great Thrift Wood displays a varied and relatively undisturbed stand structure with a rich shrub and ground flora, all indicating a very long continuity of woodland cover. The woodland is important for its representation of five semi-natural stand-types.

Ockwells Park Parkland and nature reserve South of Maidenhead Managed by RBWM

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Existing recreational resource in Existing recreational resource character type Access, parking and facilities etc RBWM and surrounding area Parking Playing field Toilets Footpaths Allens Field Parkland Ascot Managed by RBWM Car parking Local Wildlife Site

Appendix I: Ricardo Energy & Environment Air Quality Report

Air Quality Assessment for RBWM BLPSV- PC Review

______Report for Royal Borough of Windsor and Maidenhead

ED 13199100 | Issue Number 6 | Date 20/03/2020 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | i

Customer: Contact: Royal Borough of Windsor and Maidenhead Thomas Adams Ricardo Energy & Environment Gemini Building, Harwell, Didcot, OX11 0QR, United Kingdom

Confidentiality, copyright & reproduction: t: +44 (0) 1235 75 3517 e: [email protected] This report is submitted by Ricardo Energy & Environment under contract to the Royal Borough of Windsor and Maidenhead. Ricardo-AEA Ltd is certificated to ISO9001 and ISO14001

Authors: Thomas Adams, Richard Andrews, Hayley Breen, Charlotte Day, Abigail Pepler, Martha Preater, Tom Priestley and Hannah Walker

Approved By: Mark Broomfield and Martin Ferreira

Date: 20 March 2020

Ricardo Energy & Environment reference: Ref: ED13199100- Issue Number 6

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Executive Summary

Introduction Approximately 150,000 people live in the Royal Borough of Windsor and Maidenhead (RBWM). With an area of 198 km2, the borough is predominantly rural, with the main population centres in Maidenhead, Windsor and Ascot. The borough is located in the south-east of England and is subject to the pressures resulting from this location, including relatively high background levels of air pollution and the presence of major roads running through and close to the borough. RBWM and the surrounding area includes numerous nature conservation areas of national and international significance. These sites may be adversely affected by increases in air concentrations of pollutants, particularly oxides of nitrogen and ammonia, and the deposition of these pollutants within the habitats. Ricardo Energy & Environment produced the Habitat Regulations Assessment (HRA) Stage 1 Screening Assessment1 and Stage 2 Appropriate Assessment2 for the RBWM Borough Local Plan in 2018. RBWM has since identified a number of changes to proposed housing and employment allocations. These are reflected in the Borough Local Plan Submission Version – Proposed Changes (BLPSV-PC). In addition, RBWM is considering Green Infrastructure allocation within the updated BLPSV-PC. As a result of the proposed allocation changes and Green Infrastructure space allocation, both the Stage 1 and Stage 2 HRA reports require updating, to reflect these changes. This report includes an update of the Stage 1 HRA Report, with a specific focus on the following tasks: a) To update the reports in light of significant changes to the housing allocations; b) To update the reports in light of changes to the employment allocations set out in Policy ED2; c) To update the reports in light of a proposed new Green Infrastructure space allocation; and d) To consider the above changes within an in-combination assessment, where required. This report contains the results of a Stage 1 and Stage 2 Air Quality HRA of road traffic emissions associated with the proposed development within RBWM. The HRA forms part of the robust evidence base supporting RBWM Council in connection with their emerging RBWM BLPSV-PC. The BLPSV-PC study area contains the designated sites with European (or equivalent international) designation, namely Ramsar sites, Special Areas of Conservation (SACs), and Special Protection Areas (SPAs) within a 10 km buffer area around RBWM. Method For all European-designated sites contained in the study area, a sub-regional air dispersion model (RapidAIR) was used to model predicted air quality impacts at a resolution of 3 m x 3 m. Traffic growth within the study area was provided by Royal Borough of Windsor and Maidenhead.3 Four traffic scenarios were modelled for the purposes of this study, in order to assess the potential air quality impacts of the RBWM BLPSV-PC:

• 2016 Reference (2016 Ref): This model was designed to replicate 2016 traffic conditions within RBWM. It was used to verify the performance of the air dispersion model.

• 2033 Baseline (2033 BL / Scenario A): This model represents a scenario including all known current (as of 2019) completed development and infrastructure within RBWM, in addition to all

1 Ricardo (2019), Habitats Regulations Screening Report, Borough Local Plan Regulation 19 Consultation. Report for Royal Borough of Windsor & Maidenhead. ED11104104.

2 Ricardo (2019), RBWM Borough Local Plan: Appropriate Assessment. Information to Inform an Appropriate Assessment (Habitats Regulations Assessment (HRA) Stage 2). Report for Royal Borough of Windsor and Maidenhead.

3 GIS datasets provided by WSP Parsons Brinckerhoff to RBWM, October 2019

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committed development and infrastructure up to 2033. This is a hypothetical scenario against which to test the impacts of the RBWM BLPSV-PC, as it assumes the unlikely scenario that there will be no development within RBWM up to 2033, other than at sites which already have planning permission.

• 2033 Scenario B (Scenario B): This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development but assumes there will be no further improvements to the transport network, aside from those which are already committed and therefore already included in the 2033 BL scenario. Development growth outside RBWM is identical to that included in the 2033 BL scenario. • 2033 Scenario C (Scenario C): This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development as well as further improvements to the transport network required to mitigate the impact of the RBWM BLPSV-PC on highways and road junctions, which are not already included in the 2033 BL scenario. It does not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. Development growth outside RBWM is identical to that included in the 2033 BL scenario. Additionally, in order to assist with an assessment of in-combination effects arising from emerging local plans in neighbouring authorities, HRA reports were identified and reviewed for neighbouring authorities. Information on the impacts of other borough Local Plans was taken from the HRA reports for those local plans. In-combination effects were evaluated by explicitly considering modelled levels of nitrogen deposition, acid deposition and airborne oxides of nitrogen at the European sites under consideration. Where modelled data were not available in relation to Local Plans published by neighbouring boroughs, the assessment of in-combination effects was based on qualitative findings published by these authorities. Air quality impacts on designated sites were assessed based on predicted annual average airborne concentrations of oxides of nitrogen (NOx) and ammonia (NH3), as well as annual average deposition rates of nutrient nitrogen and acid. Predicted pollutant concentrations associated with the proposed development in Scenario B and Scenario C were compared to pollutant screening thresholds in an HRA Stage 1 Assessment. Findings for air quality impacts on human health If the development envisaged in the BLPSV-PC could potentially affect air quality within an AQMA, this could pose a constraint on realising the full development potential. Consequently, the impact of the BLPSV-PC on air quality in the five Air Quality Management Areas (AQMAs) in RBWM was assessed. These AQMAs were all designated because concentrations of nitrogen dioxide were above the air quality objective for nitrogen dioxide, or at risk of exceeding this objective.

An assessment of NO2, PM10 and PM2.5 concentrations was performed across the entire RBWM including areas that are not assigned as AQMAs. For both Scenario B and Scenario C there were no concentrations above the AQOs, or within 10% of the AQOs, at locations where AQOs should apply. The most significant changes in concentrations at receptor points are observed in the Maidenhead and Bray/M4 AQMAs, with differences greater than 1% of the air quality standard of 40 µg/m3 between Scenario B and Scenario C and the 2033 BL scenario. However, no relevant locations were identified as being at risk of exceeding the AQOs in 2033 for both scenarios containing the BLPSV-PC. Findings for air quality impacts on designated habitat sites Air quality impacts from Scenario C were used to assess the impacts of the BLPSV-PC against the habitats regulations. This is because the transport mitigation schemes included in Scenario C would be required to mitigate the impact of the RBWM BLPSV-PC on highways and road junctions and do not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites.

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At HRA Stage 1, only one site was screened out for all pollutants: • Burnham Beeches SAC Where screening analysis indicated that Likely Significant Effects (LSEs) on part of a European site could not be ruled out, further analysis was undertaken in the form of an HRA Stage 2 Appropriate Assessment. The sites where this was applicable for Scenario C contributions were: • South West London Waterbodies Ramsar & SPA • Thames Basin Heaths SPA • Thursley, Ash, Pirbright & Chobham SAC • Windsor Forest & Great Park SAC • Chiltern Beechwoods SAC The Stage 2 Appropriate Assessment reached the following conclusions, following consultation with Natural England: • South West London Waterbodies Ramsar & SPA: the area potentially affected by the BLPSV- PC would only be susceptible to impacts resulting from algal bloom as a result of excessive nitrogen deposition. The contribution from the BLPSV-PC would be insignificant in relation to the risk of algal bloom. • Thames Basin Heaths SPA: a site visit confirmed that the area potentially affected by the BLPSV-PC does not contain habitats sensitive to air pollution impacts. The contribution from the BLPSV-PC at other locations would be insignificant. • Thursley, Ash, Pirbright & Chobham SAC: a site visit confirmed that the area potentially affected by the BLPSV-PC does not contain habitats sensitive to air pollution impacts. The contribution from the BLPSV-PC at other locations would be insignificant. • Windsor Forest & Great Park SAC: a site visit confirmed that the area potentially affected by the BLPSV-PC does not contain potentially relevant habitats, comprising ancient and veteran oak and beech trees. The contribution from the BLPSV-PC at other locations would be insignificant. • Chiltern Beechwoods SAC: Natural England confirmed that the area potentially affected by the BLPSV-PC does not contain habitats sensitive to air pollution impacts. The contribution from the BLPSV-PC at other locations would be insignificant. It is therefore concluded that the RBWM BLPSV-PC in isolation would have no likely significant effect on the Natura 2000 sites. The risk of in-combination impacts was assessed by reviewing the available evidence for impacts due to other potentially relevant plans and projects. Quantitative assessment based on the information currently available indicates that no significant in-combination impacts are forecast to occur. Nevertheless, the boroughs should work together as the evidence base for development plans in the region continues to emerge.

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Table of contents Executive Summary ...... ii Abbreviations ...... 6 1 Introduction ...... 7 2 Method Statement ...... 9 2.1 Study Overview ...... 9 2.2 Updated Transport Model ...... 9 2.3 Air dispersion modelling methodology ...... 10 2.4 Assessment of impacts on designated sites ...... 17 3 Assessment of air quality related to human health ...... 22 3.1 Overview of air quality standards for human health ...... 22 3.2 Air Quality Management Areas (AQMAs) within the Royal Borough of Windsor and Maidenhead ...... 22 3.3 Modelled receptor points ...... 24 3.4 Model results ...... 24 3.5 Summary of model results ...... 48 4 Assessment of air quality impacts on designated sites ...... 49 4.1 Burnham Beeches SAC (UK0030034) ...... 49 4.2 Chilterns Beechwoods SAC (UK0012724) ...... 53 4.3 Thursley, Ash, Pirbright & Chobham SAC (UK0012793) ...... 65 4.4 Windsor Forest and Great Park SAC (UK0012586) ...... 76 4.5 South West London Waterbodies Ramsar (UK11065) and SPA (UK9012171)...... 87 4.6 Thames Basin Heaths SPA (UK9012141) ...... 96 5 Summary of HRA results and conclusions ...... 113 Appendices ...... 116

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Abbreviations Abbreviation Explanation AADT Annual Average Daily Traffic APIS Air Pollution Information System AQIA Air Quality Impact Assessment AQMA Air Quality Management Area AQO Air Quality Objective ASR Annual Status Report AURN Automatic Urban and Rural Network BEIS UK Department for Business, Energy & Industrial Strategy BL Baseline (a future-year model scenario) BLP Borough Local Plan BLPSV-PC Borough Local Plan Submission Version – Proposed Changes CAZ Clean Air Zone CL Critical Limit/Level EEA European Environment Agency EFT Emissions Factor Toolkit GIS Geographic Information System HGV Heavy Goods Vehicle HRA Habitat Regulations Assessment IAQM Institute of Air Quality Management LAQM Local Air Quality Management LES Low Emission Strategy LGV Light Goods Vehicle NAEI National Atmospheric Emissions Inventory

NH3 Ammonia NMHBAHP No main habitat but additional habitats present NOAA National Oceanic and Atmospheric Administration

NO2 Nitrogen dioxide

NOx Nitrogen oxides (NO + NO2) PHI Priority Habitat Inventory, a GIS dataset from Natural England

PM10 Particulate matter 10 micrometres or less in diameter PUSH Partnership for Urban South Hampshire RBWM Royal Borough of Windsor and Maidenhead RMSE Root Mean Square Error SAC Special Area of Conservation SIP Site Improvement Plan SPA Special Protection Area SSSI Site of Special Scientific Interest

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1 Introduction

Approximately 150,000 people live in the Royal Borough of Windsor and Maidenhead (RBWM). With an area of 198 km2, the borough is predominantly rural, with the main population centres in Maidenhead, Windsor and Ascot. The borough is located in the south-east of England and is subject to the pressures resulting from this location, including relatively high background levels of air pollution and the presence of major roads running through and close to the borough. RBWM and the surrounding area includes numerous nature conservation areas of national and international significance. These sites may be adversely affected by increases in air concentrations of pollutants, particularly oxides of nitrogen and ammonia, and the deposition of these pollutants within the habitats. Ricardo Energy & Environment carried out the Habitat Regulations Assessment (HRA) Stage 1 Screening Assessment4 and Stage 2 Appropriate Assessment5 for the RBWM Borough Local Plan (BLPSV-PC) in 2018. RBWM has since identified a number of changes to proposed housing and employment allocations. In addition, RBWM is considering Green Infrastructure allocation within the updated BLPSV-PC. As a result of the proposed allocation changes and Green Infrastructure space allocation, both the Stage 1 and Stage 2 HRA reports require updating, to reflect these changes. This report includes an update of the Stage 1 HRA Report, with a specific focus on the following tasks: a) To update the reports in light of significant changes to the housing allocations; b) To update the reports in light of changes to the employment allocations set out in Policy ED2; c) To update the reports in light of a proposed new Green Infrastructure space allocation; and d) To consider the above changes within an in-combination assessment, where required. This report contains the results of an Air Quality HRA of road traffic emissions associated with the proposed development within RBWM. The HRA forms part of the robust evidence base supporting RBWM Council in connection with their emerging RBWM BLPSV-PC. The BLPSV-PC study area contains the designated sites with European (or equivalent international) designation, namely Ramsar sites, Special Areas of Conservation (SACs), and Special Protection Areas (SPAs) within a 10 km buffer area around RBWM. For all European-designated sites contained in the study area, a sub-regional air dispersion model (RapidAIR) was used to model predicted air quality impacts at a resolution of 3 m x 3 m. Forecast traffic flows within the study area were provided by Royal Borough of Windsor and Maidenhead.6 Four traffic scenarios were modelled for the purposes of this study, in order to assess the potential air quality impacts of the RBWM BLPSV-PC: • 2016 Reference (2016 Ref): This model was designed to replicate 2016 traffic conditions within RBWM. It was used to verify the performance of the air dispersion model.

• 2033 Baseline (2033 BL / Scenario A): This model represents a scenario including all known current (as of 2019) completed development and infrastructure within RBWM, in addition to all committed development and infrastructure up to 2033. This is a hypothetical scenario against which to test the impacts of the RBWM BLPSV-PC, as it assumes the unlikely scenario that there will be no development within RBWM up to 2033, other than at sites which already have planning permission.

4 Ricardo (2019), Habitats Regulations Screening Report, Borough Local Plan Regulation 19 Consultation. Report for Royal Borough of Windsor & Maidenhead. ED11104104.

5 Ricardo (2019), RBWM Borough Local Plan: Appropriate Assessment. Information to Inform an Appropriate Assessment (Habitats Regulations Assessment (HRA) Stage 2). Report for Royal Borough of Windsor and Maidenhead.

6 GIS datasets provided by WSP Parsons Brinckerhoff to RBWM, October 2019

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• 2033 Scenario C (Scenario C): This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development as well as further improvements to the transport network required to mitigate the impact of the RBWM BLPSV-PC on highways and road junctions, which are not already included in the 2033 BL scenario. It does not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. Development growth outside RBWM is identical to that included in the 2033 BL scenario. Additionally, in order to assist with an assessment of in-combination effects arising from emerging local plans in neighbouring authorities, HRA reports were identified and reviewed for neighbouring authorities. Information on the impacts of other borough Local Plans was taken from the HRA reports for those local plans. In-combination effects were evaluated by explicitly considering modelled levels of nitrogen deposition, acid deposition and airborne oxides of nitrogen at the European sites under consideration. Where modelled data were not available in relation to Local Plans published by neighbouring boroughs, the assessment of in-combination effects was based on qualitative findings published by these authorities. Following the Stage 1 assessment, the impacts at the areas of European sites which were not screened out at Stage 1 were assessed in more detail (Stage 2). The findings of the Stage 2 assessment were discussed with Natural England, and have been finalised in this report. Alongside the assessment of impacts on protected habitat sites, it is also important to investigate the potential effects of the BLPSV-PC on air quality in relation to the Council’s obligations to manage local air quality. If the development envisaged in the BLPSV-PC could potentially affect air quality within an AQMA, this could pose a constraint on realising the full development potential. Consequently, the impact of the BLPSV-PC on air quality in the five Air Quality Management Areas (AQMAs) in RBWM was assessed. These AQMAs were all designated because concentrations of nitrogen dioxide were above the air quality objective for nitrogen dioxide (40 µg/m3), or at risk of exceeding this objective.

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2 Method Statement

2.1 Study Overview This chapter begins by describing the transport modelling upon which the air quality modelling was based, using information from the traffic model developers (WSP Parsons Brinckerhoff). It then goes on to describe the air quality modelling methodology utilized for the four RBWM model scenarios (2016 Ref, 2033 BL, Scenario B and Scenario C), as well as the methodology for the assessment of impacts on designated sites.

2.2 Updated Transport Model Traffic data were provided by Royal Borough of Windsor and Maidenhead.7 Further details of the strategic traffic modelling is provided in a report prepared by RBWM’s consultants, WSP Parsons Brinckerhoff (this report refers to a previous iteration of the traffic model, but the approach and methodology for the traffic modelling results used in this assessment are understood to be similar to the previous analysis).8 The features of the data provided were as follows: • The traffic data covers three zones: o Zone 1: Within the borough: all roads are included in the model o Zone 2: Outside but surrounding the borough: all motorways, A roads and B roads are included in the model o Outside Zone 3: Major roads included in the model • It was considered that the available road links provided sufficient accuracy in the study areas to form a robust basis for the study. • Traffic data were provided for four scenarios: o 2016 Reference (2016 Ref): This model was designed to replicate 2016 traffic conditions within RBWM. It was used to verify the performance of the air dispersion model.

o 2033 Baseline (2033 BL / Scenario A): This model represents a scenario including all known current (as of 2019) completed development and infrastructure within RBWM, in addition to all committed development and infrastructure up to 2033. This is a hypothetical scenario against which to test the impacts of the RBWM BLPSV-PC, as it assumes the unlikely scenario that there will be no development within RBWM up to 2033, other than at sites which already have planning permission. o Scenario B: This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development but assumes there will be no further improvements to the transport network, aside from those which are already committed and therefore already included in the 2033 BL scenario. Development growth outside RBWM is identical to that included in the 2033 BL scenario.

o Scenario C: This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development as well as further improvements to the transport

7 GIS datasets provided by WSP Parsons Brinckerhoff to RBWM, November-October 2019

8 Royal Borough of Windsor and Maidenhead “Local Plan Assessment using RBWM Strategic Highway Model,” WSP Parsons Brinckerhoff Report ref. 70016529, June 2017

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network required to mitigate the impact of the RBWM BLPSV-PC on highways and road junctions, which are not already included in the 2033 BL scenario. It does not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. Development growth outside RBWM is identical to that included in the 2033 BL scenario.

• Traffic data were provided as Annual Average Daily Traffic (AADT) flows • Traffic speed data was provided by the traffic consultants, WSP Parsons Brinckerhoff.3 • Road alignments were included in the WSP Parsons Brinckerhoff data, but these were approximate only. For the purposes of this strategic assessment, the road alignments were snapped to the Ordnance Survey (OS) Integrated Transport Network (ITN) layer at all locations included within the modelling domain.

2.3 Air dispersion modelling methodology 2.3.1 Air quality modelling system The RapidAIR Urban Air Quality Modelling Platform was used to predict air pollutant concentrations for this study. This is Ricardo Energy & Environment’s proprietary modelling system developed for urban air pollution assessment, and the model that was used previously in the assessment of the RBWM BLPSV-PC completed in March 2018, as well as for Southampton for the Low Emission Strategy (LES) and Clean Air Zone (CAZ) studies and for the Partnership for Urban South Hampshire (PUSH) air quality impact assessment (AQIA) completed in September 2018. RapidAIR has been developed to provide graphic and numerical outputs which are comparable with other models used widely in the United Kingdom. The model approach is based on loose-coupling of three elements: • Road traffic emissions model conducted using fleet specific COPERT 5 (via the Defra EfT) algorithms to prepare grams/kilometre/second (g km-1 s-1) emission rates of air pollutants originating from traffic sources. • Convolution of an emissions grid with dispersion kernels derived from the USEPA AERMOD9 model, at resolutions ranging from 1 m to 20 m. AERMOD provides the algorithms which govern the dispersion of the emissions and is an accepted international model for road traffic studies.

• The kernel based RapidAIR model running in GIS software to prepare dispersion fields of concentration for further analysis with a set of decision support tools coded by us in Python/arcpy. RapidAIR includes an automated meteorological processor based on AERMET which obtains and processes meteorological data of a format suitable for use in AERMOD. Surface meteorological data is obtained from the NOAA online repository10 and upper air data is downloaded from the NOAA Radiosonde database11. The model produces high resolution concentration fields at the city scale (down to a 1 m scale) so is ideal for spatially detailed compliance modelling. The combination of an internationally recognised model code and careful parameterisation matching international best practice makes RapidAIR ideal for this study. A validation study has been conducted in London using the same datasets as the 2011

9 https://www3.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod 10 ftp://ftp.ncdc.noaa.gov/pub/data/noaa

11 https://www.esrl.noaa.gov/roabs/

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Defra air quality model inter-comparison study12. Using the LAEI (London Atmospheric Emissions Inventory) 2008 data and the measurements for the same time period the model performance is consistent (and across some metrics performs better) than other modelling solutions currently in use in the UK.13 This validation study has been published in Environmental Modelling and Software, in partnership with the University of Strathclyde14. 2.3.2 Model domain Dispersion modelling was carried out to forecast levels of air pollutants at a 3 m x 3 m grid resolution across the entire RBWM study area, including all the designated sites within a 10 km buffer area around the RBWM and all AQMAs within the borough. A grid height of 1.5 m was modelled to represent human exposure at ground level. Dispersion modelling was carried out for the years 2016 (as a reference year for dispersion model verification) as well as three future 2033 scenarios (2033 BL, Scenario B and Scenario C). Data were then extracted from the 3 m x 3 m grid results to provide a detailed evaluation of air quality impacts at locations within the relevant designated sites and AQMAs. 2.3.3 Traffic activity data Annual average daily traffic (AADT) vehicle numbers and average vehicle speeds were extracted from the datasets provided by WSP for the four scenarios (2016 Ref, 2033 BL, Scenario B and Scenario C). Further detailed information about the four transport model scenarios can be found in Section 2.2. The transport model provides a fleet composition breakdown into cars, light goods vehicles (LGVs), and heavy goods vehicles (HGVs). NAEI (National Atmospheric Emissions Inventory) fleet split information can be used to further split cars into petrol and diesel categories, and HGVs into rigid HGV and articulated HGV categories, based on national average fleet composition information and depending on whether the road link is categorized as rural, urban or motorway. For this study, AADT numbers for cars and HGVs were further categorized based on mapping the transport model road types onto the NAEI road types as shown in Table 2-1 and Table 2-2. Non- motorway road types were categorized as either rural or urban based on their location as compared to the 2011 Rural-Urban Classification for Local Enterprise Partnership (LEP) Areas based on Census Output Areas.15 AADT numbers for buses and coaches (Table 2-4) were estimated for urban, rural and motorway road types using DfT traffic count data16 recorded at points located within the modelling domain.

Table 2-1 NAEI fleet split information used to construct the transport data for the 2016 Ref Scenario Articulated NAEI Road Type Petrol Car Diesel Car Electric Car Rigid HGV HGV

Urban (not London) 57.29% 42.59% 0.12% 72.38% 27.62%

Rural 50.83% 49.17% – 52.25% 47.75% Motorway 40.84% 59.16% – 30.63% 69.37%

12 https://uk-air.defra.gov.uk/research/air-quality-modelling?view=intercomparison

13 The 2008 LAEI dataset was used in this context as a benchmarking study, to compare the performance of RapidAIR to other modelling systems. The 2008 LAEI dataset was not used as an input in the current modelling study.

14 Masey, Nicola, Scott Hamilton, and Iain J. Beverland. "Development and evaluation of the RapidAIR® dispersion model, including the use of geospatial surrogates to represent street canyon effects." Environmental Modelling & Software (2018). DOI: https://doi.org/10.1016/j.envsoft.2018.05.014

15 https://www.gov.uk/government/statistical-data-sets/local-enterprise-partnerships-leps-rural-urban-gis-shapefiles

16 DfT traffic count data accessed October 2019 https://roadtraffic.dft.gov.uk/#6/55.254/-6.053/basemap-regions-countpoints

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Table 2-2 NAEI fleet split information used to construct the transport data for the 2033 BL Scenario, Scenario B & Scenario C Articulated NAEI Road Type Petrol Car Diesel Car Electric Car Rigid HGV HGV

Urban (not London) 60.10% 36.37% 3.52% 73.43% 26.57%

Rural 56.65% 43.35% – 48.41% 51.59%

Motorway 48.16% 51.84% – 28.96% 71.04%

Table 2-3 EfT count data used to construct the AADT numbers for buses and coaches NAEI Road Type Buses & Coaches

Urban 0.48%

Rural 0.28%

Motorway 0.30%

The fleet compositions in Table 2-1 and Table 2-2 were calculated using the most recent set of NAEI fleet projection information available at the time of commission (base year 2018, published December 2018).17 2.3.4 Emission factors

Vehicle emission factors for oxides of nitrogen (NOx) and particulate matter (PM10 and PM2.5) were 17 obtained from COPERT v5 emission functions. Vehicle emission factors for ammonia (NH3) were obtained from the EMEP/EEA air pollutant emission inventory guidebook.18 Link specific emission factors were calculated with Ricardo’s in-house emission calculation tool RapidEMS, which links directly to our RapidAIR dispersion modelling system. The input for RapidEMS consists of a basic fleet split based on vehicle categories (diesel cars, petrol cars, LGVs, articulated HGVs, rigid HGVs, and buses) according to the traffic activity information specified in Section 2.3.3. RapidEMS is used to provide a more detailed parameterization of vehicle fleets in 2016 and 2033, including all vehicles up to and including Euro 6/VI. 2.3.5 Meteorological data RapidAIR includes an automated meteorological processor based on AERMET which obtains and processes meteorological data of a format suitable for use in AERMOD. Surface meteorological data is obtained from the NOAA online repository19 and upper air data is downloaded from the NOAA Radiosonde database20. For this study, 2016 surface meteorological data was obtained from three stations (Heathrow, Northolt and Farnborough) and upper air meteorological data was obtained from two stations (Larkhill and Herstomonceux). RapidMet was used to carry out data filling where necessary according to the methodology provided by the USEPA in their “Meteorological Monitoring Guidance for Regulatory Modelling Applications” guidance document21. Data gaps from the primary meteorological stations (Heathrow and Larkhill) are first filled using data from the other nearby stations (Northolt and

17 National Atmospheric Emissions Inventory, “Emission factors for transport”, http://naei.beis.gov.uk/data/ef-transport, accessed October 2019.

18 European Environment Agency, “EMEP/EEA air pollution emission inventory guidebook 2016”, https://www.eea.europa.eu/publications/emep- eea-guidebook-2016, accessed 12/12/2017.

19 ftp://ftp.ncdc.noaa.gov/pub/data/noaa

20 https://www.esrl.noaa.gov/roabs/

21 United States Environmental Protection Agency, “Meteorological Monitoring Guidance for Regulatory Modelling Applications” available via https://www3.epa.gov/scram001/guidance/met/mmgrma.pdf, accessed June 2017.

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Farnborough for surface stations, and Herstomonceux for the upper air station). Remaining data gaps were filled based on the persistence method, where a missing value is replaced by the use of data from the previous hour(s), for data gaps up to and including three hours. 2.3.6 Reference year modelling and model verification This section provides a summary of the model verification process and the derivation of linear adjustment factors to improve model performance. A more detailed description of the model verification process is presented in Appendix 1.

2.3.6.1 Oxides of nitrogen (NOx) and nitrogen dioxide (NO2) model verification and adjustment

A combination of automatic monitoring and diffusion tube NO2 measurements was used for model verification. NO2 measurements were obtained from Defra’s Automatic Urban and Rural Network (AURN) as well as the Annual Status Reports (ASRs) of RBWM. Some monitoring sites were excluded from the model verification process for the following reasons: • The monitoring station is located outside the boundary of the RBWM.

• No measurement was reported for that monitoring site in 2016. • Data capture for the monitoring site was less than 75% in 2016.

After exclusion of some monitoring sites for the above reasons, a total of 41 NO2 measurements were carried forward into the model verification step. RapidAIR was used to generate a map of NOx concentrations arising from road traffic sources across the entire RBWM study area at a 3 m x 3 m resolution, based on the traffic activity data from the 2016 Reference Case and 2016 meteorological data. Background NOx values for 2016 were obtained from the background maps available on the LAQM website.22 The most up to date background maps used a 2017 base year. A 2017 base year background map was not available for 2016, therefore, a 2017-based 2016 background map was generated by applying a specific scaling factor to every 1 km x 1 km grid square of the 2015-based 2016 background map. The scaling factor was derived using the differences between the 2015-based 2016 map and 2017-based 2016 map. NOx contributions arising from major roads were removed from the background map values to avoid double-counting, and the background values were then added to the RapidAIR road NOx results to compare the modelled vs measured concentrations at each of the monitoring locations. This initial comparison indicated that the model was under-predicting the NOx arising from road emissions at most locations. Refinements were subsequently made to the model inputs to improve model performance where possible, and a linear adjustment factor of 2.4733 was calculated for the road emissions component of the NOx model (see Appendix 1). Total NOx was calculated as the sum of the adjusted NOx road contribution from RapidAIR and the Defra 2016 background maps (with main road sources removed from the background map). Total NO2 concentrations were derived using the following equation (see Appendix 1 for further details):

3 3 2 3 (NO2 in µg/m ) = -0.0006514(NOx in µg/m ) + 0.5175(NOx in µg/m ) + 4.9746 To evaluate model performance and uncertainty, the Root Mean Square Error (RMSE) for the observed vs predicted NO2 annual mean concentrations was calculated, as detailed in Technical Guidance LAQM.TG(16). This guidance indicates that an RMSE of up to 4 µg/m3 is ideal, and an RMSE of up to 10 µg/m3 is acceptable. In this case the RMSE was calculated at 7.95 µg/m3, which is acceptable, and reasonable for a modelling study over this large a geographical region.

22 Department for Environment, Food & Rural Affairs, Background maps, https://laqm.defra.gov.uk/review-and-assessment/tools/background- maps.html, accessed October 2019.

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2.3.6.2 Particulate matter (PM) model verification and adjustment

There is only one monitoring location for PM10 and there are no monitoring locations for PM2.5 located within the RBWM; therefore, it was not possible to compare measured vs modelled concentrations for either of these pollutants. We have adopted an approach based on Section 7.527 of the Technical Guidance LAQM.TG(16) which suggests that, in the absence of measured data for model verification of a traffic pollutant, it may be appropriate to apply the adjustment factor derived from another traffic pollutant to the pollutant that does not have any monitoring data available. We have therefore applied the NOx adjustment factor of 2.4733 to the roads component of the PM10 and PM2.5 model.

2.3.6.3 Ammonia (NH3) model verification and adjustment

There are no monitoring locations for NH3 located within the RBWM, and therefore it was not possible to compare measured vs modelled concentrations for NH3. We have adopted the same approach as for PM in the section above, based on Section 7.527 of the Technical Guidance LAQM.TG(16) which suggests that, in the absence of measured data for model verification of a traffic pollutant, it may be appropriate to apply the adjustment factor derived from another traffic pollutant to the pollutant that does not have any monitoring data available. We have therefore applied the NOx adjustment factor of 2.4733 to the roads component of the NH3 model.

There are no background maps available for NH3 concentrations, and therefore total NH3 concentrations could not be modelled. This does not affect the analysis of air quality impacts at designated sites, as it is the development contribution to traffic emissions that is of interest in this study, rather than the total concentration of NH3. 2.3.7 Future scenario modelling 2.3.7.1 Airborne pollutant concentrations For the three future scenarios (2033 BL, Scenario B and Scenario C), RapidAIR was used to generate pollutant concentration map across the entire study area at a 3 m x 3 m resolution. These maps were generated using traffic activity data from the appropriate future scenario, emission factors calculated using RapidEMS, and 2016 meteorological data.

Pollutant concentration maps for road-only contributions (NOx, NO2, and NH3) were calculated using the adjustment factors described in Section 2.3.6. Maps for total pollutant concentrations (NOx and NO2) were calculated by adding the road-only concentration maps to the appropriate pollutant background map from the LAQM website. Background maps for the year 2030 were selected, as this is the farthest year into the future for which background maps are available. 2.3.7.2 Pollutant deposition Dry deposition rates of nutrient nitrogen and acid were calculated by multiplying the ground level air concentration of the appropriate pollutants (road contribution only) by the appropriate deposition velocity, followed by multiplication with a conversion factor. Deposition velocities and conversion factors were obtained from Environment Agency guidance,23 and are provided in Table 2-4 and Table 2-5 respectively.

Table 2-4 Deposition velocities for NO2 and NH3 Pollutant Vegetation type Deposition velocity (m/s) Grassland (sites with short vegetation) 0.0015 NO2 Woodland (sites with tall vegetation) 0.003

NH3 Grassland (sites with short vegetation) 0.02

23 Environment Agency, “AQTAG06: Technical guidance on detailed modelling approach for an appropriate assessment for emissions to air,” March 2014

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Woodland (sites with tall vegetation) 0.03

Table 2-5 Dry deposition conversion factors Conversion factor for nitrogen deposition Conversion factor for acid deposition Pollutant (from µg/m2-s to kgN/ha-year) (from µg/m2-s to kEq/ha-year)

NO2 95.9 6.84

NH3 260 18.5 2.3.8 Model years and considerations This study assesses air pollution concentrations across the study area for 2016 (as a historical reference year) and for three future scenarios in 2033. These years were selected based on the availability of existing modelling results. The 2033 scenarios correspond to the end of the development period associated with the RBWM BLPSV-PC. A comprehensive analysis of the air quality impacts of the RBWM BLPSV-PC development is therefore constrained to the 2033 development scenarios modelled in this study. The model results for future scenarios are particularly important to understand in the context of declining NOx emissions. Figure 2-1 presents projected road emissions of NOx for approximately 9,000 major UK roads from 2018 to 2030. The emissions in this figure are extracted from the Streamlined Pollution Climate Mapping model (SL-PCM)24 for the baseline projection scenario, which assumes no further action beyond air quality measures that were committed across the UK by 2015. Although the emissions correspond to a subset of the UK’s road network, the decrease in annual NOx emissions is indicative of the expected trend in NOx road emissions going forward, reflecting anticipated improvements in Euro emissions standards as well as changing vehicle fleet composition.

Figure 2-1 Projected road emissions of nitrogen oxides (NOx) in ktonnes per year for major UK roads

Indeed, reductions are already being realised. In the study “Nitrogen Dioxide and Nitrogen Oxides 25 Trends in the UK 2005 to 2016” an analysis of NO2 and NOx concentrations measured across the UK showed that a reduction in concentrations of approximately 1.7% per year has been seen on average between 2005 and 2016. Figure 2-2 presents results for monitoring sites in Southern England and Wales. The plot shows the best fit linear trend line, together with the lines representing the 90%

24 SL-PCM has been developed specifically to model the effect of changes in fleet composition on NOX emissions and NO2 concentrations. See https://uk-air.defra.gov.uk/library/no2ten/2017-no2-projections-from-2015-data, accessed 20/09/2018. 25 Nitrogen Dioxide and Nitrogen Oxides Trends in the UK 2005 to 2016, Air Quality Consultants, 2018. http://www.aqconsultants.co.uk/AQC/media/Reports/NO2-NOx-Trend-Report.pdf

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 16 confidence interval. The figure demonstrates a 1.66% reduction per year. The Theil–Sen fit chooses the median of the slopes of all lines through pairs of points to carry out simple linear regression.

Figure 2-2. Overall NO2 Trend across All Sites in Southern England and Southern Wales, with Theil-Sen Fit (% per yr)

2.3.9 Sources of model uncertainty There are a number of sources of model uncertainty inherent in this type of study, as discussed below: • A monitoring site used to derive the linear adjustment factor might be located next to a large car park, bus stop, petrol station, or taxi rank that has not been explicitly modelled due to unknown activity data. This would have the effect of artificially inflating the calculated adjustment factor, resulting in an over-prediction of impacts. Where we have identified such locations, we have removed these from the model verification process.

• A monitoring site used to derive the linear adjustment factor might be located in an area where not all of the road sources contributing to pollutant concentrations have been modelled, i.e. at a junction. This would have the effect of artificially inflating the calculated adjustment factor, resulting in an over-prediction of impacts.

• Uncertainties in the traffic model outputs on modelled road links, with regards to number of vehicles, type of vehicles and vehicle speed. The number of low emission vehicles in the future development scenarios may be underestimated if the UK government is successful in ending the sale of all conventional diesel and petrol cars and vans by 2040, which could result in a systematic over-estimation of future air quality impacts. • Uncertainties in the real-world emissions from Euro 6/VI vehicles. Early real-world emission test results of Euro 6 vehicles indicate mixed results, ranging from vehicles which met the Euro 6 standards under real-world driving emissions to vehicles which displayed NOx emissions up to 12 times higher than the Euro 6 standard.26,27 However, the increasing use of real-world emissions tests is likely to intensify pressure on vehicle manufacturers to comply with more stringent Euro standards. If real-world emissions do not decrease as anticipated, RBWM may wish to review the current study in the context of updated emission parameters at some point in the future.

26 The Real Urban Emissions Initiative, https://www.trueinitiative.org/, accessed 20/06/2018.

27 Emissions Analytics, EQUA Index, https://equaindex.com/equa-air-quality-index/, accessed 20/06/2018.

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• Uncertainties in the background maps used to develop model adjustment factors and predict total modelled concentrations, with regards to other sources of pollution, such as industrial sources, domestic heating, port activity and forest fires.

• Background maps for the year 2030 were used to calculate total pollutant concentrations in the 2033 scenarios, as that is the farthest year into the future for which background maps are available. Background concentrations in 2030 are not expected to differ significantly from background concentrations in 2033, taking into account the uncertainties associated with the interpolation process and forecasting 14 years into the future. If anything, the 2030 maps are expected to be slightly conservative (i.e. over-predict) for NOx and NO2 levels in 2033. There is no strong reason to anticipate that the 2030 maps for PM10 would be over- or under- predictions of the levels expected to occur in 2033.

• Uncertainties resulting from the lack of monitoring data for particulate matter (PM10 and PM2.5). There are few monitoring locations for PM10 located within the RBWM study area and no monitoring locations for PM2.5. We have therefore applied the NOx adjustment factor to the PM10 and PM2.5 model outputs. The incorporation of monitoring data for PM10 and PM2.5 (if available) would result in a more robust model.

• Uncertainties resulting from the lack of monitoring data for ammonia (NH3). There are no monitoring locations for NH3 located within the RBWM study area. We have therefore applied the NOx adjustment factor to the NH3 model outputs. The incorporation of monitoring data for NH3 (if available) would result in a more robust model.

• Uncertainties in the dispersion modelling process. These are accounted for so far as possible through the model verification process, but there inevitably remain some differences between modelled concentrations and the levels that would be measured in practice.

2.4 Assessment of impacts on designated sites The assessment of impacts on sites designated for nature conservation was carried out in a stepwise process, designed to comply with Natural England’s emerging requirements and good practice for evaluation of the impacts of air pollution on nature conservation sites. The requirements from Natural England were developed primarily for the assessment of designated sites with European (or equivalent international) designation, namely Ramsar sites, Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). 2.4.1 Consideration of whether the proposed development could give rise to emissions which are likely to reach a designated site Long-standing guidance from Natural England and Highways England (the Design Manual for Roads and Bridges, DMRB)28 indicates that protected sites falling within 200 metres of the edge of a road affected by a plan or project need to be considered further. This assessment avoids the need for relying on the assumption of a 200-metre zone of influence by including dispersion modelling of emissions from all roads with modelled traffic flows within the RBWM study area, whether or not they are located within 200 m of a designated site. All potentially relevant designated sites located within 10 km of RBWM were included in the subsequent stage. This approach ensured a robust assessment without relying on a distance-based screening criterion and provided a more detailed and complete assessment for each relevant designated site.

28 Highways Agency, 2007, Design Manual for Roads and Bridges, Volume 11 Environmental Assessment, Section 3 Environmental Assessment Techniques, Part 1 HA207/07 Air Quality, available online at http://www.standardsforhighways.co.uk/ha/standards/dmrb/vol11/section3/ha20707.pdf

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In-combination air pollution impacts have been evaluated only for European-designated sites located within a study domain that includes all of RBWM plus a 10 km buffer (Figure 2-3).

Figure 2-3 RBWM HRA study domain

2.4.2 Consideration of whether the qualifying features of the designated site are sensitive to air pollution impacts Consideration was given to whether the designated site contains qualifying features that are sensitive to the emissions associated with the planned development. For increased road traffic resulting from the proposed development, the associated emissions include nutrient nitrogen deposition, acid deposition, airborne oxides of nitrogen (NOx) and airborne ammonia (NH3). Site screening was carried out by searching for information on the UK Air Pollution Information System (APIS, www.apis.co.uk) and identifying potential sensitivity to air pollution impacts. At this stage, the spatial distribution of qualifying features within each designated site was not considered. If a potentially sensitive feature was identified at the designated site, as determined by APIS listing a critical load or critical level for at least one pollutant associated with road traffic at that site, it was included in the subsequent stages of the study. Otherwise, the site was screened out of requiring further assessment. The results of this analysis are summarised in Table 2-6. Consideration was also given to whether potential impacts on “functional linked land” should be considered: that is, a zone surrounding the designated site which plays a role in supporting the habitats and/or species for which each site was designated. In relation to the 2018 study, Natural England advised for the HRA Stage 1 Screening Assessment4 and Stage 2 Appropriate Assessment5 for the RBWM BLPSV-PC reports in 2018 that, in view of the nature of the specific designated sites under consideration in this study, and their qualifying features, there was no requirement to consider functionally linked land in an assessment of potential air quality impacts of the RBWM BLPSV-PC.

Table 2-6 European-designated sites: Assessment of sensitivity to emissions from road traffic

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Does the site contain Ramsar SPA SAC qualifying features that are Site name site code site code site code sensitive to emissions from road traffic?

Burnham Beeches (SAC) UK0030034 Yes – include in study

Chilterns Beechwoods (SAC) UK0012724 Yes – include in study

Thursley, Ash, Pirbright & UK0012793 Yes – include in study Chobham (SAC) Windsor Forest & Great Park UK0012586 Yes – include in study (SAC)

Thames Basin Heaths (SPA) UK9012141 Yes – include in study

South West London UK9012171 Yes – include in study Waterbodies (SPA)

South West London UK11065 Yes – include in study Waterbodies (Ramsar) 2.4.3 HRA Stage 1: Assessment of air quality impacts of the development against screening thresholds The next step was to use the dispersion modelling results to predict the air quality impacts associated with changes in traffic flow resulting from the BLPSV-PC. For each set of model results (nutrient nitrogen deposition, acid deposition, airborne NOx and airborne NH3), the contributions attributable to the BLPSV-PC development scenarios were calculated as follows: (Contribution of the BLPSV-PC Scenario B) = (BLPSV-PC Scenario B) – (RBWM Baseline) (Contribution of the BLPSV-PC Scenario C) = (BLPSV-PC Scenario C) – (RBWM Baseline) The contributions attributable to each of the future development scenarios were then compared to a screening threshold, where the screening threshold for each pollutant / habitat combination was set to 1% of the applicable long-term Critical Load or Critical Level. This approach is supported by online guidance published by Defra and the Environment Agency,29 a position statement published by the Institute of Air Quality Management (IAQM), 30 and recent guidance received from Natural England.31 According to the position statement published by the IAQM, the 1% threshold “was originally set at a level that was considered to be so low as to be unequivocally in the ‘inconsequential’ category. In other words, this can be reasonably taken to mean that an impact of this magnitude will have an insignificant effect. This would be determined as part of the HRA screening stage. Such a conclusion would eliminate the requirement to proceed to ‘appropriate assessment.’30 The position statement indicates that the 1% criterion is intended to be a threshold below which the impact should be considered insignificant and screened out; impacts above 1% do not necessarily correspond to the onset of damage to a designated site. Impacts above 1% should be treated as potentially significant and undergo further detailed assessment.

29 Department for Environment, Food and Rural Affairs and Environment Agency, “Air emissions risk assessment for your environmental permit”, February 2016.

30 Institute for Air Quality Management, “Position Statement: Effect of Air Quality Impacts on Sensitive Habitats,” January 2016

31 Email communication with Natural England, 12/01/2018.

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In view of this guidance, a threshold of a contribution of 1% of the applicable Critical Load or Critical Level was used to screen out any areas where the emerging BLPSV-PC, alone or in-combination, would have an insignificant impact on the relevant designated site. 2.4.3.1 Consideration of in-combination effects Recent guidance from Natural England, developed following the requirements of the Wealden Judgment, advise that the screening thresholds should be applied with consideration to impacts from individual proposed developments and with consideration to in-combination effects. In-combination effects were evaluated by reviewing published information in relation to potentially relevant development in the local area and wider region. Three sources of information were used for this evaluation: • Strategic plans for development in the local area were taken into account by considering local development plans published by neighbouring authorities, drawing in particular on published HRAs of the potential air quality impacts of these development plans. • Major developments in London and the South-East which could potentially affect air quality at the European sites under consideration were identified from the National Infrastructure Planning website. All live projects were identified which were: (a) located within 15 km of one or more of the relevant habitat sites, and (b) could potentially affect air quality at the habitat sites. These projects included both road and non-road strategic developments. Published information relevant to these developments provided via National Infrastructure Planning (for current and determined applications) or other publications (for forthcoming applications) was assessed. • The potential impacts of more general development within RBWM and the surrounding area were taken into account through the use of traffic forecasts which relied on the use of the Tempro model for forecasting future traffic growth over the period to 2033.3 2.4.4 HRA Stage 2: Appropriate assessment Where the screening analysis indicated that Likely Significant Effects (LSEs) on a designated site could not be ruled out, further analysis was undertaken in the form of an HRA Stage 2 Appropriate Assessment. 2.4.4.1 Consultation Consultation, via correspondence, was undertaken with Natural England during HRA Stage 2 to help determine which potential effects required more detailed, appropriate assessment provided by HRA Stage 2 and confirm the approaches for ruling out any LSEs are robust. 2.4.4.2 Impact assessment This assessment will consider the potentially damaging aspects of the proposed RBWM BLPSV-PC with potential effects on a European site’s qualifying features and likely achievement of the conservation objectives. The potential for adverse effect on the integrity of the site depends on the scale and magnitude of the predicted air pollution impacts, taking into account the distribution of the designated features across the site in relation to the predicted impact. The Stage 1 Screening sections of this report aim to set out the designated sites which require HRA Stage 2 Appropriate Assessment. The subsequent Stage 2 Appropriate Assessment sections will then set out, in sufficient detail for it to be transparent and understandable, what the effects of the proposed BLPSV-PC (alone and in-combination) are likely to be on each internationally-designated site’s qualifying feature. The report will refer to relevant background documents and other information on which these judgements, which are essentially ecological judgements, rely. Guidance states that the size or complexity of the HRA Stage 2 report to inform the Appropriate Assessment will not necessarily reflect the scale of the proposed BLPSV-PC, but rather the complexity of potential effects. The length of the report may not reflect the complexity of ecological judgements made to arrive at the necessary conclusions. Very complex ecological analysis and judgements may be expressed succinctly, with detailed supporting analyses contained in appendices or clearly referenced separate documents.

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2.4.4.3 Incorporated mitigation measures The HRA Stage 2 assessment of effects takes into account any mitigation measures that may already form part of the proposed BLPSV-PC specification (i.e. that are ‘incorporated’), to determine whether they will most likely reduce the likelihood, magnitude, scale, and/or duration of the effect to a lower level. These measures can include both avoidance and reduction measures, with the former being the preferred option. 2.4.4.4 Conservation objectives The Habitats Regulations require that the Appropriate Assessment is of “the implications for the site in view of that site’s conservation objectives.” The development of conservation objectives is required by the 1992 ‘Habitats’ Directive (92/43/EEC). The generic conservation objectives coving all the European sites assessed in this report are: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring: • The extent and distribution of qualifying natural habitats and habitats of qualifying species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and function of the habitats of qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Site-specific conservation objectives are summarised for each designated site in Section 4. 2.4.4.5 Additional mitigation measures Where the BLPSV-PC has been assessed as having a significant adverse effect by undermining the site’s conservation objectives, additional mitigation may be necessary to satisfy the integrity test (Section 2.4.4.6). Such mitigation is that which is in addition to the incorporated measures described in Section 2.4.4.3 above, and which is usually imposed by a Competent Authority through enforceable conditions or restrictions. 2.4.4.6 Integrity test The integrity test is the conclusion of the Appropriate Assessment and requires the competent authority to ascertain whether the proposed BLPSV-PC (either alone or in-combination with other plans or projects), will not have an adverse effect on site integrity. The following definition of site integrity is provided by Defra. The integrity of the site is: “the coherence of its ecological structure and function, across its whole area, that enables it to sustain the habitat, complex of habitats and/or the level of populations of the species for which it was classified” This report will conclude with a professional opinion on whether such a test can be met, but it is for the Competent Authority to make that decision in light of the information presented.

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3 Assessment of air quality related to human health

This section describes the impact of the RBWM BLPSV-PC development options on air quality related to human health.

This section does not form part of the Habitats Regulations Assessment. 3.1 Overview of air quality standards for human health Table 3-1 summarises the air quality objectives relevant in this study. For Local Air Quality Management (LAQM) purposes, and for the assessment of air quality against the Air Quality Objectives (AQOs), personal exposure is also important. Therefore, predicted concentrations greater than the values listed in Table 3-1 at a given location do not necessarily indicate an exceedance of the AQO. Rather, the predicted concentrations should be considered in the context of personal exposure, with consideration given to the types of locations where the AQOs should apply (Table 3-2). A total of five Air Quality Management Areas (AQMAs) have been declared in Windsor and Maidenhead, all of which were declared on the basis of exceedance of the annual mean objective for nitrogen dioxide. Therefore, this report assesses air quality against annual mean AQOs.

Table 3-1 Annual Air Quality Objectives in England

Pollutant Air Quality Objective Measured as Nitrogen dioxide 40 µg/m3 Annual mean

3 Particulate Matter (PM10) 40 µg/m Annual mean Particulate Matter (PM ); to be achieved by 2020 and 2.5 25 µg/m3 Annual mean maintained thereafter

Table 3-2 Examples of where the Air Quality Objectives should apply32 Averaging Objectives should apply at: Objectives should generally not apply at: Period Building façades of offices or other places of work where members of the public do not have regular access. All locations where members of the public Hotels, unless people live there as their Annual might be regularly exposed. Building façades permanent residence. mean of residential properties, schools, hospitals, care homes etc. Gardens of residential properties. Kerbside sites (as opposed to locations at the building façade), or any other location where public exposure is expected to be short term.

There are no current legal obligations on local authorities in relation to compliance with the PM2.5 AQO. However, local authorities are expected to make efforts to reduce emissions and/or concentrations of the pollutant through the application of measures, as described in their Annual Status Report (ASR). 3.2 Air Quality Management Areas (AQMAs) within the Royal Borough of Windsor and Maidenhead Each local authority in England has a responsibility under the Environment Act 1995 to assess and monitor, as required, nitrogen dioxide concentrations within its council area. If nitrogen dioxide (NO2) concentrations either exceed the annual objective concentration of 40 µg/m3 or there are more than 18 exceedances of the 1-hour objective of 200 µg/m3 in a year, the local authority is required to declare an

32 Department for Environment Food and Rural Affairs, “Local Air Quality Management: Technical Guidance (TG16)”, February 2018.

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AQMA and develop an Air Quality Action Plan to prevent further exceedances. Similarly, local authorities are also required to declare an AQMA and develop an Air Quality Action Plan if PM10 concentrations exceed the objectives set out in Table 3-1. As of June 2019, a total of five AQMAs have been declared in Windsor and Maidenhead. These are listed in Table 3-3 and displayed in Figure 3-1. All five were declared on the basis of exceedance of the annual mean objective for nitrogen dioxide.

Table 3-3 Location of Air Quality Management Areas within Windsor and Maidenhead (as of June 2019) Local AQMA Area, Title Description Authority ref Hectares Imperial Road/ An area encompassing the junction of Imperial Road 1565 St Leonards 3.5 and Leonards Road Road Junction An enlarged area encompassing parts of west Royal 277 Windsor AQMA 58.6 Borough of Windsor Windsor and Maidenhead 276 An enlarged area encompassing the town centre. 145.2 Maidenhead AQMA An area encompassing part of Bray around the 613 Bray/M4 AQMA place where the M4 crosses over the A308 Windsor 25.5 Road The area runs along the B376 and intersects with 1567 Wraysbury/M25 3.6 the M25 near junction 13

Figure 3-1 Location of Air Quality Management Areas (AQMAs) within Windsor and Maidenhead

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3.3 Modelled receptor points In order to investigate the impact of different model scenarios on AQMAs and neighbouring local authorities, model results from the 3 m x 3 m grid were extracted at known air quality monitoring locations within the borough. The locations of these are shown in Figure 3-2. It is considered that these monitoring site locations are representative of key receptor locations across the borough.

Figure 3-2 Air quality monitoring locations within Windsor and Maidenhead

3.4 Model results

An assessment of NO2, PM10 and PM2.5 concentrations was performed across the entire RBWM including areas that are not assigned as AQMAs. For both Scenario B and Scenario C there were no concentrations above or within 10% of the AQO observed at locations where AQOs should apply (Table 3-4). Maps demonstrating the modelled pollutant levels across the Borough for Scenario B and Scenario C are provided in Figure 3-3 to Figure 3-8. Table 3-4 summarises 2033 modelled concentrations for each scenario in µg/m3. Table 3-5 expresses the difference in air pollution concentration between the 2033 Scenario B and 2033 Baseline (BL) scenarios, and the 2033 Scenario C and 2033BL scenarios, as a % of the air quality standard of 40 µg/m3. Negative values indicate that the pollutant concentration in Scenario B or Scenario C is lower than in the 2033 BL scenario, and therefore correspond to an improvement in air quality. The most significant changes in concentration at receptor points are observed in the Maidenhead and Bray/M4 AQMAs, with differences greater than 1% of the air quality standard of 40µg/m3 between

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Scenario B or Scenario C, and the 2033 BL scenario. Maps displaying the difference between modelled 3 annual mean NO2 concentrations in µg/m in each AQMA are provided in Figure 3-9 to Figure 3-38.

3 Figure 3-3 Scenario B total modelled NO2 concentrations (µg/m )

3 Figure 3-4 Scenario C total modelled NO2 concentrations (µg/m )

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3 Figure 3-5 Scenario B total modelled PM10 concentrations (µg/m )

3 Figure 3-6 Scenario C total modelled PM10 concentrations (µg/m )

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3 Figure 3-7 Scenario B total modelled PM2.5 concentrations (µg/m )

3 Figure 3-8 Scenario C total modelled PM2.5 concentrations (µg/m )

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3 Table 3-4 Summary of model results for annual mean NO2, PM10 and PM2.5 concentrations in µg/m (road contribution + background concentration) for the 2033 BL, Scenario B and Scenario C Modelled annual mean concentrations (µg/m3) Modelled NO PM PM receptor AQMA 2 10 2.5 Scenario Scenario Scenario Scenario Scenario Scenario points 2033 BL 2033 BL 2033 BL B C B C B C Air quality standard 40 40 25 MW1 Maidenhead 19.5 19.5 20.2 16.8 17.0 17.1 11.3 11.5 11.5 MW2 Windsor 21.9 21.9 22.0 19.1 19.2 19.2 12.9 13.0 13.0 MW4 N/A 13.9 13.9 14.0 15.1 15.1 15.1 10.3 10.3 10.4 WM1 N/A 12.9 12.9 12.9 14.2 14.2 14.2 10.0 10.0 10.0 WM2 Bray/M4 17.6 17.6 17.9 17.3 17.4 17.5 11.4 11.5 11.6 WM5 Maidenhead 18.1 18.1 18.8 16.0 16.3 16.3 10.8 11.0 11.0 WM5a Maidenhead 18.0 18.0 18.9 15.8 16.1 16.2 10.7 10.9 11.0 WM8 N/A 13.9 13.9 14.0 14.9 14.9 14.9 10.3 10.3 10.3 WM9 N/A 16.0 16.0 16.0 15.5 15.6 15.5 10.8 10.8 10.8 WM10 Windsor 19.2 19.2 19.1 17.7 17.7 17.6 12.1 12.1 12.1 WM13 Wraysbury/M25 20.6 20.6 20.7 19.0 19.0 19.0 12.6 12.6 12.6 WM13a Wraysbury/M25 23.3 23.3 23.3 20.0 20.0 20.0 13.3 13.3 13.3 WM15 Wraysbury/M25 26.4 26.4 26.5 21.3 21.4 21.3 14.1 14.2 14.2 WM15a Wraysbury/M25 26.2 26.2 26.2 21.0 21.1 21.1 14.0 14.0 14.0 WM15b Wraysbury/M25 24.7 24.7 24.8 20.7 20.7 20.7 13.8 13.8 13.8 WM18 Windsor 21.9 21.9 22.0 19.1 19.2 19.2 12.9 13.0 13.0 WM19 Windsor 21.9 21.9 22.0 19.1 19.2 19.2 12.9 13.0 13.0 WM20 Windsor 21.9 21.9 22.0 19.1 19.2 19.2 12.9 13.0 13.0

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Modelled annual mean concentrations (µg/m3) Modelled NO PM PM receptor AQMA 2 10 2.5 Scenario Scenario Scenario Scenario Scenario Scenario points 2033 BL 2033 BL 2033 BL B C B C B C Air quality standard 40 40 25 WM21 Maidenhead 19.5 19.5 20.2 16.8 17.0 17.1 11.3 11.5 11.5 WM22 Maidenhead 19.5 19.5 20.2 16.8 17.0 17.1 11.3 11.5 11.5 WM23 Maidenhead 19.5 19.5 20.2 16.8 17.0 17.1 11.3 11.5 11.5 WM28 N/A 18.3 18.3 18.7 16.0 16.0 16.1 10.9 10.9 10.9 WM28a N/A 17.1 17.1 17.4 15.4 15.4 15.5 10.5 10.5 10.6 WM29 Bray/M4 21.8 21.8 22.7 19.3 19.5 19.9 12.6 12.8 13.0 WM29a Bray/M4 19.9 19.9 20.7 18.6 18.8 19.2 12.2 12.3 12.6 WM29b Bray/M4 22.6 22.6 23.3 19.4 19.6 19.9 12.7 12.8 13.0 WM29e Bray/M4 19.0 19.0 19.5 18.0 18.1 18.4 11.9 11.9 12.1 WM30a N/A 15.0 15.0 14.8 15.3 15.3 15.2 10.4 10.5 10.4 WM31 Windsor 16.9 16.9 17.0 15.8 15.9 15.8 10.9 11.0 10.9 WM32 Windsor 16.4 16.4 16.4 15.4 15.4 15.4 10.7 10.7 10.7 WM33 Windsor 16.4 16.4 16.4 15.4 15.4 15.4 10.7 10.7 10.7 WM01 N/A 14.6 14.6 14.6 15.2 15.2 15.2 10.4 10.4 10.4 Imperial/St WM03 16.9 16.9 16.9 16.7 16.7 16.6 11.3 11.3 11.3 Leonards Road Imperial/St WM03a 16.9 16.9 16.8 16.7 16.7 16.7 11.3 11.3 11.3 Leonards Road Imperial/St WM03b 16.7 16.7 16.7 16.6 16.6 16.5 11.2 11.2 11.2 Leonards Road Imperial/St WM03d 14.4 14.4 14.4 15.3 15.3 15.3 10.4 10.5 10.4 Leonards Road WM04 N/A 14.3 14.3 14.4 14.9 15.0 15.0 10.3 10.3 10.3

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Table 3-5 Summary of model results for annual mean NO2, PM10 and PM2.5 concentrations (road contribution + background concentration): Average change in concentration (as % of applicable annual mean AQO) between the 2033 BL, Scenario B and Scenario C Change in annual mean concentration compared to 2033 BL for 2033 (as a % of air quality standard) Modelled receptor AQMA NO2 PM10 PM2.5 points Scenario B Scenario C Scenario B Scenario C Scenario B Scenario C MW1 Maidenhead 1.22 1.92 0.53 0.81 1.45 0.87 MW2 Windsor 0.43 0.32 0.25 0.11 0.42 0.17 MW4 N/A 0.14 0.18 0.05 0.08 0.20 0.10 WM1 N/A 0.09 0.03 0.06 0.01 0.15 0.01 WM2 Bray/M4 0.38 0.75 0.23 0.55 0.59 0.54 WM5 Maidenhead 1.51 1.75 0.70 0.84 1.78 0.89 WM5a Maidenhead 1.55 2.13 0.67 0.95 1.80 1.03 WM8 N/A 0.31 0.35 0.18 0.20 0.41 0.18 WM9 N/A 0.03 0.02 0.02 0.00 0.02 0.01 WM10 Windsor 0.06 -0.26 0.09 -0.11 0.14 -0.09 WM13 Wraysbury/M25 0.13 0.08 0.04 0.04 0.08 0.04 WM13a Wraysbury/M25 0.26 0.14 0.09 0.07 0.17 0.07 WM15 Wraysbury/M25 0.42 0.15 0.18 0.09 0.30 0.09

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Change in annual mean concentration compared to 2033 BL for 2033 (as a % of air quality standard) Modelled receptor AQMA NO2 PM10 PM2.5 points Scenario B Scenario C Scenario B Scenario C Scenario B Scenario C WM15a Wraysbury/M25 0.45 0.16 0.19 0.09 0.32 0.09 WM15b Wraysbury/M25 0.28 0.12 0.12 0.07 0.19 0.07 WM18 Windsor 0.43 0.32 0.25 0.11 0.42 0.17 WM19 Windsor 0.43 0.32 0.25 0.11 0.42 0.17 WM20 Windsor 0.43 0.32 0.25 0.11 0.42 0.17 WM21 Maidenhead 1.22 1.92 0.53 0.81 1.52 0.87 WM22 Maidenhead 1.22 1.92 0.53 0.81 1.52 0.87 WM23 Maidenhead 1.22 1.92 0.53 0.81 1.52 0.87 WM28 N/A 0.30 0.91 0.16 0.32 0.29 0.29 WM28a N/A 0.25 0.64 0.13 0.24 0.24 0.21 WM29 Bray/M4 0.36 2.36 0.48 1.58 1.07 1.49 WM29a Bray/M4 0.65 2.01 0.31 1.36 0.83 1.29 WM29b Bray/M4 -0.19 1.72 0.53 1.11 0.99 1.04 WM29e Bray/M4 0.41 1.18 0.27 0.83 0.65 0.80 WM30a N/A 0.16 -0.50 0.08 -0.23 0.19 -0.21 WM31 Windsor 0.32 0.12 0.15 0.05 0.37 0.08 WM32 Windsor 0.23 0.17 0.12 0.08 0.29 0.10 WM33 Windsor 0.24 0.07 0.12 0.04 0.31 0.06 WM01 N/A 0.04 0.03 0.01 0.01 0.04 0.02 WM03 Imperial/St Leonards Road 0.11 -0.15 0.10 -0.06 0.19 -0.05 WM03a Imperial/St Leonards Road 0.10 -0.16 0.09 -0.07 0.18 -0.05 WM03b Imperial/St Leonards Road 0.12 -0.10 0.10 -0.04 0.20 -0.03 WM03d Imperial/St Leonards Road 0.09 -0.05 0.06 -0.02 0.14 -0.01 WM04 N/A 0.16 0.31 0.09 0.14 0.22 0.18 WM04a N/A 0.14 0.27 0.07 0.12 0.17 0.15

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Change in annual mean concentration compared to 2033 BL for 2033 (as a % of air quality standard) Modelled receptor AQMA NO2 PM10 PM2.5 points Scenario B Scenario C Scenario B Scenario C Scenario B Scenario C WM012 N/A 0.11 0.23 -0.01 0.07 0.16 0.13 WM013 Maidenhead 0.73 0.59 0.44 0.31 0.97 0.33 WM013a Maidenhead 0.83 0.14 0.52 -0.03 1.12 0.05 WM014a Maidenhead 1.27 0.85 0.55 0.27 1.36 0.43

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Figure 3-9 Maidenhead AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

Figure 3-10 Maidenhead AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

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Figure 3-11 Maidenhead AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

Figure 3-12 Maidenhead AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

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Figure 3-13 Maidenhead AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

Figure 3-14 Maidenhead AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

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Figure 3-15 Bray/M4 AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

Figure 3-16 Bray/M4 AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

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Figure 3-17 Bray/M4 AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

Figure 3-18 Bray/M4 AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

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Figure 3-19 Bray/M4 AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

Figure 3-20 Bray/M4 AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

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Figure 3-21 Windsor AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

Figure 3-22 Windsor AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

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Figure 3-23 Windsor AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

Figure 3-24 Windsor AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

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Figure 3-25 Windsor AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

Figure 3-26 Windsor AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

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Figure 3-27 Imperial Road AQMA – difference between Scenario B and 2033 Baseline scenario total 3 modelled annual mean NO2 concentration for (µg/m )

Figure 3-28 Imperial Road AQMA – difference between Scenario C and 2033 Baseline scenario total 3 modelled annual mean NO2 concentration (µg/m )

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Figure 3-29 Imperial Road AQMA – difference between Scenario B and 2033 Baseline scenario total 3 modelled annual mean PM10 concentration (µg/m )

Figure 3-30 Imperial Road AQMA – difference between Scenario C and 2033 Baseline scenario total 3 modelled annual mean PM10 concentration (µg/m )

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Figure 3-31 Imperial Road AQMA – difference between Scenario B and 2033 Baseline scenario total 3 modelled annual mean PM2.5 concentration (µg/m )

Figure 3-32 Imperial Road AQMA – difference between Scenario C and 2033 Baseline scenario total 3 modelled annual mean PM2.5 concentration (µg/m )

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Figure 3-33 Wraysbury AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

Figure 3-34 Wraysbury AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean NO2 concentration (µg/m )

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Figure 3-35 Wraysbury AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

Figure 3-36 Wraysbury AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM10 concentration (µg/m )

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Figure 3-37 Wraysbury AQMA – difference between Scenario B and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

Figure 3-38 Wraysbury AQMA – difference between Scenario C and 2033 Baseline scenario total modelled 3 annual mean PM2.5 concentration (µg/m )

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3.5 Summary of model results

An assessment of NO2, PM10 and PM2.5 concentrations was performed across the entire RBWM including areas that are not assigned as AQMAs. Table 3-4 demonstrates that for all future scenarios (2033 Baseline2033 Scenario B and 2033 Scenario C) there were no concentrations above or within 10% of the relevant AQOs observed at locations relevant for human exposure. This is supported by maps showing the modelled pollutant levels across the Borough for Scenario B and Scenario C. Table 3-5 expresses the difference in air pollution concentration between the 2033 Scenario B and 2033 Baseline (BL) scenarios, and the 2033 Scenario C and 2033BL scenarios, as a % of the air quality 3 3 standard of 40 µg/m for NO2 and PM10, and 25 µg/m for PM2.5. The most significant changes in concentration at receptor points are observed in the Maidenhead and Bray/M4 AQMAs, with differences greater than 1% of the air quality standards between Scenario B or Scenario C and the 2033 BL scenario:

• For NO2, seven differences greater than +1% were seen for Scenario B – all of them at monitoring locations within the Maidenhead AQMA. Six differences greater than +1% were seen for Scenario C – again, all of them at monitoring locations within the Maidenhead AQMA.

• For PM10, no differences greater than +1% were seen for Scenario B. Three differences greater than +1% were seen for Scenario C; these were all at monitoring locations within the Bray/M4 AQMA.

• For PM2.5, nine differences greater than +1% were seen for Scenario B – eight of them at monitoring locations within the Maidenhead AQMA and one in the Bray/M4 AQMA. Four differences greater than +1% were seen for Scenario C – however, only one was at a monitoring location within the Maidenhead AQMA and the other three were within the Bray/M4 AQMA. Negative values indicate that the pollutant concentration in Scenario B or Scenario C is lower than in the 2033 BL scenario, and therefore correspond to an improvement in air quality. Negative values were seen in various monitoring locations for each pollutant:

• For NO2, one air quality improvement was seen in the Bray AQMA for Scenario B. One improvement was seen in the Windsor AQMA for Scenario C, as well as four improvements within the Imperial/St Leonards Road AQMA and one improvement outside any AQMA. Note that these improvements were small, the largest (within an AQMA) being a change of -0.26%.

• For PM10, again one improvement was seen for Scenario B; however, this was a change of only -0.01%. For Scenario C, seven improvements were seen: four in the Imperial/St Leonards Road AQMA, one in the Windsor AQMA, one in the Maidenhead AQMA and one not located in any AQMA. The negative changes within the Imperial/St Leonards Road AQMA were the smallest, ranging from -0.02% to -0.07%. The largest negative change was -0.23% at WM30a (not inside any AQMA).

• For PM2.5, no negative changes were seen under Scenario B. Six improvements in air quality were seen for Scenario C; again, four were within the Imperial/St Leonards Road AQMA ranging from -0.01% to -0.05%. The largest negative change was again at WM30a (-0.21%).

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4 Assessment of air quality impacts on designated sites

In the following section, the dispersion modelling results have been used to predict the air quality impacts associated with changes in traffic flow resulting from the RBWM BLPSV-PC. For each set of model results (nutrient nitrogen deposition, acid deposition, airborne NOx and airborne NH3), the contributions attributable to the BLPSV-PC development scenarios were calculated. These scenarios are as follows: • Scenario B: This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development but assumes there will be no further improvements to the transport network, aside from those which are already committed and therefore already included in the 2033 Baseline scenario. Development growth outside RBWM is identical to that included in the 2033 Baseline scenario.

• Scenario C: This model represents a scenario which includes the RBWM BLPSV-PC housing and employment development as well as includes transport interventions that may be required to mitigate the impact of the RBWM “Borough Local Plan Submission Version – Proposed Changes” on highways and road junctions. It does not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. Development growth outside RBWM is identical to that included in the 2033 Baseline scenario. For the Stage 1 assessment, the contributions attributable to the development scenarios were then compared to a screening threshold, where the screening threshold for each pollutant / habitat combination was set to 1% of the applicable Critical Load or Critical Level. A threshold of a contribution of 1% of the applicable Critical Load or Critical Level was used to screen out any areas where the emerging BLPSV-PC, alone or in-combination, would have an insignificant impact on the relevant designated site.

The numerical data in Section 4 refers to the impact of the RBWM BLPSV-PC in isolation. We have also considered whether other plans or projects have the potential to result in a potentially significant in-combination impact at any European site, focusing mainly on the development plans of other neighbouring local authorities.

Impacts on Natura 2000 sites resulting from Scenario C only are relevant to assess the impacts of the BLPSV-PC against the habitats regulations.

This is because the transport mitigation schemes included in Scenario C are required to mitigate the traffic impact of the RBWM BLPSV-PC on highways and road junctions. Scenario C does not include any mitigation measures which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. The measures included in Scenario C are all required to ensure that the BLPSV-PC is acceptable in traffic terms.

4.1 Burnham Beeches SAC (UK0030034) 4.1.1 Background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Burnham Beeches SSSI Annex I habitats that are a primary reason for selection of this site: • 9120 Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrub layer (Quercion robori-petraeae or Ilici-Fagenion).

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The Site Improvement Plan (SIP) states that nitrogen deposition has been identified as a threat to the qualifying feature habitats of this SAC.33 Epiphytic lichen communities are sensitive to nutrient deposition, promoting the growth of nutrient-tolerant species and reducing overall lichen diversity. The SIP identifies that improvements have been achieved in terms of SO2 and particulate deposition in the area but NO2 and ammonia deposition levels remain high. The SIP also identifies that nitrogen deposition may be affecting tree health, resulting in changes in tree canopy structure and other effects.33 4.1.2 HRA Stage 1: Assessment of air quality impacts against screening thresholds This section comprises the outcome of the screening assessment described in Section 2.4.3. Table 4-1 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this designated site/designated feature habitat. The critical level for airborne NOx is set at 30 µg/m3 across all designated sites.

Table 4-1 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for Burnham Beeches SAC Minimum acid Minimum nutrient deposition CLs Minimum airborne Sensitive feature nitrogen deposition 3 (MinCLMaxN, NH3 CLs (µg/m ) CLs (kgN/ha-year) kEq/ha-year) 9120 Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrub layer 10 2.561 1 (Quercion robori-petraeae or Ilici- Fagenion) 4.1.2.1 Consideration of in-combination effects HRA reports that identified potential impacts to Burnham Beeches were identified for the following neighbouring authorities: • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 identified no likely significant effects to Burnham Beeches SAC. The site is over 10km from Bracknell Forest Borough and was screened out of the assessment. • London Borough of Hillingdon. An HRA screening assessment of the Council’s Core Strategy published in 2014 found that Burnham Beeches SAC was “not considered to be sensitive to the Air Quality impacts of the Core Strategy due to prevailing wind direction and the distance from the borough.” • Reading Borough Council. An HRA Screening of the Local Plan Options undertaken in as part of a Sustainability Appraisal 2016 found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Local Plan. Burnham Beeches was not included in the HRA screening as it was not within the study area. • Runnymede Borough Council. An HRA of the updated Local Plan was published in December 2019. The findings of this HRA were taken into account in the present assessment of in- combination effects. • Rushmoor Borough Council. An HRA of the updated Local Plan was published in June 2017. The findings of this HRA were taken into account in the present assessment of in-combination effects. • The Slough Borough Council (SBC) Local Plan is scheduled for preferred option consultation in February 2020. The plan is not formally published or submitted for final consultation, examination or adoption and is therefore not relevant to the in-combination assessment. • South Buckinghamshire Borough Council: An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 identified likely significant effects to Burnham

33 Natural England (2014) Site Improvement Plan Burnham Beeches SAC. Improvement Programme for England's Natura 2000 Sites (IPENS). Available at http://publications.naturalengland.org.uk/publication/5689860228644864. Accessed on 19 November 2019

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Beeches SAC Relating to air quality. The HRA report indicated that nitrogen deposition as a result of the Chiltern and South Buckinghamshire Local Plan exceeds the 1% criteria within an area along Stewards Drive and Bedford Drive on the eastern edge of the Burnham Beeches SAC. In addition, it was identified that Total nitrogen deposition rates were predicted to exceed the Critical Load of 10kgN/ha-yr throughout the SAC34. • Surrey Heath Borough Council. An HRA report for Draft Local Plan to 2032 Issues and Options Consultation 2018 screened out impacts on Burnham Beeches SAC. No air quality modelling was undertaken as part of the May 2018 HRA for Surrey Heath BLPSV-PC but was scheduled to be included in a revised HRA. • Wokingham Borough Council. An HRA scoping document published in August 2016 did not identify the potential for significant air quality impacts at the SAC. • Wycombe District Council. A screening assessment published in September 2017 highlighted potential impacts on Burnham Beeches SAC. Wycombe DC was “considered to be at too great a distance to significantly affect traffic flows on the A355 and consequent pollution impacts on Burnham Beeches SAC”. • Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue. Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified: • Heathrow airport development. Information was taken from the “Revised Draft Airports National Policy Statement – Habitats Regulations Assessment Statement to inform Appropriate Assessment “(October 2017). Due to potential increases in traffic on motorways and main roads associated with potential future development at Heathrow Airport, in-combination impacts may need to be considered in the future. However, no information on potential impacts at European sites due to this development is available at this time. On this basis, it is concluded that this proposed development is not relevant to the in-combination assessment. • North London Heat and Power Project. This comprises an upgrade to a major waste to energy facility in North London and was included even though it lies outside the 15 km screening distance, as an indicator of the potential impacts of energy development. Potential impacts were identified and assessed at three European sites: Lee Valley SPA and Ramsar, and Epping Forest SAC. The risk of significant impacts at these sites was ruled out. In view of the much greater distance to Natura 2000 sites in and near RBWM and similar site sensitivity, no significant impacts would be forecast to occur at Natura 2000 sites in and near RBWM. While the plans and projects noted above could potentially have an in-combination effect on Burnham Beeches SAC, it was found that the risk of any in-combination impacts could be ruled out because of the forecast absence of any impact due to the RBWM BLPSV-PC (see Section 4.1.2.3 below). 4.1.2.2 Screening results Table 4-2 and Table 4-3 compare the maximum modelled contribution of Scenario B and Scenario C, respectively, to the lowest applicable CL. This screening exercise represents a precautionary approach, as it assumes that the most sensitive qualifying features (with the lowest CLs) are present in the areas with the highest modelled contribution (typically adjacent to the busiest road). The screening results indicate that air quality impacts for all pollutants associated with the BLPSV-PC, in isolation, are well below the 1% screening threshold, with maximum modelled values representing no more than 0.15% of the CL. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Burnham Beeches SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for nitrogen deposition, acid deposition, NH3 and NOx as causal pollutants arising from increased road emissions associated with the BLPSV-

34 Lepus Consulting (2019) Report to inform the Habitats Regulations Assessment of the Chiltern and South Bucks Local Plan. LC-476_Report to Inform HRA_16_060619SC.docx

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PC (either alone or in combination, based on information currently available on in-combination effects). No further HRA stages are required for air quality impacts.

Table 4-2 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Forest 10 0.0145 0.15% (kgN/ha-year) ͣ Grassland 10 0.00907 0.09% Acid deposition (kEq/ha- Forest 2.561 0.00104 0.04% year) ͣ Grassland 2.561 0.000631 0.03% Airborne NOx (µg/m3) N/A 30 0.0262 0.09% 3 Airborne NH3 (µg/m ) N/A 1 0.00139 0.14%

ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. Table 4-3 Screening results based on dispersion modelling of Scenario C Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Forest 10 -0.000293 -0.003% (kgN/ha-year) ͣ Grassland 10 -0.000168 -0.002% Acid deposition (kEq/ha- Forest 2.561 -0.0000209 -0.0008% year) ͣ Grassland 2.561 -0.0000120 -0.0005% Airborne NOx (µg/m3) N/A 30 -0.00101 -0.003% 3 Airborne NH3 (µg/m ) N/A 1 -0.0000162 -0.002%

ͣ This site is characterised by some habitats with tall vegetation; therefore forest deposition rates were used as a precautionary approach. 4.1.2.3 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. The results from HRA Stage 1 indicate that air quality impacts for all pollutants associated with the BLPSV-PC, in isolation, are well below the 1% screening threshold. For Scenario C, small improvements in air quality are predicted for all pollutants assessed. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Burnham Beeches SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for nitrogen deposition, acid deposition, NH3 and NOx as causal pollutants arising from increased road emissions associated with the BLPSV-PC (either alone or in combination, based on information currently available on in-combination effects). Natural England have confirmed that as all contributions are less than 1%, likely significant effects can be screened out for all pollutants in isolation. As the BLPSV-PC is forecast to result in a slight improvement in air quality at this site, it is concluded that there is no significant risk of any adverse in- combination impact with other plans or projects.

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4.2 Chilterns Beechwoods SAC (UK0012724) 4.2.1 SAC background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Ashridge Commons and Woods SSSI; Aston Rowant Woods SSSI; Bisham Woods SSSI; Bradenham Woods, Park Wood & The Coppice SSSI; Ellesborough and Kimble Warrens SSSI; Hollowhill and Pullingshill Woods SSSI; Naphill Common SSSI; Tring Woodlands SSSI; Windsor Hill SSSI. Qualifying and notifiable features associated with this site include: • H6210 Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco- Brometalia), (note that this includes the priority feature "important orchid rich sites") • H9130 Asperulo-Fagetum beech forests • S1083 Stag beetle, (Lucanus cervus) The Site Improvement Plan (SIP) states that nitrogen deposition has been identified as a threat to the qualifying features of this SAC.35 The SIP states that atmospheric nitrogen deposition exceeds the critical loads for ecosystem protection and that some parts of the site are recorded as unfavourable (recovering), but impacts associated with nitrogen deposition are unclear. 4.2.2 HRA Stage 1: Assessment of air quality impacts against screening thresholds This section comprises the outcome of the assessment described in Section 2.4.3. Table 4-4 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this designated site. In this table, the most stringent critical load or critical level (CL) for each pollutant is indicated in bold. The critical level for airborne NOx is set at 30 µg/m3 across all designated sites.

Table 4-4 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for Chiltern Beechwoods SAC Minimum Minimum acid Minimum nutrient nitrogen deposition CLs Sensitive feature airborne NH3 deposition CLs (MinCLMaxN, kEq/ha- CLs (µg/m3) (kgN/ha-year) year) H6210 Semi-natural dry grasslands and scrubland facies: on calcareous 15 - 25 4.856 1 substrates (Festuco-Brometalia)36 H9130 Asperulo-Fagetum beech forests 10 - 20 1.647 1 4.2.2.1 Consideration of in-combination effects • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 screened out impacts from the BLPSV-PC on the Chilterns Beechwoods SAC. • London Borough of Hillingdon. A screening assessment of the Council’s Core Strategy published in 2014 screened out impacts on Chilterns Beechwoods SAC. • Reading Borough Council. An HRA screening of the Local plan in 2016 found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Sites and Detailed Policies Document. The Habitat Regulations assessment was included as an appendix to the Local Plan Sustainability Appraisal Adoption Statement and identified potential

35 Natural England (2015) Site Improvement Plan Chiltern Beechwoods SAC. Improvement Programme for England's Natura 2000 Sites (IPENS). Available at http://publications.naturalengland.org.uk/file/5908864568393728. Accessed on 19 November 2019

36 note that this includes the priority feature "important orchid rich sites"

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significant effects on Chiltern Beechwoods, “in terms of noise, disturbance and vibration as well as air pollution and quality". • Runnymede Borough Council. An HRA of the updated Local Plan was published in May 2018, with a supplementary assessment of modifications published in December 2019. The risk of impacts at Chilterns Beechwoods SAC due to the updated Runnymede Local Plan was ruled out because “the next nearest European sites are 12km from the borough boundary and do not lie on any routes that are likely to constitute significant journey to work routes for residents of the borough.” • Rushmoor Borough Council. An HRA of the updated Local Plan was published in June 2017. The risk of impacts at Chilterns Beechwoods SAC due to the updated Rushmoor Local Plan was ruled out because of the distance between Rushmoor borough and this site. • Slough Borough Council (SBC). Not relevant to this assessment (see Section 4.1.2.1) • South Buckinghamshire Borough Council. An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 screened out impacts to the Chilterns Beechwoods SAC. • Surrey Heath Borough Council. Chiltern Beechwoods was not included as part of the HRA for Draft Local Plan to 2032 Issues and Options Consultation 2018 due to the distance to Surrey Heath Borough. • Wokingham Borough Council. A scoping document published in August 2016 did not identify the potential for significant air quality impacts at the SAC. • Wycombe District Council. A screening assessment published in September 2017 highlighted potential impacts on Chilterns Beechwoods SAC. The risk of potential impacts on Chilterns Beechwoods SAC was screened out on the basis that traffic increases on the adjacent A404 would be less than 1000 vehicles per day: however, this would not enable the risk of in- combination impacts to be screened out. • Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified: • Western Rail Link to Heathrow. The Initial Environmental Information Report (February 2016) indicates that there may be overall air quality benefits from implementation of the Rail Link. The rail link itself is located well away from the Natura 2000 sites under consideration, and consequently there are not likely to be any significant impacts from local traffic movements to and from Langley station. If anything, the rail link is likely to result in reductions in traffic movements on the key road links to and from Heathrow Airport, such as the M4 and M3. In view of this evaluation, it was concluded that there were no plans or projects which could potentially pose a risk of in-combination impacts with the RBWM BLPSV-PC at Chilterns Beechwoods SAC. 4.2.2.2 Screening results Table 4-5 and Table 4-6 compare the maximum modelled contribution of Scenario B and Scenario C, respectively, to the lowest applicable CL. Values highlighted in yellow exceed the 1% screening threshold. This screening exercise represents a precautionary approach, as it assumes that the most sensitive qualifying features (with the lowest CLs) are present in the areas with the highest modelled contribution (typically adjacent to the busiest road). The screening results indicate that air quality impacts for acid deposition associated with the BLPSV- PC, in isolation, are below the 1% screening threshold in both scenarios, with maximum modelled values up to 0.64% of the CL. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Chilterns Beechwoods SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for acid deposition as a causal pollutant arising from increased road emissions associated with the BLPSV-PC in isolation.

Nitrogen deposition, airborne NOx and NH3 are predicted to exceed the 1% screening threshold for Scenario B and Scenario C, in isolation. Therefore, likely significant effects from air quality impacts

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Table 4-5 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Forest 10 0.138 1.38% (kgN/ha-year) ͣ Grassland 10 0.0781 0.78% Acid deposition (kEq/ha- Forest 1.647 0.00986 0.60% year) ͣ Grassland 1.647 0.00556 0.34% Airborne NOx (µg/m3) N/A 30 0.677 2.26% 3 Airborne NH3 (µg/m ) N/A 1 0.0109 1.09% ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. Table 4-6 Screening results based on dispersion modelling of Scenario C Maximum Maximum distance of Minimum Pollutant Deposition type modelled % of CL exceedance CL contribution from roadside / m Nutrient nitrogen Forest 10 0.148 1.48% 27 deposition (kgN/ha-year) ͣ Grassland 10 0.0895 0.90% NA Acid deposition (kEq/ha- Forest 1.647 0.0106 0.64% NA year) ͣ Grassland 1.647 0.00638 0.39% NA Airborne NOx (µg/m3) N/A 30 0.465 1.55% 44 3 Airborne NH3 (µg/m ) N/A 1 0.0118 1.18% 12 ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. 4.2.3 HRA Stage 2: Appropriate assessment 4.2.3.1 Airborne NOx The relevant CL for Chilterns Beechwoods SAC is 30 µg/m3 for all vegetation. Figure 4-1 illustrates the areas where the modelled contribution from the BLPSV-PC is predicted to exceed 0.3 µg/m3 (1% of 30 µg/m3).

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Figure 4-1 Overview of screening results for oxides of nitrogen (NOx) within Chilterns Beechwoods SAC for Scenario B and Scenario C

Cookham Bisham Dean

Consideration of background concentrations Figure 4-2 and Figure 4-3 show the results of the BLPSV-PC Scenario B and Scenario C, respectively, overlaid with the 2030 background NOx concentrations from Defra37. Background maps for the year 2030 were selected, as this is the farthest year into the future for which background maps are available (Section 2.3.7.1).The total predicted NOx concentrations were calculated as the sum of the forecast background concentrations of airborne NOx for 2030, and the modelled road contribution to airborne NOx from Scenario B and Scenario C. The maximum total predicted concentration for Scenario B from zonal statistics, within Chilterns Beechwoods SAC, was 22.00 µg/m3, corresponding to 73.3% of the CL. For Scenario C, the maximum was 22.14 µg/m3, equivalent to 73.8% of the CL. On the basis of available evidence, the BLPSV-PC development scenarios will not result in an increase in NOx above the CL. As such, supporting processes (on which the feature relies) will not be affected and there will be no adverse effect on the integrity of this SAC.

37 https://laqm.defra.gov.uk/review-and-assessment/tools/background-maps.html

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Figure 4-2 Total predicted concentrations and areas predicted to exceed the 1% screening threshold for airborne NOx at Chilterns Beechwoods SAC for Scenario B

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Figure 4-3 Total predicted concentrations and areas predicted to exceed the 1% screening threshold for airborne NOx at Chilterns Beechwoods SAC for Scenario C

4.2.3.2 Nitrogen deposition Figure 4-4 and Figure 4-5 illustrate the areas where the modelled contributions from the BLPSV-PC Scenario B and Scenario C, respectively, are predicted to exceed 0.1 kgN/ha-year (1% of the lowest CL). All the areas of exceedance are located within Bisham Woods SSSI. For Scenario B, there are four small areas of exceedance adjacent to the A404. For Scenario C there are two areas of exceedance: one adjacent to the A404 and one in the north-east of the site at Quarry Wood Road.

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Figure 4-4 Overview of screening results for nitrogen deposition within Chilterns Beechwoods SAC for Scenario B, assuming forest deposition rates and a CL of 10 kgN/ha-year

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Figure 4-5 Overview of screening results for nitrogen deposition within Chilterns Beechwoods SAC for Scenario C, assuming forest deposition rates and a CL of 10 kgN/ha-year

Cookham Dean

Summary of critical loads • The lowest CL of 10-20 kgN/ha-yr is set for Asperulo-Fagetum beech forests. • A higher CL of 15-25 kgN/ha-yr is set for Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia). A CL of 10-20 kgN/ha-yr is set for Lucanus cervus (Stag beetle), but no negative impacts are expected on the species due to impacts on the species’ broad habitat (Broadleaved, mixed and yew woodland). Consideration of background concentrations According to APIS, the background levels for nitrogen deposition within Chilterns Beechwoods SAC range from 24.22 to 33.46 kgN/ha-yr in areas with the broad habitat Broadleaved, mixed and yew woodland. The lowest CL of 10 kgN/ha-yr is exceeded by background concentrations, without any contribution from proposed developments included. Supplementary advice for the conservation objectives also indicates that, for this feature, the critical loads for nitrogen are currently exceeded. The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the A404 and Bisham Roundabout. The central area predicted to exceed the 1% screening threshold for nitrogen deposition within Chilterns Beechwoods SAC for Scenario B, adjacent to the Bisham Roundabout, was subject to a National

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Vegetation Classification (NVC) survey in 201838. The NVC survey identified that the habitat present was W12a Fagus sylvatica – Mercurialis perennis which corresponds with the Annex 1 qualifying feature habitat Asperulo-Fagetum beech forests for which Chilterns Beechwoods SAC is (in part) designated. The NVC survey in 2018 did not cover all the areas predicted to receive increased levels of nitrogen deposition under scenarios B and C but the Priority Habitat Inventory (PHI) information and aerial imagery indicate that the habitats in the other areas are comparable and are likely to be qualifying features of the SAC. Natural England provided the following advice in relation to this site: “Typically however, because of the ‘edge effects’ seen at most isolated woodlands the lichen and bryophyte flora of woodland margins will tend to be quite different to that within the body of the wood where light, humidity, temperature, nutrient levels are all more ‘natural’ and uniform. It is widely recognised that woodland edges act as a ‘buffer zone’ and often have a different composition to the main body of a wood. Effects of nutrient deposition in this zone will be much less obvious, so even if there were to be increased risk of detrimental impacts they may not be detectable. Specifically in relation to lichens and bryophytes, the type of species which typically colonise the margins of woods are those that are able to make use of increased nitrogen and ammonia (and light) and able to tolerate deposition of dust, so it would be difficult to argue that these areas would be at risk.” In view of this advice, it was concluded that there is no adverse effect on the integrity of Chilterns Beechwoods SAC due to increased nitrogen deposition as a result of the BLPSV-PC in isolation. The increase in nitrogen deposition is unlikely to result in an overall habitat loss and, as such, would not affect the extent and distribution of the Annex 1 habitat. 4.2.3.3 Airborne ammonia The relevant CLs for Chilterns Beechwoods SAC are: • 1 µg/m3 throughout the site due to the presence of Lichens and Bryophytes. • 3 µg/m3 for the broad habitat Broadleaved, mixed and yew woodland. Figure 4-6 illustrates the areas where the modelled contribution from Scenario B and Scenario C are predicted to exceed 0.01 µg/m3 (1% of 1 µg/m3). The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the A404.

38 Ricardo Energy and Environment (2018) Bisham Woods SSSI National Vegetation Classification Report. Report for Royal Borough of Windsor and Maidenhead. ED11104102. Issue Number 1.

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Figure 4-6 Areas predicted to exceed the 1% screening threshold for airborne NH3 within Chilterns Beechwoods SAC for Scenario B and Scenario C

Consideration of background concentrations

According to APIS, the background levels for airborne NH3 at Chilterns Beechwoods SAC range from 1.27 to 1.97 µg/m3. Therefore, the lowest CL of 1 µg/m3 is exceeded by background concentrations, without any contribution from proposed developments included. The NVC survey undertaken at Bisham Woods in 201838 identified that bryophytes were present within the woodland but did not form an important part of the community. The area covered by the NVC survey was outside of the area predicted to receive increased acid deposition, however, the priority habitat inventory and aerial imagery indicate that the habitats are likely to be comparable between the two areas. The NVC community present typically has few bryophytes associated with it39; this is also confirmed by the NVC survey in 2018 which found low bryophyte diversity and abundance. Lichens were not identified as being present during the survey, however, they are not typically covered by the NVC survey methodology. Lichen and bryophytes are not mentioned as an important constituent of the woodland habitat in SAC citation or habitat description on the Joint Nature Conservation Committee (JNCC) website for Asperulo- Fagetum woodland. APIS identifies that lichens and bryophytes are present, but does not specify a CL for the woodland habitat at Chiltern Beechwoods SAC. A limit of 1 μg/m3 for Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia – important orchid sites, H6210) is listed, as well as a limit of 3 μg/m3 for stag beetles (which are dependent on woodland) stating that they are not sensitive to ammonia, but this CL is for higher plants that they depend on.

39 Rodwell, J, S (1998) – British Plant Communities –Volume 1 – Woodlands and Scrub. Cambridge University Press.

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Natural England have confirmed that “In the absence of any information on the presence of particularly sensitive species anywhere in Bisham Woods, we can say that we do not perceive a risk to the integrity of the SAC from the data provided.” Natural England have also highlighted that “It is widely recognised that woodland edges act as a ‘buffer zone’ and often have a different composition to the main body of a wood… Specifically, in relation to lichens and bryophytes, the type of species which typically colonise the margins of woods are those that are able to make use of increased nitrogen and ammonia (and light) and able to tolerate deposition of dust, so it would be difficult to argue that these areas would be at risk.” Based on the above evidence, a CL of 3 μg/m3 for airborne ammonia is appropriate for the areas of exceedance identified in the Chilterns Beechwoods SAC.

The total predicted NH3 concentrations were calculated as the sum of the 2013-2015 background NH3 concentrations from APIS, and the modelled road contribution to airborne NH3 from Scenario B and Scenario C. The greatest predicted concentrations of total airborne ammonia are 1.621 and 1.622 µg/m3 for Scenarios B and C, respectively, corresponding to 54.0% and 54.1%, respectively, of the CL of 3 µg/m3. On the basis of available evidence, there is no adverse effect on the integrity of this SAC site arising from increased airborne ammonia associated with the BLPSV-PC development scenarios in isolation. 4.2.4 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. 4.2.4.1 Stage 1 Screening The screening results indicate that air quality impacts for acid deposition associated with the BLPSV- PC, in isolation, are below the 1% screening threshold. Consequently, likely significant effects can be discounted for acid deposition as a causal pollutant arising from increased road emissions associated with the BLPSV-PC in isolation.

Nitrogen deposition, airborne NOx and NH3 are predicted to exceed the 1% screening threshold for Scenario C for small components of the SAC, in isolation. Therefore, likely significant effects from air quality impacts was not ruled out for these pollutants at Stage 1. 4.2.4.2 Stage 2 appropriate assessment A stage 2 appropriate assessment within the exceedance zones identified at the screening stage was carried out: Airborne NOx: The total predicted NOx concentrations were calculated. The maximum total predicted concentration for Scenario C, within Chilterns Beechwoods SAC, was 22.14 µg/m3 (73.8% of the CL). On the basis of available evidence, there is no adverse effect on the integrity of this SAC site arising from increased airborne NOx associated with the BLPSV-PC in isolation. Nitrogen deposition: The lowest CL of 10 kgN/ha-yr is exceeded by background concentrations, without any contribution from proposed developments included. The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the A404 and Bisham Roundabout. However, based on advice from Natural England, in view of the forest edge location of the potentially affected area, there is no adverse effect on the integrity of Chilterns Beechwoods SAC due to nitrogen deposition.

3 Airborne NH3: The lowest CL of 1 µg/m is exceeded by background concentrations, without any contribution from proposed developments included. The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the A404. Evidence from NVC surveys and advice from Natural England indicates that Lichens and Bryophytes would not be adversely affected by

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 64 increased airborne ammonia, if they are present within the exceedance areas identified. Therefore, a CL of 3 µg/m3 is appropriate. The greatest predicted concentration of total airborne ammonia is 1.622 µg/m3 for Scenario C (54.1% of the CL of 3 µg/m3). On the basis of available evidence, there is no adverse effect on the integrity of this SAC site arising from increased airborne NH3 associated with the BLPSV-PC in isolation. 4.2.4.3 In-combination effects In view of the evaluation of potentially relevant plans and projects set out in Section 4.2.2.1, it was concluded that there were no plans or projects which could potentially pose a risk of in-combination impacts with the RBWM BLPSV-PC at Chilterns Beechwoods SAC.

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4.3 Thursley, Ash, Pirbright & Chobham SAC (UK0012793) 4.3.1 Background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Ash to Brookwood Heaths SSSI; Chobham Common SSSI; Colony Bog and Bagshot Heath SSSI; Thursley, Hankley and Frensham Commons SSSI. This site forms part of the Thames Basin Heaths SPA (UK9012141). Thames Basin Heaths SPA is a composite site spread across Surrey, Hampshire, and Berkshire, the other units of the site are designated only as a SPA. Qualifying and notifiable features associated with this site include: • H4010 Northern Atlantic wet heaths with Erica tetralix • H4030 European dry heaths • H7150 Depressions on peat substrates of the Rhynchosporion The Site Improvement Plan (SIP 237)40 states that nitrogen deposition has been identified as a pressure/threat for the designated sites that form the Thames Basin complex41. 4.3.2 HRA Stage 1: Assessment of air quality impacts against screening thresholds This section comprises the outcome of the screening assessment described in Section 2.4.3. Table 4-7 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this designated site. The most stringent critical load or critical level (CL) for each pollutant is indicated in bold. The critical level for airborne NOx is set at 30 µg/m3 across all designated sites.

Table 4-7 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for Thursley, Ash, Pirbright & Chobham SAC Minimum acid Minimum nutrient deposition CLs Minimum Sensitive feature nitrogen deposition CLs (MinCLMaxN, kEq/ha- airborne NH3 3 (kgN/ha-year) year) CLs (µg/m ) H4010 Northern Atlantic wet 10 - 20 0.872 1 heaths with Erica tetralix H4030 European dry heaths 10 - 20 0.872 1 H7150 Depressions on peat substrates of the 10 - 15 0.532 1 Rhynchosporion 4.3.2.1 Consideration of in-combination effects HRA reports that identified potential impacts to Burnham Beeches were identified for the following neighbouring authorities: • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 screened out the impacts from the BLPSV-PC on the Thursley, Ash, Pirbright and Chobham SAC.

40 Natural England (2014) Site Improvement Plan: Thames Basin (SIP237). Improvement Programme for England's Natura 2000 Sites (IPENS). Available at: http://publications.naturalengland.org.uk/file/5946121331408896. Accessed on 19th November 2019.

41 Site Improvement Plan 237 covers the Natura 2000 site(s) which form the Thames Basin complex: Thames Basin Heaths SPA, Thursley, Ash, Pirbright & Chobham SAC, Thursley, Hankley & Frensham Commons SPA.

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• London Borough of Hillingdon. A screening assessment of the Council’s Core Strategy published in 2014 screened out impacts on the Thursley, Ash, Pirbright and Chobham SAC. • Reading Borough Council. An HRA screening of the Local plan in 2016 found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Sites and Detailed Policies Document. • Runnymede Borough Council. An HRA of the updated Local Plan was published in May 2018, with a supplementary assessment of modifications published in December 2019. The findings of this HRA were taken into account in the present assessment of in-combination effects. • Rushmoor Borough Council. An HRA of the updated Local Plan was published in June 2017, this concluded that the Local Plan would not result in likely significant effect upon the SAC in respect of air quality. The findings of this HRA were taken into account in the present assessment of in-combination effects. • Slough Borough Council (SBC). Not relevant to this assessment (see Section 4.1.2.1) • South Buckinghamshire Borough Council: An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 screened out impacts to the SAC. • Surrey Heath Borough Council. is unlikely to lead to significant effects on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC and can be screened out. • Surrey Heath Borough Council. An HRA report for Draft Local Plan to 2032 Issues and Options Consultation 2018 concluded that the local plan is unlikely to lead to significant effects on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. No air quality modelling was undertaken as part of the May 2018 HRA for Surrey Heath draft BLPSV-PC but was scheduled to be included in a revised HRA. • Wokingham Borough Council. A scoping document published in August 2016 highlighted the need for consideration of potential air quality impacts of the borough Local Plan Update on air quality at Thursley, Ash, Pirbright and Chobham SAC. Wokingham Borough Council has not yet carried out this HRA. • Wycombe District Council. An HRA screening report for the Local Plan published in September 2017 did not identify any potential significant effects to the SAC. • Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue. Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified: • Heathrow airport development. Not relevant to this assessment (see Section 4.1.2.1) • Western Rail Link to Heathrow. The Initial Environmental Information Report (February 2016) indicates that there may be overall air quality benefits from implementation of the Rail Link. The rail link itself is located well away from the Natura 2000 sites under consideration, and consequently there are not likely to be any significant impacts from local traffic movements to and from Langley station. If anything, the rail link is likely to result in reductions in traffic movements on the key road links to and from Heathrow Airport, such as the M4 and M3. • M4 Junctions 3 to 12 Smart Motorway improvements. The Environmental Statement identified potential impacts at Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. Detailed assessment identified that the proposed development would have a nil to marginal net benefit on air quality at these locations, with the greatest forecast impact identified as a reduction of 0.2 μg/m3 in airborne NOx at Chobham Common SSSI The assessment of the Borough Local Plan for Runnymede Borough Council found that the Runnymede Local Plan would result in a maximum increase of 3.3% of the critical level for airborne NOx, and a maximum increase of 0.4% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne ammonia or acid deposition was provided. As set out in Section 4.3.4.3, where quantitative information was provided for the Runnymede Local Plan, it was possible to rule out the risk of in-combination impacts at this location. The assessment of the Borough Local Plan for Rushmoor Borough Council found that the Rushmoor Local Plan would result in a maximum increase of 0.7% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne NOx, airborne

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 67 ammonia or acid deposition was provided. As set out in Section 4.3.4.3, where quantitative information was provided for the Runnymede and Rushmoor Local Plans, it was possible to rule out the risk of in- combination impacts at this location. 4.3.2.2 Screening results Table 4-8 and Table 4-9 compare the maximum modelled contribution of Scenario B and Scenario C, respectively, to the lowest applicable CL. Values highlighted in yellow exceed the 1% screening threshold. This screening exercise represents a precautionary approach, as it assumes that the most sensitive qualifying features (with the lowest CLs) are present in the areas with the highest modelled contribution (typically adjacent to the busiest road). The screening results indicate that air quality impacts for airborne NOx associated with the BLPSV-PC, in isolation, are below the 1% screening threshold in both scenarios. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Thursley, Ash, Pirbright and Chobham SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for airborne NOx as a causal pollutant arising from increased road emissions associated with the BLPSV-PC (either alone or in combination).

Acid deposition and NH3 are predicted to exceed the 1% screening threshold for Scenario B and Scenario C, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these three pollutants. A Stage 2 Appropriate Assessment has been undertaken in the following section.

Table 4-8 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Grassland 10 0.253 2.53% (kgN/ha-year) Acid deposition (kEq/ha- Grassland 0.532 0.0180 3.38% year) Airborne NOx (µg/m3) N/A 30 0.216 0.72% 3 Airborne NH3 (µg/m ) N/A 1 0.0465 4.65%

Table 4-9 Screening results based on dispersion modelling of Scenario C Maximum Maximum distance of Pollutant Deposition type Minimum CL modelled % of CL exceedance contribution from roadside / m Nutrient nitrogen Grassland 10 0.0886 0.89% NA deposition (kgN/ha-year) Acid deposition (kEq/ha- Grassland 0.532 0.00631 1.19% 10 year) Airborne NOx (µg/m3) N/A 30 0.232 0.78% NA 3 Airborne NH3 (µg/m ) N/A 1 0.0151 1.51% 13 4.3.3 HRA Stage 2: Appropriate assessment 4.3.3.1 Airborne ammonia The relevant CL for Thursley, Ash, Pirbright and Chobham SAC is 1 µg/m3 due to the presence of Lichens and Bryophytes.

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Error! Not a valid bookmark self-reference. illustrates the areas where the modelled contribution from Scenario B and Scenario C are predicted to exceed 0.01 µg/m3 (1% of 1 µg/m3). The BLPSV-PC would result in a contribution above 1% of the CL in areas of this site adjacent to the M3.

Figure 4-7 Overview of screening results for airborne NH3 at Thursley, Ash, Pirbright and Chobham SAC for Scenarios B and C

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Consideration of background concentrations

According to APIS, the background levels for airborne NH3 at Thursley, Ash, Pirbirght and Chobham SAC within the modelling domain range from 1.01 to 1.61 µg/m3.

The area where Scenario B airborne NH3 contribution exceeds 1% of the CL is fully within Unit 1 of the Colony Bog and Bagshot heath SSSI, a constituent SSSI of the Thursley, Ash, Pirbirght and Chobham SAC. The SSSI habitat condition assessment (2017)42 identifies that Unit 1 contains dwarf shrub heath. Bell heather (Erica cinerea) is identified as being frequent-occasional and cross leaved heath (Erica tetralix) is identified as being rare; this indicates that the habitats are likely to be predominantly European dry heath within Unit 1 but the exact distribution or extent within the affected area is not known. Bog pools are not identified in the condition assessment and none are visible from aerial imagery, but the resolution available means there is low certainty for this. The SSSI site condition assessment identifies that there are occasional or rare occurrences of reindeer lichen (Cladonia portentosa) within Unit 1, so lichens are likely to be present with the exceedance area. The habitats present are likely to comprise Annex 1 habitats that are qualifying features of the SAC: European dry heath and/or Northern Atlantic wet heaths with Erica tetralix.

The area where Scenario C airborne NH3 contribution exceeds 1% is within Units 12 (south west of the B383), 13 and 14 (north east of the B383) of Chobham Common SSSI, a constituent SSSI of the Thursley, Ash, Pirbirght and Chobham SAC. The condition assessment for the Scenario C exceedance areas indicates that lichens are present within the heath (if heath is present in the exceedance areas, with Unit 12 identified as supporting a good diversity of Cladonia sp. lichens. The heathland within these areas is identified as dry heath or “humid” heath which would correspond with the Annex 1 habitats that are qualifying features of the SAC. The PHI information indicates that heath is only present in the exceedance area north-east of the B383, however, the site condition assessment for Unit 13 and aerial imagery indicates that the habitat is not present in this area. The Unit 13 condition assessment states “Part of the lower slope appears to be on land modified during the construction of the motorway.” The lowest CL of 1 µg/m3 is exceeded by background concentrations, without any contribution from proposed developments included. This CL is appropriate as lichens / bryophytes are likely to be present within the exceedance areas for both development scenarios. The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the M3 at Bagshot / Lightwater (Scenario B) and at Longcross Studios (Scenario C). The greatest predicted concentrations of total 3 3 airborne ammonia are 1.66 µg/m and 1.63 µg/m for Scenarios B and C respectively. Airborne NH3 cannot be screened out in isolation under either scenario. Site survey A site walkover survey was carried out on 21 January 2020 to investigate the presence of relevant habitats and species in the areas potentially affected by the BLPSV-PC under Scenario C. This survey confirmed that, due to management measures used in this area, no lichens and a single bryophyte was identified in this part of the SAC. It was concluded that mosses and bryophytes do not form an important part of the community in this area. As a result, a CL of 3 µg/m3 can be considered as applicable in this area. As the greatest predicted concentration of total airborne ammonia is 1.63 µg/m3 for Scenario C, it is concluded that the BLPSV-PC in isolation will have no adverse effect on the integrity of this site due to airborne NH3.

42 Condition of SSSI Units for Site Chobham Common SSSI, Natural England, 2017, https://designatedsites.naturalengland.org.uk/ ReportUnitCondition.aspx?SiteCode=S1004332&ReportTitle=Chobham%20Common%20SSSI (Accessed December 2019).

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4.3.3.2 Nitrogen deposition Error! Not a valid bookmark self-reference. shows the area where the modelled contributions from the BLPSV-PC Scenario B is predicted to exceed 0.1 kgN/ha-year (1% of the lowest CL). For Scenario B, there is one small area of exceedance adjacent to the M3. For Scenario C no exceedances were predicted.

Figure 4-8 Screening results for nitrogen deposition at Thursley, Ash, Pirbright and Chobham SAC, assuming grassland deposition rates and a CL of 10, for Scenario B

Bagshot

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Summary of critical loads The lowest CL is 10-15 kg N/ha-yr for Depressions on peat substrates of the Rhynchosporion. A higher CL of 10-20 kg N/ha-yr is set for Northern Atlantic wet heaths with Erica tetralix, and European dry heaths. Consideration of background concentrations According to APIS, the background levels for nitrogen deposition range from 12.04 to 25.06 kgN/ha-yr in areas with short vegetation, including the broad habitats Bogs and Dwarf shrub heath. The area predicted to exceed the 1% screening threshold for nitrogen deposition fully within Unit 1 of the Colony Bog and Bagshot heath SSSI, a constituent SSSI of the Thursley, Ash, Pirbirght and Chobham SAC. The SSSI habitat condition assessment (2017)42 identifies that Unit 1 contains dwarf shrub heath. Bell heather is identified as being frequent-occasional and cross leaved heath is identified as being rare; this indicates that the habitats are likely to be predominantly dry heath within Unit 1 but the exact distribution or extent within the affected area is not known. Bog pools are not identified in the condition assessment and none are visible from aerial imagery. The data available from the SSSI condition assessment and priority habitat inventory indicates the nitrogen exceedance area contains Annex 1 habitats that are qualifying features of the SAC: European dry heath and/or Northern Atlantic wet heaths with Erica tetralix. The lowest CL of 10 kg N/ha-yr is exceeded by background concentrations, without any contribution from proposed developments included. 4.3.3.3 Acid deposition Figure 4-9 illustrates the areas where the modelled contribution from Scenario B and Scenario C are predicted to exceed 0.00532 kEq/ha-year (1% of the lowest CL). The BLPSV-PC would result in a contribution above 1% of the CL in areas of this site adjacent to the M3, almost identical to those areas of exceedance identified for airborne ammonia. Summary of critical loads The lowest CL is 0.532 to 0.676 kEq/ha-yr for Depressions on peat substrates of the Rhynchosporion. A higher CL of 0.872 to 2.404 kEq/ha-yr is set for Northern Atlantic wet heaths with Erica tetralix, and European dry heaths. Consideration of background concentrations According to APIS, the background levels for acid deposition (total of N and S) range from 1.09 to 2.10 kEq/ha-yr in areas with short vegetation, including the broad habitats Bogs and Dwarf shrub heath.

As described above for NH3 and nitrogen deposition, the acid deposition exceedance area for Scenario B is likely to contain Annex 1 habitats that are qualifying features of the SAC: European dry heath and/or Northern Atlantic wet heaths with Erica tetralix. The lowest CL of 0.532 kEq/ha-yr is exceeded by background concentrations, without any contribution from proposed developments included, therefore acid deposition cannot be screened out for Scenario B. The acid deposition exceedance areas for Scenario C were deemed unlikely to contain habitats that are qualifying features of the SAC based on the information from the PHI data, aerial imagery, and the Chobham Common SSSI unit condition assessment. These exceedance areas were therefore subject to a walkover survey in January 2020 to identify the broad habitat types present. Natural England identified that many areas of Chobham common adjacent to the M3 were modified during road construction, meaning that much of the natural soil is substantially modified or buried under more clay-rich material therefore suitable habitat for qualifying features is unlikely in these areas. The area is currently managed by mowing to reduce the risk of fires however Natural England indicate it

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 72 may change to management by grazing in the future. Natural England indicated that plants characteristic of wet heaths may be present in the area potentially affected by the BLPSV-PC. The results of the walkover survey for the areas of exceedance identified for Scenario C are as follows: • The land to the west of Windsor Road (B383) slopes upwards from the M3 and comprises predominantly birch (Betula sp.) and oak (Quercus sp.) woodland with occasional patches of bramble (Rubus fruticosus agg.) and gorse (Ulex sp.) present within the shrub layer. The lower section of the slope adjacent to the M3 comprises patches of bare earth, gorse scrub and birch saplings whereas the upper slope, near the waterbody (name unknown), supports common heather (Calluna vulgaris). • The land between Windsor Road (B383, west) and Chobham Road (B383, east) is predominantly acid grassland, with the areas directly adjacent to the motorway generally comprising finer grasses such as fescues (Festuca sp.) and matt grass (Nardus stricta). The area further away from the motorway (outside of the exceedance area) is dominated by purple moor grass (Molinia caerulea). These areas have low bryophyte abundance, with only occasional heath plait moss (Hypnum jutlandicum) identified. There are occasional bell heather (Erica cinerea), dwarf gorse (Ulex minor), and cross-leaved heath (Erica tetralix), particularly at the western extent near Windsor Road. Some extensive areas of gorse had been cleared by mowing to the west of the underpass which resulted in large patches of bare earth dominated by young gorse re-growth.

• Although occasional species indicative of dwarf shrub heaths were identified, the habitats present within the acid deposition exceedance area adjacent to the M3 do not represent habitats that form the qualifying features of the SAC due to the current management of these areas and historic disturbance from construction of the motorway. The SAC’s qualifying features are not present in the areas of exceedance identified for acid deposition under Scenario C for the reasons set out above. It was concluded that the BLPSV-PC in isolation will have no adverse effect on the integrity of this SAC due to acid deposition.

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Figure 4-9 Overview of screening results for acid deposition at Thursley, Ash, Pirbright and Chobham SAC, assuming grassland deposition rates and a CL of 0.532 kEq/ha-year, for Scenarios B and C

Woking

Farnborough

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4.3.4 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. 4.3.4.1 Stage 1 Screening The screening results indicate that air quality impacts for airborne NOx and nitrogen deposition associated with the BLPSV-PC, in isolation, are below the 1% screening threshold. Consequently, likely significant effects can be discounted for airborne NOx and nitrogen deposition arising from increased road emissions associated with the BLPSV-PC in isolation.

Acid deposition and airborne NH3 are predicted to exceed the 1% screening threshold for Scenario C, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these pollutants. The potential for in-combination effects from the borough of Runnymede should be taken into account in further assessment of these two pollutants. 4.3.4.2 Stage 2 appropriate assessment A stage 2 appropriate assessment within the exceedance zones identified at the screening stage was carried out:

Airborne NH3: The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the M3 at Longcross Studios, for Scenario C. The lowest CL of 1 µg/m3 is exceeded by background concentrations, without any contribution from proposed developments included. However, the site walkover survey found that lichens and bryophytes are not an important component of the site in this area. It was concluded that the higher CL is applicable in this area, and consequently the BLPSV-PC in isolation will have no adverse effect on the integrity of the SAC due to airborne NH3.

Acid deposition: The exceedance areas for acid deposition closely match those for airborne NH3. Natural England advised that wet heath plants could be present in this area. The acid deposition exceedance areas for Scenario C were subject to a walkover survey to identify any habitats that are qualifying features of the SAC. It was found that the SAC’s qualifying features are not present in the areas of exceedance identified for acid deposition and therefore the BLPSV-PC in isolation will have no adverse effect on the integrity of the SAC due to acid deposition. Natural England’s supplementary advice for this site indicates that the total extent of the H4030 feature is a baseline value of approximately 1830 hectares and the BLPSV-PC would result in no measurable net reduction (excluding any trivial loss) in the extent and area of the feature. 4.3.4.3 In-combination effects The assessment of the Borough Local Plan for Runnymede Council found that the Runnymede Local Plan would result in a maximum increase of 3.3% of the critical level for airborne NOx, and a maximum increase of 0.4% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne ammonia or acid deposition was provided. The assessment of the Borough Local Plan for Rushmoor Borough Council found that the Rushmoor Local Plan would result in a maximum increase of 0.7% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne NOx, airborne ammonia or acid deposition was provided. Baseline levels of NOx are forecast to comply with the air quality guideline at the Thursley, Ash, Pirbright and Chobham SAC by 2030, with a maximum concentration of 55.8% of the air quality guideline. The maximum in-combination increment from the RBWM and Runnymede Local Plans is 4.1% of the air quality guideline. In view of the forecast margin of compliance in 2030, and the relatively small in- combination increments from the RBWM and Runnymede Councils’ Local Plans, it is concluded that

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 75 there will be no adverse effect on the integrity of this SAC arising from increased airborne NOx associated with the BLPSV-PC development scenarios in combination with other plans and projects. The maximum in-combination increment to nitrogen deposition from the RBWM, Runnymede and Rushmoor Local Plans is 2.0% of the air quality guideline. This in-combination increase could potentially affect the immediate vicinity of the M3 motorway, in similar areas to those assessed above in relation to potential impacts due to acid and nitrogen deposition. The site surveys confirmed that the SAC’s qualifying features are not present in the areas of exceedance surveyed. It is concluded that there is no adverse effect on the integrity of this SAC due to nitrogen deposition from the BLPSV-PC in combination with the Runnymede and Rushmoor Local Plans No quantitative information was provided in the Runnymede Council HRA for acid deposition or ammonia, or in the Rushmoor Borough Council HRA for acid deposition, airborne ammonia or airborne NOx. However, the results for airborne NOx and nitrogen deposition set out above indicate that there is no significant risk of in-combination impacts due to the pathways that were assessed by the other authorities. As a result, it is concluded that there is no significant risk of an adverse effect on the integrity of the Thursley, Ash, Pirbright and Chobham SAC resulting from in-combination airborne NOx, airborne ammonia or acid deposition pathways.

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4.4 Windsor Forest and Great Park SAC (UK0012586) 4.4.1 SAC background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Windsor Forest and Great Park SSSI Qualifying and notifiable features associated with this site include: • 9190 Old acidophilous oak woods with Quercus robur on sandy plains • 9120 Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion)

• 1079 Violet click beetle (Limoniscus violaceus) The Site Improvement Plan (SIP) states that nitrogen deposition has been identified as a pressure to the qualifying feature habitats of this SAC43. The conservation objectives stated for this site are to ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring; • The extent and distribution of qualifying natural habitats, • The structure and function (including typical species) of qualifying natural habitats, and, • The supporting processes on which qualifying natural habitats rely. 4.4.2 HRA Stage 1: Assessment of impacts against screening thresholds This section comprises the outcome of the screening assessment described in Section 2.4.3. Table 4-10 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this designated site. The most stringent critical load or critical level (CL) for each pollutant is indicated in bold. The critical level for airborne NOx is set at 30 µg/m3 across all designated sites.

Table 4-10 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for Windsor Forest and Great Park SAC Minimum acid Minimum nutrient deposition CLs Minimum airborne Sensitive feature nitrogen deposition (MinCLMaxN, 3 NH3 CLs (µg/m ) CLs (kgN/ha-year) kEq/ha-year) 9190 Old acidophilous oak woods with Quercus robur on sandy 10 - 15 1.044 1 plains 9120 Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrub layer 10-20 1.044 1 (Quercion robori-petraeae or Ilici- Fagenion) 1079 Violet click beetle 10-20 1.044 3 (Limoniscus violaceus)

43 Natural England (2014) Site Improvement Plan Burnham Beeches SAC. Improvement Programme for England's Natura 2000 Sites (IPENS). Available at http://publications.naturalengland.org.uk/publication/5689860228644864. Accessed on 19 November 2019

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4.4.2.1 Consideration of in-combination effects HRA reports were identified for the following neighbouring authorities: • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 screened the impacts from the BLPSV-PC on the Windsor Forest and Great Park SAC. • London Borough of Hillingdon. A screening assessment of the Council’s Core Strategy published in 2014 found that Windsor Forest and Great Park SAC was “not considered to be sensitive to the Air Quality impacts of the Core Strategy due to prevailing wind direction and the distance from the borough.” • Reading Borough Council. An HRA screening of the Local plan in 2016 found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Sites and Detailed Policies Document. • Runnymede Borough Council. An HRA of the updated Local Plan was published in May 2018, with a supplementary assessment of modifications published in December 2019. The findings of this HRA were taken into account in the present assessment of in-combination effects. • Rushmoor Borough Council. An HRA of the updated Local Plan was published in June 2017; this concluded that the Local Plan would not result in likely significant effect upon the SAC in respect of air quality. • Slough Borough Council (SBC). Not relevant to this assessment (see Section 4.1.2.1) • South Buckinghamshire Borough Council: An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 screened out impacts to the Windsor Forest and Great Park SAC. • Surrey Heath Borough Council. An HRA report for Draft Local Plan to 2032 Issues and Options Consultation 2018 screened out Windsor Forest and Great Park SAC as the local plan is unlikely to result in significant effects. No air quality modelling was undertaken as part of the May 2018 HRA for Surrey Heath draft BLPSV-PC but was scheduled to be included in a revised HRA. • Wokingham Borough Council. A scoping document published in August 2016 did not identify the potential for significant air quality impacts at the SAC. • Wycombe District Council. An HRA screening report for the Local Plan published in September 2017 did not identify any potential significant effects to the SAC. • Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue. Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified: • Heathrow airport development. Not relevant to this assessment (see Section 4.1.2.1) • Western Rail Link to Heathrow. The Initial Environmental Information Report (February 2016) indicates that there may be overall air quality benefits from implementation of the Rail Link. The rail link itself is located well away from the Natura 2000 sites under consideration, and consequently there are not likely to be any significant impacts from local traffic movements to and from Langley station. If anything, the rail link is likely to result in reductions in traffic movements on the key road links to and from Heathrow Airport, such as the M4 and M3. The assessment of the Borough Local Plan for Runnymede Council found that the Runnymede Local Plan would result in a maximum increase of 1.6% of the critical level for airborne NOx, and a maximum increase of 0.3% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne ammonia or acid deposition was provided. As set out in Section 4.4.4.3, where quantitative information was provided for the Runnymede Local Plan, it was possible to rule out the risk of in-combination impacts at this location. 4.4.2.2 Screening results Table 4-11 and Table 4-12 compare the maximum modelled contribution of Scenario B and Scenario C, respectively, to the lowest applicable CL. Values highlighted in yellow exceed the 1% screening

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The screening results indicate that air quality impacts for acid deposition and airborne NH3 associated with the BLPSV-PC, in isolation, are below the 1% screening threshold in both scenarios. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Windsor Forest and Great Park SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for acid deposition and airborne NH3 as causal pollutants arising from increased road emissions associated with the BLPSV-PC in isolation. Nitrogen deposition is predicted to exceed the 1% screening threshold for Scenario B, in isolation; airborne NOx is predicted to exceed the 1% screening threshold for both development scenarios, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these pollutants. A Stage 2 Appropriate Assessment has been undertaken in the following section.

Table 4-11 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Forest 10 0.143 1.43% (kgN/ha-year) ͣ Grassland 10 0.0859 0.86% Acid deposition (kEq/ha- Forest 1.439 0.0102 0.71% year) ͣ Grassland 1.439 0.00611 0.42% Airborne NOx (µg/m3) N/A 30 0.492 1.64% 3 Airborne NH3 (µg/m ) N/A 3 0.0109 0.36% ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. Table 4-12 Screening results based on dispersion modelling of Scenario C Maximum Maximum distance of Pollutant Deposition type Minimum CL modelled % of CL exceedance contribution from roadside / m Nutrient nitrogen Forest 10 0.0711 0.71% NA deposition (kgN/ha-year) ͣ Grassland 10 0.0399 0.40% NA Acid deposition (kEq/ha- Forest 1.439 0.00507 0.35% NA year) ͣ Grassland 1.439 0.00284 0.20% NA Airborne NOx (µg/m3) N/A 30 0.338 1.13% 15 3 Airborne NH3 (µg/m ) N/A 3 0.00533 0.18% NA ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. 4.4.3 HRA Stage 2: Appropriate assessment 4.4.3.1 Airborne NOx The relevant CL for Windsor Forest and Great Park SAC is 30 µg/m3 for all vegetation. Figure 4-10 and Figure 4-11 illustrate the areas where the modelled contribution from the BLPSV-PC is predicted to exceed 0.3 µg/m3 (1% of 30 µg/m3) under both development scenarios.

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Figure 4-10 Overview of screening results for airborne NOx at Windsor Forest and Great Park SAC, for Scenarios B and C

Windsor

LEGOLAND® Old Windsor Resort Windsor

Cranbourne

Woodside

Cheapside

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Figure 4-11 Screening results for airborne NOx at Windsor Forest and Great Park SAC, for Scenarios B and C

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Consideration of background concentrations Figure 4-12 and Figure 4-13 show the results of the BLPSV-PC Scenario B and Scenario C, respectively, overlaid with the 2030 background NOx concentrations from Defra.44 The total predicted NOx concentrations were calculated as the sum of the forecast background concentrations of airborne NOx for 2030, and the modelled road contribution to airborne NOx from Scenario B and Scenario C. The maximum total predicted concentration for Scenario B from zonal statistics, within Chilterns Beechwoods SAC, was 19.64 µg/m3, corresponding to 65.5% of the CL. For Scenario C, the maximum was 19.46 µg/m3, equivalent to 64.9% of the CL. On the basis of available evidence, the BLPSV-PC development scenarios will not result in an increase in NOx above the CL. As such, supporting processes (on which the feature relies) will not be affected and there will be no adverse effect on the integrity of this SAC.

Figure 4-12 Total predicted concentrations and areas predicted to exceed the 1% screening threshold for airborne NOx at Windsor Forest & Great Park SAC for Scenario B

44 https://laqm.defra.gov.uk/review-and-assessment/tools/background-maps.html

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Figure 4-13 Total predicted concentrations and areas predicted to exceed the 1% screening threshold for airborne NOx at Windsor Forest & Great Park SAC for Scenario C

4.4.3.2 Nitrogen deposition Figure 4-14 shows the area where the modelled contributions from the BLPSV-PC Scenario B is predicted to exceed 0.1 kgN/ha-year (1% of the lowest CL).

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Figure 4-14 Overview of screening results for nitrogen deposition at Windsor Forest and Great Park SAC, assuming forest deposition rates and a CL of 10, for Scenario B

Windsor

LEGOLAND® Windsor Resort Old Windsor

Cranbourne

Woodside

Cheapside

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Figure 4-15 Screening results for nitrogen deposition at Windsor Forest and Great Park SAC, assuming forest deposition rates and a CL of 10, for Scenario B

Sunninghill Park

Summary of critical loads The lowest CL is 10-15 kg N/ha-yr, set for Old acidophilous oak woods with Quercus robur on sandy plains. A higher CL of 10-20 kg N/ha-yr is set for Atlantic acidophilous beech forests with Ilex and sometimes Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion). The same CL of 10-20 kg N/ha-yr is set for Limoniscus violaceus (the Violet click beetle), but no negative impacts are expected on the species due to impacts on the species’ broad habitat (Broadleaved deciduous woodland).

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Consideration of background concentrations According to APIS, the background levels for nitrogen deposition range from 21.0 to 28.7 kg N/ha-yr in areas with the broad habitat Broadleaved, mixed and yew woodland. The lowest CL of 10 kg N/ha/yr is exceeded by background concentrations, without any contribution from proposed developments included. The areas predicted to exceed 1% of the lowest CL under Scenario B, adjacent to the B383, appear to be deciduous woodland from the satellite imagery. These areas potentially contain habitats that are qualifying features of the Windsor Forest and Great Park SAC. The priority habitat inventory data indicates that the area comprises Old Acidophilous Oak Woods with Quercus robur On Sandy Plains, an Annex I habitat that is a primary reason for selection of the SAC. The landowner (Crown Estate) provided a map showing the location of veteran and ancient trees which have been surveyed and recorded. This has been examined and a site survey carried out where the map indicates there may be veteran oak or beech trees within the areas of exceedance. A walkover survey of an area of Windsor Forest and Great Park was undertaken on 21st January 2020 by a suitably qualified and experienced ecologist. The survey focused on identifying veteran trees, specifically oak (Quercus sp.) and beech (Fagus sylvatica) species, within the identified areas of predicted nitrogen deposition exceedance identified for Scenario B, located between Watersplash Lane (south) and the hamlet of Woodside to the north. The predicted areas of exceedance occurring within the SAC were located at the south-west, adjacent to Sunninghill Road, and extend to a maximum of approximately 10 m from the road. During the walkover, no veteran trees were located within the areas of exceedance. All of the trees, regardless of species, were generally located more than 10m from the road. Where trees were located within or on the edge of the area of exceedance, at the northern end of the area identified on Figure 4-15, the trees were either birch (Betula sp.), sycamore (Acer pseudoplatanus) or coniferous trees and not species indicative of the habitats for which the site is designated. There was one single semi- mature oak tree located within the exceedance area; this tree was not a veteran tree. Due to the absence of qualifying features within the exceedance areas identified for nitrogen deposition, there is no adverse effect on the integrity of the Windsor Forest and Great Park SAC under Scenario B or Scenario C. The increase in nitrogen deposition is unlikely to result in an overall habitat loss and, as such, would not affect the extent and distribution of the Annex 1 habitat. 4.4.4 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. 4.4.4.1 Stage 1 Screening The screening results indicate that air quality impacts for nitrogen deposition, acid deposition and airborne NH3 associated with the BLPSV-PC, in isolation, are below the 1% screening threshold for Scenario C. Taking into account the qualitative information available at this stage, and the quantitative results from the ‘in isolation’ assessment, likely significant effects can be discounted for acid deposition and airborne NH3 as causal pollutants arising from increased road emissions associated with the BLPSV-PC in isolation. Airborne NOx is predicted to exceed the 1% screening threshold for Scenario C, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for this pollutant. 4.4.4.2 Stage 2 appropriate assessment A stage 2 appropriate assessment within the exceedance zones identified at the screening stage was carried out:

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Airborne NOx: The areas of exceedance of 1% of the CL for airborne NOx are adjacent to the B383, along the western boundary of the site. The maximum total predicted concentration for Scenario C, within Windsor Forest and Great Park SAC, was 19.46 µg/m3 (64.9% of the CL). On the basis of available evidence, there is no adverse effect on the integrity of this SAC site arising from increased airborne NOx associated with the BLPSV-PC in isolation. 4.4.4.3 In-combination effects The assessment of the Local Plan for Runnymede Borough Council found that the Runnymede Local Plan would result in a maximum increase of 1.6% of the critical level for airborne NOx, and a maximum increase of 0.3% of the critical load for nitrogen deposition at the closest point of the SAC to the local road network. No information in relation to airborne ammonia or acid deposition was provided. Because baseline levels of NOx are forecast to comply with the air quality guideline by 2030, and in view of the relatively small increment from Runnymede Council Local Plan, it is concluded that there is no adverse effect on the integrity of this SAC arising from increased airborne NOx associated with the BLPSV-PC development scenarios in combination with other plans and projects. Due to the absence of qualifying features within the exceedance areas identified for nitrogen deposition, and in view of the relatively small increment from Runnymede Council Local Plan, it is concluded that there is no adverse effect on the integrity of the Windsor Forest and Great Park SAC due to the BLPSV- PC development scenarios in combination with other plans and projects. No quantitative information was provided in the Runnymede Council HRA for acid deposition or ammonia. However, the results for airborne NOx and nitrogen deposition set out above indicate that there is no significant risk of in-combination impacts due to the pathways that were assessed by the other authorities. As a result, it is concluded that there is no significant risk of an adverse effect on the integrity of the Windsor Forest and Great Park SAC resulting from in-combination airborne ammonia or acid deposition pathways.

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4.5 South West London Waterbodies Ramsar (UK11065) and SPA (UK9012171) 4.5.1 Ramsar background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Kempton Park Reservoirs SSSI; Knight and Bessborough Reservoirs SSSI; Staines Moor SSSI Thorpe Park No. 1; Gravel Pit SSSI; Wraysbury and Hythe End Gravel Pits SSSI; Wraysbury No. 1 Gravel Pit SSSI; Wraysbury Reservoir SSSI. The Ramsar citation identifies the site comprises open water, plus associated wetland habitats including grassland and woodland supporting a number of wetland plant and animal species including internationally important numbers of wintering wildfowl. No notable flora or habitats are listed as part of the Ramsar site Information Sheet. Table 4-13 Ramsar Criterion 6: Species occurring at levels of international importance Qualifying Species/populations (as identified at designation): Over winter the area regularly supports: Gadwall (Anas strepera) 710 individuals, representing an average of 2.4% of the population (Five-year peak mean for 1993/94 to 1997/98 Shoveler (Anas clypeata) 853 individuals, representing an average of 2.1% of the population (Five-year peak mean for 1993/94 to 1997/98) The Site Improvement Plan for the overlapping SPA (South West London waterbodies SIP227) does not identify nitrogen deposition as a pressure or threat. Ramsar sites do not have Site Improvement Plans. 4.5.2 SPA background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Kempton Park Reservoirs SSSI; Knight and Bessborough Reservoirs SSSI; Staines Moor SSSI Thorpe Park No. 1; Gravel Pit SSSI; Wraysbury and Hythe End Gravel Pits SSSI; Wraysbury No. 1 Gravel Pit SSSI; Wraysbury Reservoir SSSI. The site qualifies under Article 4.2 of the Habitats Directive (79/409/EEC) as it is used regularly by 1% or more of the biogeographical populations of the following regularly occurring migratory species (other than those listed on Annex 1), in any season: Table 4-14 Qualifying features of the South West London Waterbodies SPA Migratory species 5-year peak mean 1993/94 - 1997/98 % of population Gadwall (Anas strepera) 710 individuals - wintering 2.4% North-West Europe 2.4% North-West/Central Shoveler (Anas clypeata) 853 individuals - wintering Europe

In addition, the site supports nationally important (but non-qualifying) numbers of species of interest: cormorant (Phalacrocorax carbo), great crested grebe (Podiceps cristatus), tufted duck (Aythya fuligula), pochard (Aythya farina) and coot (Fulica atra). The Site Improvement Plan (SIP227) does not identify nitrogen deposition as a pressure or threat. The conservation objectives for this site are to ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of the habitats of the qualifying features, • The structure and function of the habitats of the qualifying features,

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• The supporting processes on which the habitats of the qualifying features rely, • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site. 4.5.3 HRA Stage 1: Assessment of air quality impacts against screening thresholds This section comprises the outcome of the screening assessment described in Section 2.4.3. Table 4-15 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this designated site. The most stringent critical load or critical level (CL) for each pollutant is indicated in bold. The critical level for airborne NOx is set at 30 µg/m3 across all designated sites.

Table 4-15 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for South West London waterbodies Ramsar and SPA Minimum acid Minimum nutrient deposition CLs Minimum airborne Sensitive feature nitrogen deposition CLs 3 (MinCLMaxN, NH3 CLs (µg/m ) (kgN/ha-year) kEq/ha-year) Gadwall (Anas strepera) 10 - 20 Not sensitive 3 Shoveler (Anas clypeata) 10 - 20 Not sensitive 3 4.5.3.1 Consideration of in-combination effects HRA reports were identified for the following neighbouring authorities: • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 screened out the impacts from the RBWM BLPSV-PC on the South West London waterbodies Ramsar and SPA. • London Borough of Hillingdon. A screening assessment of the Council’s Core Strategy published in 2014 screened out impacts on the South West London Waterbodies Ramsar and SPA. • Reading Borough Council. An HRA screening of the Local plan in 2016 found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Sites and Detailed Policies Document. • Runnymede Borough Council. An HRA of the updated Local Plan was published in December 2019. The findings of this HRA were taken into account in the present assessment of in- combination effects. • Rushmoor Borough Council. An HRA of the updated Local Plan was published in June 2017. The findings of this HRA were taken into account in the present assessment of in-combination effects. • Slough Borough Council (SBC). Not relevant to this assessment (see Section 4.1.2.1) • South Buckinghamshire Borough Council: An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 screened out impacts to the Ramsar and SPA. • Surrey Heath Borough Council. An HRA report for Draft Local Plan to 2032 Issues and Options Consultation 2018 screens out impacts to the Ramsar and SPA. No air quality modelling was undertaken as part of the May 2018 HRA for Surrey Heath draft BLPSV-PC but was scheduled to be included in a revised HRA. • Wokingham Borough Council. A scoping document published in August 2016 did not identify any potential air quality impacts at the Ramsar or SPA. • Wycombe District Council. An HRA screening report for the Local Plan published in September 2017 did not identify any potential significant effects to the Ramsar or SPA. • Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue. Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified:

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• Heathrow airport development. Information was taken from the “Revised Draft Airports National Policy Statement – Habitats Regulations Assessment Statement to inform Appropriate Assessment“ (October 2017). This study did not identify potential air quality impacts on the South West London Waterbodies Ramsar and SPA. • Western Rail Link to Heathrow. The Initial Environmental Information Report (February 2016) indicates that there may be overall air quality benefits from implementation of the Rail Link. The rail link itself is located well away from the Natura 2000 sites under consideration, and consequently there are not likely to be any significant impacts from local traffic movements to and from Langley station. If anything, the rail link is likely to result in reductions in traffic movements on the key road links to and from Heathrow Airport, such as the M4 and M3. No effects to the South West London Waterbodies Ramsar and SPA as a result of this development. While the plans and projects noted above could potentially have an in-combination effect on South West London Waterbodies SPA/Ramsar, it was found that the risk of any in-combination impacts could be ruled out because of the absence of any realistic impact due to the RBWM BLPSV-PC (see Section 4.5.5.2 below). 4.5.3.2 Screening results Table 4-16 and Table 4-17 compare the maximum modelled contribution of the Scenario B and Scenario C, respectively, to the lowest applicable CL. Values highlighted in yellow exceed the 1% screening threshold. This screening exercise represents a precautionary approach, as it assumes that the most sensitive qualifying features (with the lowest CLs) are present in the areas with the highest modelled contribution (typically adjacent to the busiest road). The site’s qualifying features are not sensitive to acid deposition. The screening results also indicate that air quality impacts for airborne NOx associated with the BLPSV-PC, in isolation, are below the 1% screening threshold in both scenarios. Based on the small modelled contribution of the BLPSV-PC to air quality impacts on Windsor Forest and Great Park SAC, and the qualitative findings of the HRAs summarised in the preceding section, likely significant effects can be discounted for Scenario C for all pollutants, as well as acid deposition and airborne NOx as causal pollutants under both scenarios, arising from increased road emissions associated with the BLPSV-PC in isolation. Airborne ammonia and nitrogen deposition are predicted to exceed the 1% screening threshold for Scenario B, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these pollutants. A Stage 2 Appropriate Assessment has been undertaken in the following section.

Table 4-16 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Grassland 10 0.203 2.03% (kgN/ha-year) Acid deposition (kEq/ha- Grassland Not sensitive N/A N/A year) Airborne NOx (µg/m3) N/A 30 0.144 0.48% 3 Airborne NH3 (µg/m ) N/A 3 0.0371 1.24% ͣ This site is characterised by habitats with short vegetation, therefore grassland deposition rates are applicable. *APIS states that for nitrogen deposition “Decision to be taken at a site-specific level since habitat sensitivity depends on N or P limitation.” A CL of 10-20 kgN/ha-year has been assigned based on the presence of Neutral Grassland / Low and medium altitude hay meadows as listed in citations for the constituent SSSIs: Staines Moor, Wraysbury and Hythe, Wwrasybury No.1 gravel pit. Table 4-17 Screening results based on dispersion modelling of Scenario C Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Grassland 10 0.0738 0.74% (kgN/ha-year)

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Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Acid deposition (kEq/ha- Grassland Not sensitive N/A N/A year) Airborne NOx (µg/m3) N/A 30 0.0895 0.30% 3 Airborne NH3 (µg/m ) N/A 3 0.0147 0.49% ͣ This site is characterised by habitats with short vegetation, therefore grassland deposition rates are applicable. *APIS states that for nitrogen deposition “Decision to be taken at a site-specific level since habitat sensitivity depends on N or P limitation.” A CL of 10-20 kgN/ha-year has been assigned based on the presence of Neutral Grassland / Low and medium altitude hay meadows as listed in citations for the constituent SSSIs: Staines Moor, Wraysbury and Hythe, Wrasybury No.1 gravel pit. 4.5.4 HRA Stage 2: Appropriate assessment 4.5.4.1 Airborne ammonia The relevant CL for South West London Waterbodies Ramsar and SPA is 3 µg/m3 throughout the site for the broad habitat type Standing water and open canals, although APIS specifies “Decision to be taken at a site-specific level since habitat sensitivity depends on N or P limitation.” The features also require terrestrial habitats which provide opportunities for birds to rest up out of water such as areas of short vegetation including grassland, rush pasture or areas of waterside scrub. Figure 4-16 illustrates the areas where the modelled contribution from Scenario B is predicted to exceed 0.03 µg/m3 (1% of 3 µg/m3). The BLPSV-PC would result in a contribution above 1% of the CL in a small area of this site adjacent to the M25 at Wraysbury Reservoir. Consideration of background concentrations

According to APIS, the background levels for airborne NH3 at South West London Waterbodies Ramsar & SPA range from 1.72 to 2.04 µg/m3.

The total predicted NH3 concentrations were calculated as the sum of the 2013-2015 background NH3 concentrations from APIS, and the modelled road contribution to airborne NH3 from Scenario B. The greatest total predicted concentration of airborne ammonia for Scenario B is 2.08 µg/m3, corresponding to 69.2% of the CL of 3 µg/m3. Therefore, there is no adverse effect on the integrity of this SPA due to airborne NH3 for Scenario B in isolation. The increase in airborne ammonia will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat.

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Figure 4-16 Overview of screening results for airborne NH3 at South West London Waterbodies Ramsar & SPA, assuming a CL of 3, for Scenario B

Heathrow Airport Wraysbury

Feltham

Ashford

Thorpe Littleton M3

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Figure 4-17 Screening results for airborne NH3 at South West London Waterbodies Ramsar & SPA, assuming a CL of 3, for Scenario B

4.5.4.2 Nitrogen deposition Figure 4-18 shows the area where the modelled contributions from the BLPSV-PC Scenario B is predicted to exceed 0.1 kgN/ha-year (1% of the lowest CL). The BLPSV-PC would result in a contribution above 1% of the CL in an area of this site adjacent to the M25 at Wraysbury Reservoir. The area of exceedance is similar, but larger, than that for airborne ammonia. Summary of critical loads Two site features Anas Strepera (North-western Europe) – Gadwall and Anas clypeata (North- western/Central Europe) – Northern shoveler are both listed on APIS stating the species broad habitat sensitive to nitrogen. No critical load has been assigned on APIS as “no comparable habitat with established critical load estimate available”. APIS requires decision to be taken at a site-specific level since habitat sensitivity depends on Nitrogen or Phosphorus limitation. A CL of 10-20 kgN/ha-year has been assigned based on the presence of Neutral Grassland / Low and medium altitude hay meadows as listed in citations for the constituent SSSIs: Staines Moor, Wraysbury and Hythe, and Wrasybury No.1 gravel pit.

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Figure 4-18 Overview of screening results for nitrogen deposition at South West London Waterbodies Ramsar & SPA, assuming grassland deposition rates and a CL of 10, for Scenario B

Heathrow Airport Wraysbury

Feltham

Ashford

Thorpe Littleton M3

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Figure 4-19 Screening results for nitrogen deposition at South West London Waterbodies Ramsar & SPA, assuming grassland deposition rates and a CL of 10, for Scenario B

Stanwell Moor

Hythe End

Consideration of background concentrations According to APIS, the background levels for nitrogen deposition range from 15.54 to 17.78 kgN/ha/yr in areas with the broad habitat Standing open water and canals. The area predicted to receive increased rates of nitrogen deposition is situated within the Wraysbury Reservoir SSSI. The latest site condition assessment for this unit if the site was undertaken in 2012. The Water Framework Directive (WFD) status of Wraysbury Reservoir (GB30642417) indicates that there are existing issues with high levels of phosphorus with the WFD status for phosphorus listed as “Bad” in 2015. The reasons for high levels of total phosphorus are listed on the Environment Agency (EA) catchment data explorer website as Sewage discharge (continuous), Poor Livestock Management, Urbanisation - urban development, and Sewage discharge (intermittent). Sewage discharge is highlighted as having the greatest impact to the increased phosphorus levels of the water body. However, due to the absence of monitoring data it is unclear if the water body is nitrogen-limited or phosphorus / nitrogen co-limiting. The lowest CL of 10 kg N/ha/yr is exceeded by background concentrations, without any contribution from proposed developments included. The lowest CL has been used for screening purposes to provide a conservative estimate of adverse impacts on the site. Further analysis has been completed at Stage 2 to more accurately assess the impact of nitrogen deposition on the site.

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Atmospheric nitrogen is unlikely to be the largest source of this nutrient to eutrophic standing waters. Therefore, in general, nitrogen deposition is unlikely to be very harmful to eutrophic standing waters, even when close to sources. The maximum modelled increase in nitrogen deposition, at a rate of 0.203 kgN/ha-year (Table 4-16), equates to an increase in nitrogen concentration of 0.000069 mg/l/year within the reservoir. This assumes complete mixing within the water body and is a worst-case estimate based on accumulation of nitrogen with no throughflow of water during the year. This increase in nitrogen equates to 0.0046% of the WFD standard for nitrogen within standing waterbodies for unfavourable status (1.5 mg/l). The closest Environment Agency water quality monitoring data is available from the River Thames at the Windsor Leisure Centre site, located 4.2 km upstream of the reservoir intake at Datchet. The average total nitrogen concentration for the period 2010 to January 2020 at this site was 6.62 mg/l, indicating that there are likely to be elevated levels of nitrogen within Wraysbury Reservoir above the WFD standard for lakes, prior to any further development. The modelled increase in nitrogen deposition within Wraysbury Reservoir from the BLPSV-PC Scenario B represents an increase of 0.001% of the average nitrogen deposition concentration from the River Thames upstream of the reservoir intake. The above calculation of maximum predicted increases in nitrogen deposition within the Wraysbury reservoir due to Scenario B indicate that there would be a negligible increase in dissolved nitrogen. The increase in dissolved nitrogen concentrations of up to 0.000069 mg/l/year within the waterbody are highly unlikely to result in changes to algal or macrophyte communities within the reservoir and would not adversely affect the wintering bird populations that are qualifying features of the SPA. Therefore, there is no adverse effect on the integrity of the South West London Waterbodies SPA due to nitrogen deposition under Scenario B in isolation. The increase in nitrogen deposition will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat. 4.5.5 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. 4.5.5.1 HRA Stage 1 and Stage 2 appropriate assessment The screening results indicate that air quality impacts for all four pollutants are below the 1% screening threshold for Scenario C, when considering potential impacts on algal or macrophyte communities in the relevant water bodies. Therefore, likely significant effects from this development scenario can be discounted for all four pollutants in isolation. 4.5.5.2 In combination effects There is a theoretical risk that in-combination impacts from the boroughs of Runnymede and Rushmoor, could result in development contributions of any of the pollutants exceeding 1% of the CL. However, in view of the minimal impact due to the BLPSV-PC in isolation, it is concluded that there is no realistic prospect of any significant adverse effect on the integrity of the SPA due to the BLPSV-PC in combination with other plans and projects.

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4.6 Thames Basin Heaths SPA (UK9012141) 4.6.1 Background information and qualifying features Underlying Sites of Special Scientific Interest (SSSI): Ash to Brookwood Heaths SSSI; Bourley and Long Valley SSSI; Bramshill SSSI; Broadmoor to Bagshot Woods and Heaths SSSI; Castle Bottom to Yateley and Hawley Commons SSSI; Chobham Common SSSI; Colony Bog and Bagshot Heath SSSI; Eelmoor Marsh SSSI; Hazeley Heath SSSI; Horsell Common SSSI; Ockham and Wisley Commons SSSI; Sandhurst to Owlsmoor Bogs and Heaths SSSI; Whitmoor Common SSSI. The site qualifies under Article 4.1 of the Habitats Directive (79/409/EEC) as it is used regularly by 1% or more of the Great Britain populations of the following species listed in Annex I in any season:

Table 4-18 Qualifying features of the Thames Basin Heaths SPA Annex 1 species Count and season Period % of GB population Nightjar (Caprimulgus 264 churring males – breeding 1998/99 7.8% europaeus) Woodlark (Lullula 149 pairs – breeding 1997 9.9% arborea) Dartford warbler 445 pairs – breeding 1999 27.8% (Sylvia undata) Non-qualifying species of interest: Hen harrier (Circus cyaneus), merlin (Falco columbarius), short- eared owl (Asio flammeus), and kingfisher (Alcedo atthis) (all Annex I species) occur in non-breeding numbers of less than European importance (less than 1% of the GB population). The Site Improvement Plan (SIP 237)45 states that nitrogen deposition has been identified as a pressure/threat for the designated sites that form the Thames Basin complex.46 The supplementary advice for the SPA states that the target for air quality is to: “Restore as necessary the concentrations and deposition of air pollutants to at or below the site-relevant Critical Load or Level values given for this feature of the site on the Air Pollution Information System.” The conservation objectives for this site are to ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of the habitats of the qualifying features

• The structure and function of the habitats of the qualifying features • The supporting processes on which the habitats of the qualifying features rely • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site. 4.6.2 HRA Stage 1: Assessment of air quality impacts against screening thresholds This section comprises the outcome of the screening assessment described in Section 2.4.3. Table 4-15 summarises all of the critical loads for nutrient nitrogen deposition (kgN/ha-year) and acid deposition (kEq/ha-year), as well as the critical levels for airborne ammonia (µg/m3), applicable to this

45 Natural England (2014) Site Improvement Plan: Thames Basin (SIP237). Improvement Programme for England's Natura 2000 Sites (IPENS). Available at: http://publications.naturalengland.org.uk/file/5946121331408896. Accessed on 19th November 2019.

46 Site Improvement Plan 237 covers the Natura 2000 site(s) which form the Thames Basin complex: Thames Basin Heaths SPA, Thursley, Ash, Pirbright & Chobham SAC, Thursley, Hankley & Frensham Commons SPA.

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Table 4-19 Minimum Critical Load and Critical Level (CL) values and associated sensitive features for the Thames Basin Heaths SPA Minimum acid Minimum nutrient deposition CLs Minimum Sensitive feature Habitat nitrogen deposition (MinCLMaxN, airborne NH3 3 CLs (kgN/ha-year) kEq/ha-year) CLs (µg/m ) Nightjar Coniferous woodland 5-15 0.536 3 (Caprimulgus europaeus) Dry heath 10-20 0.862 3

Woodlark Coniferous woodland 5-15 0.536 3 (Lullula arborea) Dry heath 10-20 0.862 3 Dartford warbler Dry heath 10-20 0.862 3 (Sylvia undata) It is understood that Natural England is considering whether the minimum critical load for nitrogen deposition at this site should be increased from 5 kgN/ha-year (the minimum value for coniferous woodland) to 10 kgN/ha-year (the minimum value for lowland heaths). At this stage, the more demanding critical load of 5 kgN/ha-year was used in this assessment. 4.6.2.1 Consideration of in-combination effects HRA reports were identified for the following neighbouring authorities: • Bracknell Forest Borough Council. The Draft HRA Draft Bracknell Forest Local Plan report from January 2018 screened out the impacts from the BLPSV-PC on the Thursley, Ash, Pirbright and Chobham SAC. • London Borough of Hillingdon. A screening assessment of the Council’s Core Strategy published in 2014 screened out impacts on the Thames Basin Heaths SPA. • Reading Borough Council. A Screening Appropriate Assessment found that no significant effects on Natura 2000 sites were likely as a result of the Reading Borough Council Sites and Detailed Policies Document. • Runnymede Borough Council. An HRA of the updated Local Plan was published in May 2018, with a supplementary assessment of modifications published in December 2019. The findings of this HRA were taken into account in the present assessment of in-combination effects. • Rushmoor Borough Council. An HRA of the updated Rushmoor Borough Local Plan published in June 2017 concluded there were no likely significant effects on the Thames Basin Heaths SPA. The findings of this HRA were taken into account in the present assessment of in- combination effects. • Slough Borough Council (SBC). Not relevant to this assessment (see Section 4.1.2.1) • South Buckinghamshire Borough Council: An HRA screening assessment of the Chiltern and South Bucks Local Plan published in 2019 screened out impacts to the Thames Basin Heaths SPA. • Surrey Heath Borough Council. An HRA report for Draft Local Plan to 2032 Issues and Options Consultation 2018 concluded that the local plan is unlikely to lead to significant effects on the Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. No air quality modelling was undertaken as part of the May 2018 HRA for Surrey Heath draft BLPSV-PC but was scheduled to be included in a revised HRA. • Wokingham Borough Council. A scoping document published in August 2016 highlighted the need for consideration of potential air quality impacts of the borough Local Plan Update on air quality at Thames Basin Heaths SPA. Wokingham Borough Council has not yet carried out this HRA. • Wycombe District Council. An HRA screening report for the Local Plan published in September 2017 did not identify any potential significant effects to the SPA.

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• Spelthorne Borough Council: No HRA report was identified for Spelthorne Borough Council, and the Council does not have any work ongoing on this issue. Other major infrastructure development projects were identified from the National Infrastructure Planning website. The following potentially relevant projects were identified: • Heathrow airport development. Not relevant to this assessment (see Section 4.1.2.1) • Western Rail Link to Heathrow. The Initial Environmental Information Report (February 2016) indicates that there may be overall air quality benefits from implementation of the Rail Link. The rail link itself is located well away from the Natura 2000 sites under consideration, and consequently there are not likely to be any significant impacts from local traffic movements to and from Langley station. If anything, the rail link is likely to result in reductions in traffic movements on the key road links to and from Heathrow Airport, such as the M4 and M3. • M4 Junctions 3 to 12 Smart Motorway improvements. The Environmental Statement identified potential impacts at Thames Basin Heaths SPA and Thursley, Ash, Pirbright and Chobham SAC. Detailed assessment identified that the proposed development would have a nil to marginal net benefit on air quality at these locations, with the greatest forecast impact identified as a reduction of 0.2 μg/m3 in airborne NOx at Chobham Common SSSI. The assessment of the Borough Local Plan for Runnymede Borough Council found that the Runnymede Local Plan would result in a maximum increase of 3.3% of the critical level for airborne NOx, and a maximum increase of 0.4% of the critical load for nitrogen deposition at the closest point of the SPA to the local road network. No information in relation to airborne ammonia or acid deposition was provided. As set out in Section 4.6.4.3, where quantitative information was provided for the Runnymede Local Plan, it was possible to rule out the risk of in-combination impacts at this location. The assessment of the Borough Local Plan for Rushmoor Borough Council found that the Rushmoor Local Plan would result in a maximum increase of 0.7% of the critical load for nitrogen deposition at the closest point of the SPA to the local road network. No information in relation to airborne NOx, airborne ammonia or acid deposition was provided. As set out in Section 4.6.4.3, where quantitative information was provided for the Runnymede and Rushmoor Local Plans, it was possible to rule out the risk of in- combination impacts at this location. 4.6.2.2 Screening results Table 4-20 and Table 4-21 compare the maximum modelled contribution of Scenario B and Scenario C, respectively, to the lowest applicable CL. Values highlighted in yellow exceed the 1% screening threshold. This screening exercise represents a precautionary approach, as it assumes that the most sensitive qualifying features (with the lowest CLs) are present in the areas with the highest modelled contribution (typically adjacent to the busiest road).

Nitrogen deposition, acid deposition, airborne NOx and NH3 are all predicted to exceed the 1% screening threshold for Scenario B, in isolation. Nitrogen deposition and acid deposition are predicted to exceed the 1% screening threshold under both development scenarios, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these pollutants. A Stage 2 Appropriate Assessment has been undertaken in the following section.

Table 4-20 Screening results based on dispersion modelling of Scenario B Maximum modelled Pollutant Deposition type Minimum CL % of CL contribution Nutrient nitrogen deposition Forest 5 0.426 8.53% (kgN/ha-year) ͣ Grassland 5 0.257 5.13% Acid deposition (kEq/ha- Forest 0.536 0.304 5.67% year) ͣ Grassland 0.536 0.00631 1.18% Airborne NOx (µg/m3) N/A 30 1.15 3.84% 3 Airborne NH3 (µg/m ) N/A 3 0.0465 1.55% ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach.

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Table 4-21 Screening results based on dispersion modelling of Scenario C Maximum Maximum distance of Pollutant Deposition type Minimum CL modelled % of CL exceedance contribution from roadside / m Nutrient nitrogen Forest 5 0.138 2.76% 36 deposition (kgN/ha-year) ͣ Grassland 5 0.0887 1.77% NA Acid deposition (kEq/ha- Forest 0.536 0.0981 1.83% 19 year) ͣ Grassland 0.536 0.00631 1.18% NA Airborne NOx (µg/m3) N/A 30 0.233 0.78% NA 3 Airborne NH3 (µg/m ) N/A 3 0.0151 0.50% NA ͣ This site is characterised by some habitats with tall vegetation, therefore forest deposition rates were used as a precautionary approach. If the less demanding minimum critical load for nitrogen deposition of 10 kgN/ha-year were used in this assessment, there would still be exceedances of the threshold of 1% of this value. However, the area affected would be smaller. 4.6.3 HRA Stage 2: Appropriate assessment 4.6.3.1 Airborne NOx The relevant CL for Thames Basin Heaths SPA is 30 µg/m3 for all vegetation. Figure 4-20 illustrates the areas where the modelled contribution from the BLPSV-PC is predicted to exceed 0.3 µg/m3 (1% of 30 µg/m3) under Scenario B. There are three areas of exceedance; all are located adjacent to the B3430 at Bracknell (to the north of the site). Consideration of background concentrations Figure 4-21and Figure 4-22 show the results of the BLPSV-PC Scenario B overlaid with the 2030 background NOx concentrations from Defra47. The total predicted NOx concentrations were calculated as the sum of the forecast background concentrations of airborne NOx for 2030, and the modelled road contribution to airborne NOx from Scenario B. The maximum total predicted concentration from zonal statistics within Thames Basin Heaths SPA was 60.72 µg/m3, 202% of the CL. This maximum concentration likely coincides with the centre of a road (e.g. the M3 running through the centre of the site). However, within the area predicted to exceed the 1% screening threshold for airborne NOx, the maximum concentration from zonal statistics was 16.73 µg/m3, corresponding to 55.8% of the CL. On the basis of available evidence, the BLPSV-PC development scenarios will not result in an increase in NOx above the CL. As such, supporting processes (on which the feature relies) will not be affected and there will be no adverse effect on the integrity of this SPA. The increase in airborne NOx will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat.

47 https://laqm.defra.gov.uk/review-and-assessment/tools/background-maps.html

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Figure 4-20 Screening results for airborne NOx at Thames Basin Heaths SPA, for Scenario B

Bracknell

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Figure 4-21 Overview of screening results and total predicted concentrations for airborne NOx at Thames Basin Heaths SPA, for Scenario B

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Figure 4-22 Total predicted concentrations and areas predicted to exceed the 1% screening threshold for airborne NOx at Thames Basin Heaths SPA, for Scenario B

4.6.3.2 Airborne ammonia The relevant CL for Thames Basin Heaths SPA is 3 µg/m3 throughout the site for the broad habitat types Coniferous woodland and Dwarf shrub heaths. The CL is set for Higher plants on which the qualifying features (reproducing European nightjar, Wood lark and Dartford warbler) rely. Figure 4-23 illustrates the areas where the modelled contribution from Scenario B is predicted to exceed 0.03 µg/m3 (1% of 3 µg/m3). The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the M3 between Bagshot and Lightwater, and adjacent to the B3430 at Bracknell.

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Figure 4-23 Overview of screening results and PHI information for airborne NH3 at Thames Basin Heaths SPA, for Scenario B

Bracknell

Bagshot

Lightwater

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Consideration of background concentrations

According to APIS, the background levels for airborne NH3 at Thames Basin Heaths SPA (within the modelling domain) range from 1.01 to 1.61 µg/m3. The northernmost exceedance area identified in Figure 4-23 is within Unit 1 of the Colony Bog and Bagshot heath SSSI. The larger, more southern area of exceedance is within Unit 11 of Broadmoor to Bagshot woods and heaths SSSI. Both are constituent SSSIs of the Thames Basin Heaths SPA. As described in Section 4.3.3 for airborne ammonia exceedances within Thursley, Ash, Pirbright and Chobham SAC, the exceedance areas identified for ammonia in the Thames Basin Heaths SPA are likely to contain the Annex 1 habitats European dry heath and/or Northern Atlantic wet heaths with Erica tetralix (which are qualifying features of the SPA). The condition assessment for Unit 1 of the Colony bog and Bagshot heath SSSI (2017) identified that the unit is of value to breeding Dartford warbler and European nightjar, but that there is little suitable habitat for Wood lark. These species are qualifying features of the SPA; Dartford warbler and European nightjar are likely to be present with the ammonia exceedance area. The SSSI condition assessment for Broadmoor to Bagshot woods and heaths SSSI indicates that the Dartford warbler (Sylvia undata), European nightjar (Caprimulgus europaeus), and Wood lark (Lullula arborea) are present in Unit 11 so are potentially present within the NH3 exceedance area. The most recent monitoring data available for the populations of qualifying features of the SPA, undertaken in 2016, shows that the nightjar population is above that on which the SPA was established; the woodlark population is declining and below the level when the SPA was established; the Dartford warbler population had recovered to above designation levels in 2015 but reduced to below it in 2016.48

The total predicted NH3 concentrations were calculated as the sum of the 2013-2015 background NH3 concentrations from APIS, and the modelled road contribution to airborne NH3 from both development scenarios. The greatest total predicted concentration of airborne ammonia for Scenario B was 1.66 µg/m3, corresponding to 55.2% of the CL of 3 µg/m3. Therefore, there is no adverse effect on the integrity of this SPA due to airborne NH3 from Scenario B and Scenario C in isolation. The increase in airborne ammonia will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat. 4.6.3.3 Nitrogen deposition Figure 4-24 shows the areas where the modelled contributions from the BLPSV-PC development scenarios are predicted to exceed 0.05 kgN/ha-year (1% of the lowest CL). The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the B3430 at Bracknell and the M3 between Bagshot and Lightwater (Scenario B) as well as small areas adjacent to the M3 near Longshot Studios (Scenario C).

48 2Js Ecology (2016) Thames Basin Heaths Special Protection Area Annex 1 bird survey results [Online] Available at: https://surreyheath.moderngov.co.uk/documents/s8821/2016%20Thames%20Basin%20Heaths%20Special%20Protection%20Area%20Annex%2 01%20bird%20surv ey%20results.pdf. (Accessed December 2019)

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Figure 4-24 Overview of screening results for nitrogen deposition at Thames Basin Heaths SPA, assuming forest deposition rates and a CL of 5, for Scenarios B and C

Bracknell Sunningdale

Crowthorne

Lightwater

Woking

Farnborough

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Summary of critical loads The lowest CL is 5-15 kg N/ha/yr is set for Lullula arborea (Wood lark) in the broad habitat Coniferous woodland. For the same species, in the broad habitat Dwarf shrub heaths, a CL of 10-20 kgN/ha/yr is stated. A higher CL of 10-20 kg N/ha/yr is applicable for Caprimulgus europaeus (European nightjar) in the broad habitat Dwarf shrub heaths. It is also applicable for Sylvia undata (Dartford warbler) in the same broad habitat. The CL of 5-15 kg N/ha/yr is applicable for Caprimulgus europaeus (European nightjar) in the broad habitat Coniferous woodland, but APIS states that “no negative impacts are expected on the species due to impacts on the broad species habitat”. Consideration of background concentrations According to APIS, the background levels for nitrogen deposition range from 19.88 to 27.30 kgN/ha/yr in areas with the broad habitat Coniferous woodland. Figure 4-25 shows the nitrogen deposition exceedance areas for Scenario B. The exceedance areas are within Unit 1 of the Colony Bog and Bagshot heath SSSI and Unit 11 of Broadmoor to Bagshot woods and heaths SSSI, constituent SSSIs of the Thames Basin Heaths SPA. The area south of the M3 contains the habitat Dwarf shrub heath and supports populations of European nightjar and Dartford warbler, which are qualifying features of the SPA. The area north of the M3 contains coniferous woodland and dwarf shrub heath and is located in Unit 11 of Broadmoor to Bagshot woods and heaths SSSI, which is reported to support the wood lark, European nightjar, and Dartford warbler. The lowest CL of 5 kg N/ha/yr and the higher CL of 10 kg N/ha/yr are exceeded by background concentrations, without any contribution from proposed developments included. The exceedance areas identified for Scenario B are reported to support the qualifying features of the Thames Basin Heaths SPA, therefore, nitrogen deposition cannot be screened out in isolation under Scenario B. Figure 4-26 shows the nitrogen deposition exceedance areas for Scenario C. The exceedance areas north of the M3 are located in Units 12, 13, and 14 of Chobham Common SSSI. The majority of this area (east of the B383) is unsuitable for the species that are qualifying features of the SPA due to the site management; there is a fire break and an absence of functioning heathland adjacent to the motorway. The section west of the B383 contains heath and woodland and could potentially support qualifying species. The exceedance area south of the M3 is within Unit 15 of the Chobham SSSI; the Unit condition assessment identifies the presence of a mosaic of dry heath, wet heath, mire, and grassland, but gives no indication of distribution within the unit. The PHI identifies the presence of heathland and fen in the exceedance area, however, aerial imagery from 2018 and 2019 indicates that the habitats within the exceedance area are predominantly grassland with scattered scrub. These are not suitable to support the species that are qualifying features of the SPA. Although the CLs are exceeded by background concentrations, the areas of exceedance identified for nitrogen deposition under Scenario C do not support the qualifying features of the SPA. Therefore, there is no adverse effect on the integrity of this SPA due to nitrogen deposition for Scenario C in isolation. The increase in nitrogen deposition will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat.

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Figure 4-25 Screening results and PHI information available for nitrogen deposition at Thames Basin Heaths SPA, assuming forest deposition rates and a CL of 5, for Scenario B

Bracknell

Bagshot

Lightwater

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Figure 4-26 Screening results and PHI information available for nitrogen deposition at Thames Basin Heaths SPA, assuming forest deposition rates and a CL of 5, for Scenario C

Bagshot

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4.6.3.4 Acid deposition Figure 4-27 shows the areas where the modelled contributions from the BLPSV-PC development scenarios are predicted to exceed 0.00536 kgN/ha-year (1% of the lowest CL). The BLPSV-PC would result in a contribution above 1% of the CL in small areas of this site adjacent to the B3430 at Bracknell and the M3 between Bagshot and Lightwater (Scenario B) as well as small areas adjacent to the M3 near Longshot Studios (Scenario C). These areas of exceedance are almost identical to those identified for nitrogen deposition. Summary of critical loads For the broad habitat Coniferous woodland, the CL is 0.536 to 2.89 kEq/ha/yr for both Caprimulgus europaeus (European nightjar) and Lullula arborea (Wood lark). For the broad habitat Dwarf shrub heath, the CL is 0.862 to 2.344 kEq/ha/yr and shared by: Caprimulgus europaeus (European nightjar), Lullula arborea (Wood lark) and Sylvia undata (Dartford warbler). According to APIS, no negative impacts are expected on any of the site’s interest features / species due to impacts on the species’ broad habitat. Therefore, there is no adverse effect on the integrity of this SPA under either of the two development scenarios. The increase in acid deposition will not result in an overall habitat loss and, as such, will not affect the extent and distribution of the supporting habitat.

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Figure 4-27 Overview of screening results for acid deposition at Thames Basin Heaths SPA, assuming forest deposition rates and a CL of 0.536, for scenario B and C

Bracknell Sunningdale

Crowthorne

Lightwater

Woking

Farnborough

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4.6.4 Conclusions As discussed at the beginning of Section 4, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. Although information is provided on Scenario B for completeness, the conclusions below relate only to Scenario C. In particular, Scenario C shows no exceedances in the region located south of Bracknell, along the B3430 which was identified by the Scenario B analysis. The risk of a likely significant effect at this location due to the BLPSV-PC can therefore be screened out. 4.6.4.1 Stage 1 Screening

The screening results indicate that air quality impacts for airborne NOx and airborne NH3 associated with the BLPSV-PC, in isolation, are below the 1% screening threshold for Scenario C. Nitrogen deposition and acid deposition are predicted to exceed the 1% screening threshold for Scenario C, in isolation. Therefore, likely significant effects from air quality impacts cannot be ruled out for these pollutants. A stage 2 appropriate assessment within the exceedance zones identified at the screening stage was carried out: 4.6.4.2 Stage 2 appropriate assessment Nitrogen deposition: There is one area of exceedance for Scenario C, located in the north east of the site. Although the CLs are exceeded, the SPA’s qualifying features are unlikely to be present in these areas of exceedance as the areas do not provide any supporting habitat for the features. This was consistent with the findings of the site walkover survey described in Section 4.3. Therefore, there is no adverse effect on the integrity of this SPA due to nitrogen deposition for Scenario C in isolation. Acid deposition: The area of exceedance is very similar to that identified for nitrogen deposition, although it is smaller. According to APIS, no negative impacts are expected on any of the site’s interest features / species due to impacts on the species’ broad habitat. Therefore, there is no adverse effect on the integrity of this SPA due to acid deposition for Scenario C. 4.6.4.3 In-combination effects The assessment of the Borough Local Plan for Runnymede Council found that the Runnymede Local Plan would result in a maximum increase of 3.3% of the critical level for airborne NOx, and a maximum increase of 0.4% of the critical load for nitrogen deposition at the closest point of the SPA to the local road network. No information in relation to airborne ammonia or acid deposition was provided. The assessment of the Borough Local Plan for Rushmoor Borough Council found that the Rushmoor Local Plan would result in a maximum increase of 0.7% of the critical load for nitrogen deposition at the closest point of the SPA to the local road network. No information in relation to airborne NOx, airborne ammonia or acid deposition was provided. Baseline levels of NOx are forecast to comply with the air quality guideline at the Thames Basin Heaths SPA by 2030, with a maximum concentration of 55.8% of the air quality guideline. The maximum in- combination increment from the RBWM and Runnymede Local Plans is 4.1% of the air quality guideline. In view of the forecast margin of compliance in 2030, and the relatively small in-combination increments from the RBWM and Runnymede Councils’ Local Plans, it is concluded that there is no adverse effect on the integrity of this SPA due to airborne NOx associated with the BLPSV-PC development scenarios in combination with other plans and projects. The maximum in-combination increment to nitrogen deposition from the RBWM, Runnymede and Rushmoor Local Plans is 2.0% of the air quality guideline. This in-combination increase could potentially affect the immediate vicinity of the M3 motorway, in similar areas to those assessed above in relation to potential impacts due to acid and nitrogen deposition. The site surveys confirmed that the SPA’s qualifying features are not present in the areas of exceedance surveyed. It is concluded that

Ref: Ricardo/ED13199100/Issue Number 6 Ricardo Energy & Environment Air Quality Assessment for RBWM BLPSV-PC Review | 112 there is no adverse effect on the integrity of this SPA due to nitrogen deposition from the BLPSV-PC in combination with the Runnymede and Rushmoor Local Plans at this SPA. No quantitative information was provided in the Runnymede Council HRA for acid deposition or ammonia, or in the Rushmoor Borough Council HRA for acid deposition, airborne ammonia or airborne NOx. However, the results for airborne NOx and nitrogen deposition set out above indicate that there is no significant risk of in-combination impacts due to the pathways that were assessed by the other authorities. As a result, it is concluded that there is no significant adverse effect on the integrity of the Thames Basin Heath SPA resulting from in-combination airborne NOx, airborne ammonia or acid deposition pathways.

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5 Summary of HRA results and conclusions

For ease of reference, the overall results of the HRA are summarised in the table below. As discussed, it is appropriate to use the air quality impacts from Scenario C to assess the impacts of the BLPSV-PC against the habitats regulations. This is because the transport mitigation schemes included in Scenario C are required to mitigate the impact of the RBWM BLPSV-PC on highways and road junctions and do not include any mitigation which may be needed to mitigate the impact of the BLPSV-PC on European sites or other nature conservation sites. The air quality impacts from Scenario B are not included in this table.

Table 5-1 Summary of HRA results for impacts from the RBWM BLPSV-PC Scenario C (SC) in isolation

Designated Site Nitrogen deposition Acid deposition Airborne NOx Airborne NH3 Burnham Conclusions: Conclusions: Conclusions: Conclusions: Beeches (SAC) Screened out at HRA Stage 1. Screened out at HRA Stage 1. Screened out at HRA Stage 1. Screened out at HRA Stage 1. HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects (the SC contribution does not (the SC contribution does not (the SC contribution does not (the SC contribution does not exceed 1% of the lowest exceed 1% of the lowest exceed 1% of the Critical Level) in exceed 1% of the lowest applicable Critical Load) in applicable Critical Load) in isolation. applicable Critical Level) in isolation. isolation. isolation. Chilterns Conclusions: Conclusions: Conclusions: Conclusions: Beechwoods Screened out at HRA Stage 2 Screened out at HRA Stage 1. Screened out at HRA Stage 2. Screened out at HRA Stage 2. (SAC) based on advice from Natural HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects England and consideration of (the SC contribution does not (the total modelled airborne NOx (NE advice states Lichens and woodland edge habitat. exceed 1% of the lowest under SC does not exceed 100% Bryophytes would not be applicable Critical Load) in of the Critical Level) in isolation. adversely affected by increased

isolation. airborne NH3 if they are present; using a higher Critical Level of 3 µg/m3 the total modelled airborne NH3 under SC does not exceed 100% of the applicable Critical Level in isolation.) Thursley, Ash, Conclusions: Conclusions: Conclusions: Conclusions: Pirbright & Screened out at HRA Stage 1. Screened out at HRA Stage 2. Screened out at HRA Stage 1. Screened out at HRA Stage 2. Chobham (SAC) HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects

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Designated Site Nitrogen deposition Acid deposition Airborne NOx Airborne NH3 (the SC contribution does not (the SC contribution exceeds 1% (the SC contribution does not (lichens and bryophytes found not exceed 1% of the lowest of the lowest applicable Critical exceed 1% of the Critical Level) in to be important components of applicable Critical Load) in Load but a site survey of the area isolation. the site in the areas at risk of isolation. confirmed no qualifying features impacts. Using a higher Critical were present) in isolation. Level of 3 µg/m3 the total modelled airborne NH3 under SC does not exceed 100% of the applicable CL in isolation. Windsor Forest & Conclusions: Conclusions: Conclusions: Conclusions: Great Park (SAC) Screened out at HRA Stage 1. Screened out at HRA Stage 1. Screened out at HRA Stage 2. Screened out at HRA Stage 1. HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects (the SC contribution does not (the SC contribution does not (the SC contribution exceeds 1% (the SC contribution does not exceed 1% of the lowest exceed 1% of the lowest of the Critical Level but the total exceed 1% of the lowest applicable Critical Load) in applicable Critical Load) in modelled airborne NOx does not applicable Critical Level) in isolation. isolation. exceed 100% of the Critical isolation. Level) in isolation. South West Conclusions: Conclusions: Conclusions: Conclusions: London Screened out at HRA Stage 1. N/A – Site is not sensitive to acid Screened out at HRA Stage 1. Screened out at HRA Stage 1. Waterbodies HRA indicates no adverse effects deposition. HRA indicates no adverse effects HRA indicates no adverse effects (Ramsar & SPA) (the SC contribution does not (the SC contribution does not (the SC contribution does not exceed 1% of the lowest exceed 1% of the Critical Level) in exceed 1% of the lowest applicable Critical Load) in isolation. applicable Critical Level) in isolation. isolation. Thames Basin Conclusions: Conclusions: Conclusions: Conclusions: Heaths (SPA) Screened out at HRA Stage 2. Screened out at HRA Stage 2. Screened out at HRA Stage 1. Screened out at HRA Stage 1. HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects HRA indicates no adverse effects in isolation (the SC contribution (no negative impacts are (the SC contribution exceeds 1% (the SC contribution does not exceeds 1% of the Critical Load expected on site interest features of the Critical Level but the total exceed 1% of the lowest but the areas of exceedance are species due to impacts on the modelled airborne NOx does not applicable Critical Level) in unlikely to support the SPA’s species’ broad habitat). exceed 100% of the Critical isolation. qualifying features). Level) in isolation.

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Table 5-2 Developments that could contribute to potential in-combination effects with the RBWM BLPSV-PC Plans and projects which were identified as Findings of in-combination assessment Designated Site having potential for in-combination effects Burnham Beeches (SAC) No adverse impact from BLPSV-PC, so there is no in-combination effect Chiltern Beechwoods (SAC) None No significant risk of in-combination effects identified from any other plans or projects Thursley, Ash, Pirbright & Runnymede and Rushmoor development plans No significant in-combination effects due to airborne NOx or nitrogen Chobham (SAC) deposition. No significant risk of in-combination effects due to airborne ammonia or acid deposition Windsor Forest & Great Park (SAC) Runnymede development plan No significant in-combination effects due to airborne NOx or nitrogen deposition. No significant risk of in-combination effects due to airborne ammonia or acid deposition South West London Waterbodies Impact of BLPSV-PC is so small that there is no plausible in-combination effect (Ramsar & SPA) Thames Basin Heaths (SPA) Runnymede and Rushmoor development plans No significant in-combination effects due to airborne NOx or nitrogen deposition. No significant risk of in-combination effects due to airborne ammonia or acid deposition

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Appendices

Appendix 1 Air dispersion model verification and adjustment

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Appendix 1 - Air dispersion model verification and adjustment Verification of the model involves comparison of the modelled results with local monitoring data at relevant locations; this helps to identify how the model is performing and if any adjustments should be applied. The verification process involves checking and refining the model input data to try and reduce uncertainties and produce model outputs that are in better agreement with the monitoring results. This can be followed by adjustment of the modelled results if required. The LAQM.TG(16) guidance recommends making the adjustment to the road contribution of the pollutant only and not the background concentration these are combined with. The approach outlined in LAQM.TG(16) section 7.508 – 7.534 (also in Box 7.14 and 7.15) has been used in this case. To verify the model, the predicted annual mean Road NOx concentrations were compared with concentrations measured at the various monitoring sites during 2016. The model output of Road NOx (the total NOx originating from road traffic) was compared with measured Road NOx, where the measured Road NOx contribution is calculated as the difference between the total measured NOx and the background NOx value. Total measured NOx for each monitoring site was calculated from the measured NO2 concentration using Version 6.1 of the Defra 49 NOx/NO2 calculator available from the LAQM website . Background NOx values for 2016 were obtained from the background maps available on the LAQM website. The most up to date background maps used a 2017 base year. A 2017 base year background map was not available for 2016. A 2017- based 2016 background map was generated by applying a specific scaling factor to every 1 km x 1 km grid square of the 2015-based 2016 background map. The scaling factor was derived using the differences between the 2015-based 2016 map and 2017-based 2016 map. NOx contributions arising from major roads were removed from the background map values to avoid double-counting, and the background values were then added to the RapidAIR road NOx results to compare the modelled vs measured concentrations at each of the monitoring locations. The initial comparison of the modelled vs measured Road NOx identified that the model was under- predicting the Road NOx contribution at most locations. Refinements were subsequently made to the model inputs to improve model performance where possible. The gradient of the best fit line for the modelled Road NOx contribution vs. measured Road NOx contribution was then determined using linear regression and used as a global/domain wide Road NOx adjustment factor. This factor was then applied to the modelled Road NOx concentration at each discretely modelled receptor point to provide adjusted modelled Road NOx concentrations. A linear regression plot comparing modelled and monitored Road NOx concentrations before and after adjustment is presented in Figure A1-1. A primary NOx adjustment factor (PAdj) of 2.4733 based on model verification using all of the included 2016 NO2 measurements was applied to all modelled Road NOx data prior to calculating an NO2 annual mean.

The total annual mean NO2 concentrations were then determined at points within the model domain using the NOx/NO2 calculator to combine background and adjusted road contribution concentrations. For this step of the process, regional concentrations of ozone, oxides of nitrogen and nitrogen dioxide were set to those of the local authority where the calibration point was located. The following relationship was determined for conversion of total NOx concentrations to total NO2 concentrations:

3 3 2 3 (NO2 in µg/m ) = – 0.0006514 (NOx in µg/m ) + 0.5175 (NOx in µg/m ) + 4.9746

A plot comparing modelled and monitored total NO2 concentrations during 2016 is presented in Figure A1-1.

49 https://laqm.defra.gov.uk/review-and-assessment/tools/background-maps.html

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To evaluate the model performance and uncertainty, the Root Mean Square Error (RMSE) for the observed vs predicted NO2 annual mean concentrations was calculated, as detailed in Technical Guidance LAQM.TG(16). The calculated RMSE is presented in Table A1-1. In this case the RMSE was calculated at 7.95 µg/m3.

Figure A1-1 Predicted annual average NO2 concentrations against measured concentrations at monitoring locations. The 30% confidence intervals are also plotted.

Table A1-1 Modelled and measured NO2 concentrations for the 2016 reference year and calculated RMSE value NO2 annual mean in 2016 Site ID Easting Northing Measured Modelled MW1 488626 180994 43.0 35.7 MM2 495664 176592 39.0 44.1 MW4 488503 182710 18.0 21.7 WM1 494067 176764 18.5 18.2 WM2 489807 178760 27.6 31.8 WM5 488753 180997 44.2 30.9 WM5a 488852 180949 44.5 31.1 WM8 487982 182307 18.8 20.9 WM9 496179 176330 25.3 24.0 WM10 495613 176434 37.1 37.1 WM11 498685 174370 32.9 32.2 WM13 502017 172541 37.1 38.2 WM13a 502108 172461 39.7 45.3 WM15 502259 172322 44.7 52.1

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NO2 annual mean in 2016 Site ID Easting Northing Measured Modelled WM15a 502257 172333 42.7 51.9 WM15b 502300 172278 38.5 47.5 WM18 495664 176592 35.7 44.1 WM19 495664 176592 36.4 44.1 WM20 495664 176592 36.0 44.1 WM21 488626 180994 41.4 35.7 WM22 488626 180994 39.5 35.7 WM23 488626 180994 41.9 35.7 WM28 496604 177866 34.3 34.2 WM28a 496539 177826 35.5 30.2 WM29 489975 178721 53.4 42.7 WM29a 489928 178754 45.2 38.3 WM29b 490060 178593 41.2 44.5 WM29d 490078 178541 25.6 33.5 WM31 495896 176939 39.3 28.5 WM32 496082 176903 34.2 26.2 WM33 496312 176886 40.6 26.3 WM01 501366 172377 18.6 21.3 WM03 495331 175569 40.3 31.5 WM03a 495294 175556 47.4 31.4 WM03b 495314 175551 48.8 30.9 WM03c 495413 175587 25.3 24.1 WM04 496631 175927 34.8 23.1 WM012 488525 182471 27.1 28.5 WM013 489571 181334 32.2 33.9 WM013a 489652 181323 44.0 34.1 WM014a 489033 180622 31.7 37.7 RMSE 7.95

Ref: Ricardo/ED13199100/Issue Number 6

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