Deane Core Strategy Levels and Moors Habitat Regulations Assessment May 2011 OS: (c) Crown Copyright and database rights 2011 Ordnance Survey 100019499 Taunton Deane Borough Council

Photos: Photos supplied by Patryk Koniuszewski of PJK Photography

SUMMARY

The need for this assessment arises from the EC Habitats Directive (92/43/EEC) and its implementation in the UK under The Conservation of Habitats and Species Regulations 2010 (as amended) (the ‘Habitats Regulations’ – previously the Conservation (Natural Habitats &c.) Regulations 1994 (as amended)). Habitats Regulations Assessment is required for any plan or project which, either alone or in combination with other plans/projects, could have a significant effect on the integrity of an international site (one that forms part of the Natura 2000 network, or a Ramsar site) and which is not directly connected with the sites management.

Royal Haskoning has previously undertaken a scoping assessment of several Somerset Authorities’ developing Land Use Plans (Royal Haskoning, 2009), including Taunton Deane, Mendip, and Councils and . In the case of Taunton Deane Borough Council, Royal Haskoning’s remit was to consider the potential impacts of the Core Strategy Local Plan and Emerging Allocations Report upon the and Moors and international sites. The aim of that report was to identify policies and options which could potentially have a significant impact on these sites. It also determined the nature of the likely impacts, and recommended, where appropriate, mitigation and avoidance measures.

This report represents an assessment of the final suite of policies within Taunton Deane Borough Councils Published Plan Core Strategy. A preliminary assessment of the policies concluded that two did have at least the potential to affect international sites. These were taken through to the detailed assessment stage. The policies were:

• Policy CP4: Housing; and • Policy SP1: Sustainable Development Locations.

Through discussion with Natural and other consultees, and based on the interest features of the international sites, there are two potential mechanisms by which the Taunton Deane Published Plan Core Strategy could impact the Somerset Levels and Moors. These impacts form the focus of the more detailed ‘Appropriate Assessment’ to determine whether the policies identified could have an adverse effect on the integrity of the international sites. The impacts are:

• increased recreational disturbance; and • increased water quality impacts.

Following detailed consideration, we believe it is possible to conclude that these two policies, and therefore the core strategy as a whole, would not, either alone or in- combination with other plans and programmes, result in adverse effects on the integrity of the Somerset Levels and Moors international sites. We anticipate that the findings of the HRA will remain robust unless material changes are made as a result of the public consultation, and subsequent Examination in Public. Where material changes are required, we recommend that a re-assessment of the findings of this report is carried out to confirm that its conclusions remain valid and that the Core Strategy for adoption remains compliant with the Habitats Regulations.

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CONTENTS

Page

1 INTRODUCTION 1 1.1 Stage 1 Report 2 1.2 Structure of the Report 2

2 METHODOLOGY 3 2.1 Application of Habitat Regulations Assessment to Land Use Plans 3 2.2 Habitats Regulations Assessment Methodology 3 2.3 Our Methodology 5 2.4 In-combination Assessment 5 2.5 Consultation 5

3 SITES AND FEATURES 7 3.1 Somerset Levels and Moors Special Protection Area 7 3.2 Somerset Levels and Moors Ramsar 7 3.3 Site Condition and Management Objectives 11

4 TEST OF LIKELY SIGNIFICANT EFFECT (LSE) 12 4.1 Results of the Stage 1 Report 12 4.2 Assessment of the Published Plan Core Strategy 13 4.3 Summary 18

5 IMPACTS ASSOCIATED WITH POLICIES 19 5.1 Recreational Disturbance 19 5.2 Reduced Water Quality and Impacts upon Invertebrate Species 24

6 THE ALONE ASSESSMENT 30 6.1 Policy CP4: Housing 30 6.2 Policy SP1: Sustainable Development Locations 31 6.3 The Draft Core Strategy – Assessment at the Plan Level 31

7 IN-COMBINATION ASSESSMENT 32 7.1 Other Plans and Strategies 32 7.2 Conclusion 35

8 CONCLUSION AND NEXT STEPS 36 8.1 Conclusions of the HRA Process 36 8.2 Further Activities and Recommendations 36 8.3 Next Steps 36

9 REFERENCES 37 APPENDIX A: Detailed Assessment Tables 38 APPENDIX B: Water Sewage Treatment Works information 44

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1 INTRODUCTION

This report provides the conclusions of a technical review to support a Habitats Regulations Assessment (HRA) for Taunton Deane Borough Council Published Plan Core Strategy 2011 to 2028.

The need for this assessment arises from the EC Habitats Directive (92/43/EEC) and its implementation in the UK under the Conservation of Habitat and Species Regulations 2010 (as amended) (previously the Conservation (Natural Habitats &c.) Regulations 1994, as amended)). HRA is required under Regulation 61 (1) of The Conservation of Habitat and Species Regulations 2010 for a plan or project not directly connected with the management of an international site1 which may have an adverse effect on the integrity of that site, either alone or in combination with other plans or projects.

This document presents an assessment of the policies detailed within Taunton Deane Borough Council’s Published Plan Core Strategy. It identifies whether these policies, either alone or in-combination with other plans or policies, are likely to have a significant effect on international sites. Where such an effect is identified, the ‘Appropriate Assessment’ stage (Section 6) considers whether the effect will have, or lead to, an adverse effect on the integrity of those sites.

The final Appropriate Assessment is a decision by the 'competent authority', in this case Taunton Deane Borough Council, as to whether the proposed Core Strategy can be determined as not having an adverse effect on the integrity of any international sites. Planning Policy Guidance Note 9 (PPG9, the precursor to PPS9) (Department of the Environment, 1994) defined a site’s integrity as the ‘coherence of the site’s ecological structure and function, across its whole area, or the habitats, complex of habitats and/or population of the species for which the site is classified’. The regulations state that impacts should be assessed against sites’ Conservation Objectives. More information is provided in Section 3.3.

Building on a previous scoping study (Royal Haskoning, 2009) this assessment is focussed on the

• Somerset Levels and Moors Special Protection Area (SPA); and • Somerset Levels and Moors Ramsar.

Other international sites, including Special Area of Conservation (SAC) and and Quantocks Oak Woodlands SAC, that fall within the ‘zone of influence’ of Taunton Deane Borough’s Core Strategy are being assessed in separate work undertaken by Somerset County Council.

1 Special Areas of Conservation (SAC, or candidate Special Area of Conservation (cSAC)), designated under the Habitats Directive, and Special Protection Areas (SPA) designated under the Birds Directive (79/409/EEC), form part of the EU-wide Natura 2000 network. UK Government policy (PPS9 and Circular 06/05) requires that ‘Ramsar sites’, designated under the (The Convention on of International Importance, especially as Waterfowl Habitat) are subject to the same provisions. This definition encompasses those European sites below the high tide mark (whether SPA or SAC) which, following the updated nomenclature used in the Marine and Coastal Access Act 2009, are referred to as European Marine Sites. The term international sites will be used throughout this report when referring to these designated sites.

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1.1 Stage 1 Report

In 2009, Royal Haskoning produced a Scoping Report considering several Somerset authorities’ developing Land Use Plans2 (Royal Haskoning, 2009). Its aim was to identify those policies and options in the documents that were likely to or could potentially have a significant impact on any international site.

The full list of policies from the Taunton Deane Borough Council Local Plan and Emerging Allocations were appraised and it was determined that some policies and options could have the potential for significant effect on the Somerset Levels and Moors and Severn Estuary international sites3. A more detailed technical assessment was undertaken with regard to effects of the policies on international sites against the conservation objectives for each of the sites. Further detail on the findings of the Stage 1 Report can be found in Section 4.1.

1.2 Structure of the Report

The report is structured as below:

• Section 2 Methodology • Section 3 Sites and features • Section 4 Test of Likely Significant Effect • Section 5 Impacts associated with policies • Section 6 The alone assessment • Section 7 In-combination assessment • Section 8 Conclusion and next steps • Section 9 References

2The strategy documents covered by the Stage 1 report were: • Taunton Deane Local Plan and Emerging Allocations (2009); • Council Core Strategy Issues and Options Report; • Sedgemoor District Council Core Strategy Issues and Options Report; • South Somerset District Council Core Strategy Issues and Options Report; and • Somerset County Council Minerals Plan. 3 The Severn Estuary international sites are not considered in this report, due to the nature of the policies within the Published Plan Core Strategy and the distance between the Borough and the site.

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2 METHODOLOGY

This section outlines the general HRA methodology and the process that was undertaken for this technical report.

2.1 Application of Habitat Regulations Assessment to Land Use Plans

Following a European Court of Justice ruling in 2005, which determined that the had not transposed the Habitats Directive into law in the correct manner, Land Use Plans have been subject to HRA to determine impacts on sites designated under the Habitats and Birds Directives. The 2010 Habitats Regulations revision now includes provisions for Land Use Plans.

HRA is considered to be a risk-based assessment, drawing on available information. The Department for Communities and Local Government (DCLG) has produced draft guidance on carrying out Appropriate Assessment for the protection of International sites for Regional Planning Bodies and Local Planning Authorities (DCLG, 2006). It addresses determining the need for an Appropriate Assessment for a given plan and the provision of an assessment if one is required. The documents: “Planning for the Protection of European Sites: Appropriate Assessment” (DCLG, 2006) and “The Assessment of Regional Spatial Strategies under the Provisions of the Habitats Regulations – Draft Guidance” (English Nature, 2006), provide a cohesive source of guidance for assessments. Further documents which have provided scope to this work are the Royal Society for the Protection of Birds (RSPB) publication “The Appropriate Assessment of Land Use Plans in England” (2007) and the more recent guidance for competent authorities (Tyldesley and Hoskin 2008).

2.2 Habitats Regulations Assessment Methodology

The general process of a HRA is shown in Figure 2.1. Initially an assessment is undertaken of whether the policies and land allocations from a core strategy have the potential to have a Likely Significant Effect (LSE), either alone or in-combination, upon the relevant international sites. Those policies that can be scoped out of the further assessment stages are deemed suitable for inclusion in the core strategy.

Policies which are determined to have an LSE are taken through to the ‘Appropriate Assessment’ stage. This involves a more detailed review of the policies or land allocations and assessing their potential impacts on the integrity of the international sites against information gathered on the condition of the site, and any further details concerning the likely impact.

If it can not be concluded at this stage that the policies will not have an adverse impact on the international sites then mitigation or avoidance measures must be developed and specified which can be used to prevent any declines in the condition of the site or sites in question.

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Figure 2.1. The Habitats Regulations Assessment Process

However, any policies for which mitigation or preventative measures cannot be established should be reconsidered and alternatives proposed. If the policy lacks a viable alternative it is necessary to consider whether the policy is required. Guidance issued by the Department of Central and Local Government (DCLG) in 2006 states:

“After mitigation measures have been exhausted on an emerging option and it is shown to still have a potentially negative effect on the integrity of a European site, and in absence of any other alternative solution, as a rule the option should be dropped.

In the exceptional circumstance and as an exception to that rule, if the pursuit of the option is justified by ‘imperative reasons of overriding public importance (IROPI)’ consideration can be given to proceeding in the absence of alternative solutions. In these cases compensatory measures must be put in place to offset negative impacts”.

In circumstances where IROPI prevails, the Secretary of State has to be shown that there were no possible mitigation measures or alternatives solutions that would negate the adverse effects on the international site(s), along with either of the following:

• That the plan is being undertaken for reasons relating to human health, public safety or beneficial consequences of primary importance to the environment; and /or • That the plan is being undertaken for imperative reasons of overriding public interest.

Mitigatory or compensatory measures must also be carried out if proceeding with a plan or policy that is likely to have adverse impacts on an international site. Consultation is required with the appropriate Government department throughout this process to ensure the overall integrity of the international site network is not detrimentally impacted.

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2.3 Our Methodology

Throughout Taunton Deane’s policy development process the HRA team have worked closely with the Council and have been involved in assessing and reviewing draft policies. This contribution, together with discussions with and Somerset County Ecologist, has aided the design and refinement of the final policy suite.

Taunton Deane Borough Council conducted public consultation under Regulation 25 in January and February 2010 on its Core Strategy and Small Sites document. Following consideration of the consultation response, a suite of policies forming its Draft Core Strategy was prepared. These policies form the focus of this technical report. Policies considered to have at least the potential for an LSE are considered in detail. This assessment of the policy suite suggests feasible measures, supported by available guidance and best practice, by which Taunton Deane Borough Council can mitigate and/or avoid any impacts.

2.4 In-combination Assessment

As well as considering the direct and in-direct impacts of policies, they must also be considered with other policies or plans in an ‘in-combination’ assessment. Policies which, in isolation, have been assessed as having no LSE could have a significant effect when considered collectively.

An in-combination assessment of the Core Strategy in relation to other plans and projects within the District and the wider county has been undertaken and is detailed separately in Section 7 of this report.

2.5 Consultation

Consultation was undertaken with various external parties during the scoping study in 2009, and ongoing liaison with Natural England, , Taunton Deane Borough Council and Somerset County Council has taken place throughout this report.

A summary of the consultation undertaken is provided in Table 2.1 below.

Table 2.1. Summary of Consultation Responses

Consultee Response/Key Comments Natural England • Recreational disturbance problems are considered to be low level issues on the Somerset Levels and Moors. • Somerset Wildlife Trust is concerned about access issues at Moor. Visitors come from all over the country to see the flocks of starlings in winter time. • Visitors will predominantly use the sites with car parks. • Significant issue if wind turbines are located in flyways. Data needed on links between coast and Levels and movement through the Levels.

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Consultee Response/Key Comments Wessex Water • Development of the Core Strategy options, and the new housing provision therein, can be supported with existing water treatment works capacity Somerset County • Where people are coming from to visit the international sites is Council Ecologist more important than numbers. Locals are more likely to be dog walking. RSPB • The associated increase in dogs caused by an increase in residential property is an issue. • Mitigation could include the distribution and size of car parks, which control numbers accessing the sites. Also, parking should be stopped elsewhere, e.g. in wide splays.

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3 SITES AND FEATURES

This section provides information on the Somerset Levels and Moors international sites, highlighting the interest features that form the basis for the designations. The location of the Somerset Levels and Moors, local settlements, rivers and main roads are shown on Figure 3.1.

The Somerset Levels and Moors is considered to be one of the most important lowland landscapes in Britain, with much of the basin lying at between 2m and 7m above Ordnance Datum (English Nature, 1997). The site is designated as both an SPA and a Ramsar site. Further details of the SPA and Ramsar sites, detailing all interest features, are given in the assessment tables at Appendix A.

The component Sites of Special Scientific Interest (SSSIs) that are considered to be potentially affected by the Taunton Deane Published Plan Core Strategy are detailed below:

• - 474.62ha; • West Sedge Moor - 1020.83ha; • South Lake Moor - 197.01ha; and • King's Sedgemoor - 831.49ha.

Figures 3.2 and 3.3 shows the condition of these SSSIs.

3.1 Somerset Levels and Moors Special Protection Area

The Somerset Levels and Moors SPA is approximately 6,400 hectares and comprised of 12 SSSIs. The site provides a range of habitats (e.g. grassland, marshland, standing water and ) which support over-wintering bird populations. The species for which the site is designated as an SPA are teal (Anas crecca), Bewick’s swan (Cygnus columbianus bewickii), golden plover (Pluvialis apricaria) and lapwing (Vanellus vanellus).

3.2 Somerset Levels and Moors Ramsar

The Somerset Levels and Moors Ramsar site is designated due to the presence of 17 Red Data Book invertebrates, which are supported by the large network of ditches present. The site also receives large numbers of over-wintering wildfowl, estimated to be approximately 97,000 individuals. As with the SPA, the site is also designated for the presence of Bewick’s swan, teal and lapwing.

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3.3 Site Condition and Management Objectives

Much of the data available for assessing the condition of international sites relates to the component SSSIs rather than features of the international site. SSSI condition is a useful tool for assessing international sites and identifying whether issues relevant to the HRA are resulting in unfavourable conditions on the site. Natural England produces Conservation Objectives for all SSSIs, which relate to maintaining the features for which the site was designated. These objectives can therefore be transferred to the wider, international site.

The overarching generic objective for all sites is:

“subject to natural change, maintain the site in favourable condition”.

More specific objectives for each site are provided in favourable condition tables. These detail targets and thresholds for a range of environmental and biological parameters which should be met in order to attain favourable condition. This is synonymous with attaining or maintaining site integrity.

For qualifying species (SPAs), Conservation Objectives can be generalised as:

• To avoid deterioration of the habitats of the qualifying species or significant disturbance to the qualifying species, thus ensuring that the integrity of the site is maintained; and • To ensure for the qualifying species that the following are maintained in the long term: o Populations of the species as a viable component of the site; o Distribution of the species within the site; o Distribution and extent of habitats supporting the species; o Structure, function and supporting processes of habitats supporting the species; and o No significant disturbance of the species.

These Conservation Objectives, along with those provided by Natural England that are specific to the features of the international sites (see Appendix A for a full breakdown), have been used to assess the potential impact the Core Strategy policies may have upon the integrity of the sites.

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4 TEST OF LIKELY SIGNIFICANT EFFECT (LSE)

This section undertakes an assessment of the Published Plan Core Strategy and identifies whether the policies are likely to have, or have the potential for, a significant effect on the international sites. It updates previous assessments carried out in the early scoping report. Whilst HRA assesses at the ‘plan level’, each policy is initially considered individually.

4.1 Results of the Stage 1 Report

The scoping report (Royal Haskoning, 2009) identified a number of policies within the Taunton Deane Borough Council Local Plan and Emerging Allocations report where direct, indirect or secondary impacts could have the potential for significant effects.

An assessment of the SSSIs which comprise the whole Somerset Levels and Moors SPA and Ramsar sites found that six of 12 sites were considered to be in an ‘unfavourable’ condition. Reasons for the unfavourable condition of the site included:

• fertiliser use; • inappropriate water levels and water level management; • water pollution and agriculture/run off; • public access and disturbance; • vehicles; • grazing; and • extraction.

Peat extraction has been carried out on the Levels and Moors, predominantly on which is further from Taunton Deane Borough, since the middle of the 1800s. Natural England considers this to be a reason for the unfavourable condition of a number of the SSSIs.

The scoping report also concluded that additional housing development within the Borough will put an increased demand on water resources, resulting in increased abstraction which could have an impact upon the international sites. Also, there could be an increased demand on wastewater treatment systems with some potential to lead to eutrophication.

During the scoping study, the potential for impacts to the migration of Severn Estuary international site fish species from increased abstraction was raised. However, since that report was produced this impact has been considered further and due to the distance of the Borough from the potentially affected rivers, is no longer considered applicable to the Taunton Deane Borough. Therefore, impacts to the Severn Estuary international sites are not considered further within this report.

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Impacts identified in the scoping report which are considered relevant to site vulnerabilities in relation to the Core Strategy and this assessment are:

• Increased recreational disturbance to birds within the Somerset Levels and Moors SPA due to population growth within the Borough, particularly , Creech St Michael, Monkton Heathfield, West Greenway, East Greenway, Priorswood/Nerrols, Killams, Staplegrove, Comeytrowe, Bishops Hull, and Ford Farm.

• Increased water quality impacts to invertebrates within the Somerset Levels and Moors Ramsar due to eutrophication from new water treatment facilities and surface water run-off from developments at North Curry, Creech St Michael, Monkton Heathfield, West Greenway, East Greenway, Priorswood/Nerrols, Killams, Staplegrove, Comeytrowe, Bishops Hull, and Ford Farm.

• Potential development of renewable energy projects near, and in the flyways to the Somerset Levels and Moors international sites that could adversely impact birds.

4.2 Assessment of the Published Plan Core Strategy

Following completion of the scoping report in 2009, the draft policies were refined and altered by Taunton Deane Borough Council. Throughout this policy development stage, draft versions of the policies have been assessed for potential impacts on the Somerset Levels and Moors international sites and comments/ alterations incorporated.

Once the final suite of policies was produced, each one was assessed for Likely or Potential Significant Effect in terms of recreational disturbance, water quality impacts on invertebrates and impacts on flyways, with the results provided in Table 4.1.

Table 4.1 Assessment of draft final policies Key

Potential for adverse effect - No adverse effect o Potential positive effect, at the plan level +

Policy CP 1 – The policy outlines the requirements of developments to be ‘sustainable’ and includes that developments should incorporate measures to promote and enhance the resilience of and networks within and beyond the site. There is also specific reference to renewable energy and large-scale, freestanding installations. These developments will be favourably considered when the impact on o nature conservation does not outweigh the economic and wider environmental benefits of the proposal. This statement indicates that there is a balance between the impacts to the environment and the potential benefits from the scheme; this could enable larger projects, with potentially greater contribution to e.g. renewables targets and climate change mitigation, to have a greater impact on the environment

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whilst still being considered ‘acceptable’.

Following refinement to the policy and its supporting text further requirements have been included that will prevent renewable energy developments from being built within 800m of the international sites and thus addresses potential impacts on birds and their movements. Also applications will have to show that they will not have an adverse effect on the bird features of the Somerset Levels and Moors.

Therefore this policy is unlikely to have an adverse effect on the Somerset Levels and Moors. Policy CP2 – Economy This policy sets out the proposed economical growth for the Borough and the chosen areas for this growth. As the areas proposed for development are within Taunton and Wellington and some rural areas, and no new industrial estates or o other developments are proposed which may be located closer to the Somerset Levels and Moors, it can be concluded that this policy will not have a likely significant effect on the condition of the international site. Policy CP3 – Town and Other Centres This policy promotes the use of town centres for community retail, leisure, cultural and business needs. Taunton and Wellington are identified as the main centres for this sort of growth. Rural development will be permitted within the boundaries of the o settlement and should be in keeping with the scale of the settlement. This development is unlikely to have an associated impact on visitor numbers in the international sites remains. It can therefore be concluded that this policy is unlikely to result in a significant adverse effect on the international sites. Policy CP4 - Housing This policy details the Borough’s housing requirements and plans. The increase in housing has the potential to result in the increase of visitors and users of the Somerset Levels and Moors. This could cause increased disturbance to bird species from walkers and dogs etc. -

The amount of housing proposed for the Borough may still result in a significant adverse effect on the international sites directly through impacts on the water environment, or indirectly through increasing visitor pressure. Policy CP5 - Inclusive Communities This policy sets out the requirements of developers to provide community and other infrastructure needs within the proposed developments. There is a focus on older people, young people, rural areas and areas of deprivation. o

As these requirements are likely to be within developments, it can be concluded that this policy is unlikely to have a significant effect on the Somerset Levels and Moors. Policy CP6 – Transport and Accessibility This policy sets out the requirements on developments to contribute to reducing the need to travel, improve accessibility to jobs, services and community facilities, and o address the impacts of climate change. It also supports the use of public transport and improving links to rail services. Therefore this policy is unlikely to have a

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significant effect on the international sites within the Borough. Policy CP7 –Infrastructure This policy proposes specific infrastructure developments to aid travel around the Borough, to other Boroughs and in the key settlements. None of the proposed improvements are considered to be sufficiently close to the international site to o have an influence on its features.

Therefore no adverse effect on the international site from this policy is anticipated. Policy CP8 – Environment This policy sets out the Council’s views regarding the natural and historic environment. The actual policy states that proposals that will have an adverse impact on Natura 2000 and Ramsar sites will not be supported by the Council. The policy also states that all developments outside of settlement boundaries will be in accordance with policies regarding development, including those for Natura 2000 sites. +

The wording of this policy supports the protection of the international sites. It also recommends a network of green infrastructure assets which will provide alternative areas for use by the public. These could contribute to relieving any visitor/recreational pressure on the international sites. It can be concluded that this policy will not have an adverse effect on the condition of the international site. Policy SP1 – Sustainable Development Locations This policy sets out the main role of each of the key development areas, identifying locations for development. The policy states that proposals should promote principles of sustainable development by minimising and/or mitigating pressures on the natural environment. - Although the main focus for development is within Wellington and Taunton, which are located away from the Somerset Levels and Moors, there is potential for increased visitor pressure to occur as a result of the increased development within the Borough. Therefore there is potential for a significant adverse effect on the international site. Policy SP2 – Realising the vision for Taunton This policy outlines the goals and key features for Taunton during the plan period. Although this policy includes the development of 13,000 dwellings, it also allows for the development of a green infrastructure network, which will potentially help to reduce visitor pressures on the international site.

o The policy also states that development within Taunton will be expected to respect the environmental constraints as set out in Policy CP8 – Environment. By including reference to this other policy, it reinforces that no impacts to the international sites should result through the implementation of SP2. It can be concluded that this policy will not have an adverse effect on the condition of the international site.

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Policy SP3 – Realising the vision for Wellington This policy outlines the goals and key features for Wellington during the plan period. Although this policy includes the development of 2,000 dwellings, it also allows for the development of a green infrastructure network, which will potentially help to reduce visitor pressures on the international site.

The policy also states that development within Wellington will be expected to o respect the environmental constraints as set out in Policy CP8 – Environment. By including reference to this other policy, it reinforces that no impacts to the international sites will result through the implementation of SP3.

It can be concluded that this policy will not have an adverse effect on the condition of the international site. Policy SP4 – Realising the vision for Rural Areas This policy outlines the key features of the vision for the rural areas of the Borough. This policy includes the proposed development of 2,000 dwellings, which will be spread across several settlements. o The policy also states that development will be expected to respect the environmental constraints as set out in Policy CP8 – Environment. It can be concluded that this policy will not have an adverse effect on the condition of the international site. Policy SS1 – Monkton Heathfield, SS2 – Priorswood / Nerrols, SS3 – Wellington Longforth, SS4 – Wellington Cades / Jurston, SS5 – Wellington: Strategic Employment Site, SS6 – Staplegrove: Broad Location for Growth, SS7 - Comeytrow / Trull: Broad Location for Growth and SS8 – Taunton: Broad Location for Strategic Employment

These policies set out the proposed residential and employment strategic sites within various areas around Taunton and Wellington, All of the proposed housing developments include the creation of country parks, green wedges and areas of open space. Due to the location of these developments, it is not felt that there will o be any water quality impacts which may affect the Somerset Levels and Moors.

These policies provide further information on the specific locations for the development proposed within Policies SP1, SP2 and SP3. As the proposed housing increase has been detailed (and considered) within the SP policies and these SS policies are not proposing any new development, these policies have been considered as ‘supporting information’ with the assessment carried out on the ‘higher level’ policy. As such, and within the context of this assessment, no additional adverse effect on the international site as a result of these policies. Policy DM1 – General Requirements This policy outlines the criteria which developments must meet, including efficient use of land, no harm to the environment from pollution, and no harm to protected species or their habitats.

o The wording of the supporting text of this policy has been refined to included reference to CP8, the Environment Policy. This therefore ensures that the international sites are afforded protection from developments and associated impacts (e.g. water quality). Therefore, there will be no adverse effect on the international site as a result of this policy.

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Policy DM2 – Development in the Countryside This policy sets out the Council’s requirements for development within the countryside and what types of uses will be supported. It included holiday and tourism development, but states that it must not harm the natural heritage of the Borough.

The policy includes the statement that all development must be compliant with the Habitats Regulations 2010 and any subsequent amendments. This ensures that the Somerset Levels and Moors will be protected from any impacts associated with o development in the countryside.

Also, the supporting text includes a section on renewable energy installations and the need to appropriately site proposals in order to minimise impact to wildlife. The section also refers to Policy CP8, offering further protection to the international sites.

Therefore, there will be no adverse effect on the international site as a result of this policy. Policy DM3 – Gypsy and Traveller Site Selection Criteria This policy sets out the criteria which should be used when selecting sites for gypsies and travellers. The policy states that environmental impacts from these developments should be minimised and that proposals should avoid an adverse o impact on Natura 2000 sites. The policy refers back to the environment policy, CP9.

Therefore this policy is not likely to result in an adverse effect on the Somerset Levels and Moors. Policy DM4 – Design This policy sets out the requirements that each development should fulfil in terms of its design. This involves making developments sustainable, attractive and good infrastructure. This policy is not recommending more developments, but is laying out the Council’s aims for every development to ensure an attractive and safe environment for residents. It is also seeking to encourage + design at a spatial scale in order to achieve a consistent design within developments that respects the local character and setting.

This policy is unlikely to have an impact on the international sites within the Borough and the requirement to provide access to green spaces may have a positive impact by providing alternative recreational areas. Policy DM5 – Use of Resources and Sustainable Design This policy outlines the Council’s requirements for all developments to incorporate sustainable design. It includes minimising pollution into the wider environment and reducing carbon dioxide emissions through renewable energy generation. The policy supporting text mentions that all developments should reduce carbon emissions and this can range from micro-renewables to wider community or Borough schemes. o

This policy includes supporting text on the potential impacts of renewable energy projects on the Somerset Levels and Moors. It states that careful consideration should be given to locational decisions on applications and that such applications should not be within or near Natura 2000 sites in the Borough. It also refers to the Environment Policy which contains more information on international

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sites.

It can therefore be concluded that this policy does not have the potential for a significant effect on the bird (or other) features of the Somerset Levels and Moors.

4.3 Summary

Completion of the assessment of individual policies concluded that there are two policies where there remains at least the potential for a significant effect on the Somerset Levels and Moors. These policies are:

• Policy CP4: Housing; and • Policy SP1: Sustainable Development Locations.

These policies were deemed to have the potential for adverse impacts through one or more of the following impact mechanisms:

• increased recreational disturbance; and • increased water quality impacts.

These impacts were highlighted in the scoping report and no further impacts were identified through the course of this assessment. These impacts are considered in more detail in Section 5. .

The potential impacts from renewable energy projects have been sufficiently accounted for within the relevant policies and their supporting text and can now be considered not applicable to the Core Strategy. Several policies were identified as having beneficial impacts. Whilst not addressed in Section 5, they are accounted for in the plan-level assessment in Section 6.

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5 IMPACTS ASSOCIATED WITH POLICIES

In this section, the potential impacts highlighted in Section 4.3 are discussed in more detail. The main objective is to establish whether or not the policies identified as having a potential or likely significant effect could actually result in adverse impacts upon site integrity.

5.1 Recreational Disturbance

Owing to the presence of internationally important over-wintering bird species the Somerset Levels and Moors has been designated as an SPA. Policies which potentially cause an increase in the number of people recreationally using the site could disturb bird species, and therefore impact the quality of the interest features of the site.

5.1.1 Site visitors

Visitor surveys commissioned by Somerset County Council were undertaken between December 2009 and February 2010 at various locations across the Somerset Levels and Moors. The aim of the surveys was to identify the reasons for people visiting the site and to establish the distance people were travelling. The locations picked for survey were focused on the main car parks and access points to the international site. The survey also collated additional information including the time of the visit, weather conditions and if dogs were present. The number of people recorded visiting each site is presented in Table 5.1.

Table 5.1 Visitor numbers at the various Somerset Levels and Moors sites.

Number of people Site visiting the site Gold Corner 4 Peat Moors 159 Ashcott Corner 203 West Hay Moor 84 Beer Wall 20 Bridge 67 New Bridge 58 54 Ablake Clyce 27

Figure 5.1 illustrates the reasons why people were visiting the Somerset Levels and Moors. 125 out of 332 visitors questioned, visited the site for bird watching. Also, walking was identified as a popular reason for visiting, with 117 of the visits for this activity. Dog walking accounted for 35 of the visits, spread over 8 of the sites.

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Figure 5.1 Key Visitor Activities on the Somerset Levels and Moors Site

Somerset Levels and Moors Visitor Activities

Walking Bird watching Dog walking Cycling Other

Figure 5.2 illustrates the distances travelled by visitors to the Somerset Levels and Moors international sites. On average, the greatest number of visitors, approximately 40% of those surveyed travelled a distance of more than 20km to the site. 22% of visitors travelled between 5 and 10km to the site.

Figure 5.2 Distances travelled by visitors

Distance Travelled to the Somerset Levels and Moors

0-5km 5-10km 10-15km 15-20km >20km

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Although, the Somerset Levels and Moors sites are used predominantly by bird watchers and walkers, Figure 5.3 shows a breakdown for each site within the Somerset Levels and Moors. Bird watching is not the main activity at sites within the Taunton Deane Borough. Burrow Mump was a popular destination for climbers and also people going there to enjoy the scenery. Walking and other activities such as photography were the most popular activities at New Bridge.

The distances travelled to the Somerset Levels and Moors varied for each of the individual sites surveyed, although a pattern emerged that showed that people travelling for recreation travelled smaller distances than those visiting specifically to watch birds (see Figure 5.4). As would be expected with the type of activities undertaken at Burrow Mump and New Bridge, the most common distance travelled to the sites was 5 to 10km.

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5.1.2 Existing pressures

A survey of bird disturbance at SSSI, one of the sites which comprise the Somerset Levels and Moors, was undertaken in 2001. The aim of the survey was to assess impacts on waterfowl species using the wet areas of the site. The study found that when the people used footpaths or designated routes through the site, there was a low level impact on bird species (Chown, 2002). This was thought to be due to the fact that the majority of wildfowl species used inaccessible areas of the SSSI away from the main visitor areas. This use of habitat was thought to be partly due to the lack of suitable habitat in proximity to paths (Chown, 2002).

Natural England considers that recreational disturbance is currently at a low level throughout the Somerset Levels and Moors sites. Due to the size of the site and the fact that it is spread out across a number of Districts and Boroughs, visitor numbers are unknown. However it is estimated that receives approximately 7,500 visitors each year. Visitor numbers to the Somerset Level and Moors site appear to be restricted by the location and size of the car parks around the various sub-sites (locations of which were used for the visitor surveys).

Over-wintering bird species are the key interest feature of the SPA. Recreational disturbance is considered to be largely a seasonal issue, with the busiest visitor periods within the summer months when the species for which the site is designated is not present. Pressures on over-wintering bird species are therefore anticipated to be lower.

5.2 Reduced Water Quality and Impacts upon Invertebrate Species

5.2.1 Invertebrates and water quality in the Somerset Levels and Moors

Pollution poses a significant threat to biodiversity in both flowing and standing waters in the UK. A recurring problem throughout English lowlands is over-enrichment of water with nutrients including nitrogen and phosphorus (eutrophication) from both diffuse and point sources.

The floodplains of the Rivers , Brue, Parrett and Tone make up much of the Somerset Levels and Moors; an area therefore sensitive to reductions in water quality. A large network of ditches (known also as ), drains and rivers run through the area. Within this network of waterways is an extensive assemblage of aquatic invertebrates, particularly beetle species. Of the invertebrate species known to exist throughout the site, 17 are featured in the British Red Data Book4 (BRDB), and are a qualifying feature of the site’s Ramsar designation. Table 5.2 shows the BRDB invertebrate species that are found within the Somerset Levels and Moors. For the purposes of this assessment, and without definitive information otherwise, it is presumed that all species are found at all sites unless the text below states otherwise.

4 The BRDBs, published by the Joint Nature Conservation Committee, are lists of species whose continued existence is deemed threatened.

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Table 5.2 Invertebrate species of conservation importance as designated in the Ramsar citation, and also appearing in the BRDB, which are known to be present within the Somerset Levels and Moors.

SPECIES Distribution or abundance in Common the Somerset Levels and Preferred habitat Latin name name Moors Hydaticus Widespread and frequent though Diving beetle Ditches transversalis nationally rare Great diving Dytiscus Local Ditches beetle dimidiatus Lesser silver Hydrocaris Well vegetated ditches Restricted to peat moors diving beetle caraboides overlying peat Great silver Hydrophilius Widespread throughout Somerset Ditches overlying peat diving beetle piceus but mainly on the peat moors with much vegetation Ditches overlying peat Water Beetle Limnebius aluta Very local and ponds , wet woodland. Soldier beetle Cantharis fusca Widespread in damp meadows River and field margins Confined as a British species to Submerged vegetation in Weevil Bagous nodulosus Somerset. Little known about its ditches distribution Fens or peat moors Very local, only on the peat moors. including Leaf beetle Oulema erichsoni Somerset has the only known recently worked out peat extant population in Britain pits Paederus Rove beetle Very local Damp mud by freshwater caligatus Laccornis Densely vegetated peaty Diving beetle Very local and scarce on the Moors oblongus ditches Restricted to three sites on the Odontomyia Moors. Recorded late 1940s, early Fens and shallow ponds angulata 1950s Soldier fly Ditches on peat with Odontomyia Regular and locally frequent floating cover and rich ornata submergent vegetation Brackish ditches. Hoverfly Lejops vittata Locally frequent Associated with Scirpus maritimus Wetlands. Ponds and Pteromicra fly One certain locality, Westhay Moor with dense leucopeza shading Freshwater Valvata Relatively common on the North Ditches mussel macrostoma Somerset Levels. Large marsh Stethophyma Very rare and localised. May be Fens, and ditch grasshopper grossum extinct banks

Table 5.3 is a summary of water quality data taken at a number of sites within, in proximity to, or along watercourses which pass through, the Somerset Levels and Moors. Biological quality of the watercourses in the majority of cases is good, although

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nitrate and particularly phosphate levels are in most cases high. Excess levels of nitrate can result in algal growth and ultimately lead to eutrophication of a watercourse.

Table 5.3 Water quality data at four locations in, around or upstream of the Somerset Levels and Moors. All data provided by the (Letters A-F indicate ‘very good’ to ‘very bad’ and 1-6 indicate ‘very low levels’ to ‘very high levels’. The locations 1-4 are marked in Figure 3.1).

River/ Location Chemistry Biology Nitrates Phosphates Watercourse 1 - Taunton west

(confluence with Tone A B 4 4 Halse and Sherford) 2 - Ruishton-Ham Tone A A 4 4 3 - Knapp-Haymoor Tone B B 5 5 4 - Kings Sedgemoor Kings (confluence with 18 Sedgemoor E - 3 5 Feet Rhyne & Sowy) Drain

Below is a detailed consideration of the current site condition for the four component SSSIs that make up the sections of the international sites being considered within this assessment.

Curry and Hay Moors

Covering 474 hectares, and most recently assessed in September 2010, Curry and Hay Moors consists of low-lying grazing adjacent to, and seasonably flooded by, the . Over 100 species of aquatic invertebrates inhabit the ditches throughout the site including one nationally rare soldier fly (Odontomyia ornata) as well as 13 nationally scarce species including the water beetles (Agabus uliginosus, Hydaticus transversalis and Helophorus nanus).

Table 5.4 below gives a breakdown of the unit conditions for the site. Unfavourable conditions that have prevailed recently are improving as shown by the assessment that over 95% of the site is in an ‘unfavourable’ but ‘recovering’ condition. Unfavourable conditions have been caused by a combination of drainage, the use of fertilisers, inappropriate water levels and pollution of watercourses caused by agricultural practices, run-off and discharge. Curry and Hay Moors lie downstream of Taunton by approximately 8.5km. In the South West River Basin Management Plan the section of the River Tone which flows through the site is currently assessed as being of on moderate quality, with phosphate issues. However it retains a high status for invertebrate species.

Table 5.4 Condition summary for SSSI units at Curry and Hay Moors

Favourable 1.7% Unfavourable recovering 95.3% Unfavourable no change 3.0% Unfavourable declining 0%

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King’s Sedgemoor

Most recently assessed in August 2010, King’s Sedgemoor – comprised largely of wet grassland, and sitting on the southern bank of the - is deemed ‘unfavourable recovering’ over majority of the site with just over a quarter deemed to be in a ‘favourable’ condition (refer to Table 5.5 below). The site forms part of the extensive grasslands of the Somerset Levels and Moors. Small field ditches and banksides, feature rich and invertebrate communities with five species of rare water beetle having been noted alongside two species of rare soldier fly, the hover fly Lejops vittata and the water beetle Hydrophilus piceus.

The overall condition of the site has improved since the previous series of monitoring. The unfavourable condition of small parts of the site is attributed to the presence of pollutants in the form of fertiliser run-off and from other agricultural practices. In addition, winter water levels remain lower than optimum in a number of areas. The Parrett is proposing measures which will enable appropriate water level management to occur on site to return the site to favourable condition.

Table 5.5 Condition summary for units at King’s Sedgemoor

Favourable 26.5% Unfavourable recovering 69.5% Unfavourable no change 4% Unfavourable declining 0%

West Sedgemoor

Covering 1,016 hectares, West Sedge Moor comprises multiple small, low lying fields and meadows separated by narrow water-filled ditches. A rich invertebrate fauna is present including scarce water beetles and dragonflies. is located on the with the northern extremity of the site adjoining the river and the vast majority of the site extending away from the river in a south-westerly direction.

Almost all of the component SSSI units are in an ‘unfavourable recovering’ condition, with only 1% assessed as ‘unfavourable, no change’ – see Table 5.6. The unfavourable condition of this small part of the site is attributed to the presence of pollutants in the form of fertiliser run-off and from other agricultural practices.

Table 5.6 Condition summary for units at West Sedgemoor

Favourable 0% Unfavourable recovering 99% Unfavourable no change 1% Unfavourable declining 0%

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South Lake Moor

South Lake Moor covers 196 hectares and lies alongside and to the west of the River Tone between West Sedgemoor and King’s Sedgemoor. It comprises lowland grazing marsh and grassland and can be deliberately flooded if necessary during winter by means of a sluice on the bank of the River Parrett (which runs along the eastern boundary of the site). A notable number of aquatic and bankside vascular plant species have been found at the site. The aquatic invertebrate fauna includes the notable variable coenagrion Coenagrion pulchellum and hairy dragonfly Brachytron pratense together with two local species, the mollusc Gyraulus laevis and the bug Sigara semistriata. Terrestrial invertebrates are less well known but include the rare soldier flies Odontomyia ornata and Stratiomys furcata.

Winter flooding of the Moor can result in significant numbers of wildfowl visiting the site including species for which the Somerset Levels and Moors are designated.

Almost the entire site is designated as being in a ‘favourable’ condition (see Table 5.7). Pollutants including fertiliser run-off are attributed for the ‘unfavourable’ condition assessment for 1.5% of the site.

Table 5.7 Condition summary for units at South Lake Moor

Favourable 98.5% Favourable recovering 0% Unfavourable no change 1.5% Unfavourable declining 0%

Water level management is of critical importance in maintaining the integrity of many of the component SSSIs, and on initial investigation appears to be of greater importance/more of a threat to site integrity, than issues related to water quality. The Parrett Internal Drainage Board has created Water Level Management Plans for all the SSSIs in order to improve their status to one of favourable condition.

5.2.2 Core Strategy policies and water quality impacts

The number of new residential developments planned within the Borough will result in a greater throughput for the existing sewage treatment works (STWs). Consultation with Wessex Water has been undertaken concerning the predicted increase in flows expected to arise from new developments that are planned throughout the Borough. Wessex Water have provided estimates on the future flow capacity of STWs up to and including 2015, within Taunton Deane Borough (see Appendix B).

Sewage treatment works have consents (agreed with regulatory authorities such as the Environment Agency) for the maximum amount of water that they can discharge into watercourses. The consent given to water treatment companies is against the Dry Weather Flow (DWF) to ensure that even when river flow rates are low (and effluent concentrations therefore rise), the impact of the effluent upon the watercourse is maintained at an acceptable level.

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Figures which illustrate the current STW outflow rates as a percentage of their consented maximum were provided by Wessex Water. It should be highlighted that these figures show existing STW output levels, and not forecast ones taking account of proposed housing growth figures as laid out in Core Strategy policies.

The data indicated that there is currently sufficient capacity within all of the STWs in the Borough to cope with the additional developments up to 2015. One site (Styles STW – serving ) is currently at 110% of its DWF and the associated consent is being reviewed. In light of proposed development in that area, Wessex Water do not anticipate a future problem associated with discharge levels.

Wessex Water also provided an assessment of the impacts of the proposed new developments, and whether DWF consented limits would be at risk. Proposed development at these sites has been considered and is not expected to result in consented limits being exceeded between 2010 and 2015. Works are currently underway that will result in an increase in the consented DWF for Taunton (Ham) STW to accommodate proposed housing growth. As mentioned above, the consent is being reviewed for Styles STW as the DWF is currently being exceeded. Planned housing development in this area is not significant. Whilst the estimations undertaken by Wessex Water do not reflect the full plan period of the draft Core Strategy (i.e. up to 2028), they do take into account the full allocation of properties for each settlement. In addition, works undertaken on their facilities in the future would need to be compliant with the Habitats Regulations and the Water Framework Directive targets set out within the River Basin Management Plan.

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6 THE ALONE ASSESSMENT

In this section, the policies identified in Section 4 as having a Likely Significant Effect on the Somerset Levels and Moors are assessed in greater detail. This assessment is undertaken for the impact of the policy on its own (disregarding the impact other policies may have on outcomes arising from them). The assessment builds upon the information presented in Section 5 to conclude whether a particular policy will have an adverse effect on site integrity. The sections below provide information for further consideration in the support of the Appropriate Assessment.

6.1 Policy CP4: Housing

Policy CP4 proposes the development of about 17,000 homes within the Borough over the period 2008 to 2028. Development will be predominantly focused within Taunton, with around 13,000 – 14,000 dwellings planned for the town. Wellington will receive approximately 2,500 dwellings. The remainder will be split between settlements in the rural areas.

Due to the location of Wellington and Taunton, no impacts through the associated population increase, on the international sites are anticipated. However, some of the smaller settlements are closer to the site and could therefore have some potential impact from increased recreational use. Although the scale of development within these areas means there is not likely to be direct impacts, they may act as a contributory factor to impacts caused by larger development within the settlements.

Section 5.1 outlines the results of visitor surveys taken at the Somerset Levels and Moors. The survey results illustrate that a variety of activities were being undertaken at the site, including dog walking and bird watching. A number of people visited the Somerset Levels and Moors from outside the Borough specifically for ornithological interests. Whilst the site is a popular destination for local residents, consultation with Natural England (who are responsible for management of the Somerset Levels and Moors) revealed that levels of recreational disturbance throughout the site are currently low. This is due to the fact that large areas of the site are relatively inaccessible and that the vast majority of users stick to defined paths and walking routes. Additionally, bird species are not concentrated in areas where recreational visitors tend to be due to a lack of suitable habitat. Also, numbers of visitors, including local users will decline during the winter period. The number of new residents in the Taunton Deane Borough is not expected to result in adverse impacts through increased recreational disturbance.

The increase in residential development will increase pressure on the current water treatment works in the Borough. During consultation, Wessex Water concluded that no exceedance of consented limits is expected within the larger settlements from the additional housing capacity set out in the Core Strategy. As STWs are in compliance with the Habitats Regulations and through the River Basin Management Plan will also be compliant with the Water Framework Directive, no impacts are anticipated.

Therefore this analysis supports a conclusion that Policy CP4 will not result in an adverse impact on the integrity of the Somerset Levels and Moors SPA or Ramsar sites.

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6.2 Policy SP1: Sustainable Development Locations

Policy SP1 is very similar in content to CP4; in that it sets out the development proposed for the Borough and the key locations to be used. The location of these developments are labelled on Figure 3.1

The impacts associated with this policy are the same as discussed for Policy CP4 above. Therefore the conclusions made above regarding the potential for adverse impacts on the Somerset Levels and Moors as a result of increased recreational disturbance and declines in water quality are also valid.

Therefore this analysis supports a conclusion that Policy SP1 will not result in an adverse impact on the integrity of the Somerset Levels and Moors SPA or Ramsar sites.

6.3 The Draft Core Strategy – Assessment at the Plan Level

As identified above, two policies were identified as having an ‘alone’ potential significant effect on the Somerset Levels and Moors and were carried through to the alone assessment stage. However after detailed consideration we conclude that they will not lead to an adverse effect on the integrity of the sites in question.

Several other policies within the plan make recommendations for green infrastructure and open spaces to be included in developments, for example Policies CP9 Environment and DM4 Design. Open space associated with new development is assumed to have some effect on limiting any additional pressure on the international sites, particularly with regard to day-to-day use for dog walking and other activities. Such open space should be provided early in the development of a site to establish its use among residents and ensure this limiting effect on designated sites is realised.

Completion of the detailed assessment has enabled a conclusion of ‘no adverse effect’ to be made for the final policy suite. It is not anticipated that adoption of the policies reviewed will result in any adverse impacts upon site integrity for the Somerset Levels and Moors international sites.

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7 IN-COMBINATION ASSESSMENT

As well as assessing the impacts of the Core Strategy’s policies individually, and at the plan level, as addressed in Section 6, it is important to consider the combined effects of the strategy with other plans and projects which could also affect the sites. “Where an in-combination is necessary … it is the plans and projects, which are likely to contribute to an increased likelihood or significance of the effects of the subject project that need to be combined” (Tyldesley and Hoskin 2008: B.2.5). In the context of this assessment this includes relevant plans from neighbouring authorities.

Various plans and strategies were identified at the Stage 1 as having a potential compounding or interacting effect on possible threats to site integrity. In particular they are relevant where they relate to any increase in residential development or encourage increased visitation to international sites. For the purposes of the assessing in- combination effects, other plans and strategies have been considered at face value, i.e. assuming no mitigation, prevention or avoidance has been applied.

The sections below provide the results of an assessment of other plans, and identify which areas have the potential to act in combination with the Taunton Deane Borough Published Plan Core Strategy.

7.1 Other Plans and Strategies

Draft Regional Spatial Strategy for the South West – incorporating the Secretary of State’s Proposed Changes – for consultation 2008

This higher-level statutory development plan for the whole of the South-West region set out the strategic scale and location of development. The Regional Spatial Strategy (RSS) outlined that a substantial growth in population is expected and that infrastructure improvements will be necessary in relation to this growth. It proposed housing, transport, business and industrial development throughout the south west. It should be noted, however, that at the time of this report the status of the RSS (and other regional-level planning documents) is highly uncertain.

In May 2010, the new Coalition Government announced and implemented a number of changes that affect the way local authorities plan for future growth, particularly the revocation of Regional Spatial Strategies. However, as a mechanism for strategic planning has not yet been decided upon, this plan is considered under this HRA.

There is no scope for the RSS (or similar) to have an in-combination impact with the Taunton Deane Borough Core Strategy as the strategy is the means by which the aims and objectives of the RSS are delivered. Other councils’ core strategies will outline the development expected in their areas and these are therefore the documents which may have an in combination effect with the Taunton Deane Borough Published Plan Core Strategy.

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Responding to Climate Change in Somerset

This document details how the county of Somerset will tackle the causes and effects of climate change. Implementation of a climate change action plan will enable the County Council to provide effective leadership, advice and encouragement to stakeholders and communities in tackling the causes and effects of climate change across the County. Climate change must be taken into account when implementing the core strategies.

No in-combination impacts have been identified as a result of the implementation of this policy. This is primarily because the policy details how Somerset will respond to the challenges of climate change, and does not set out any policies that could have an impact upon the designated sites, either alone or in-combination or with those set out in the Taunton Deane Core Strategy document.

Core Strategy documents

The impacts of development in any given Local Authority area cannot be fully considered or rectified in isolation from neighbouring authorities and their developments. Core Strategies provide an overarching policy framework for the Local Development Framework. They establish the vision, objectives and policies for how a Borough sees itself progressing.

West Somerset District Council is in the process of preparing core strategy documents. They are still under development and are not in a condition to be assessed. However, it is not anticipated that there will be any in-combination impacts, due to its location in relation to Taunton Deane. East Devon Council is also developing a core strategy but has undertaken the first stage in a HRA for the Issues and Options Consultation document. The HRA identified that’s there may be potential impacts arising from options within the Core Strategy and that these will be assessed at the next stage of the HRA process.

The HRA of the Sedgemoor District Council Proposed Submission Core Strategy assessed the impact of policies on the Severn Estuary and Somerset Levels and Moors sites. The assessment concluded that three policies could have an adverse effect on the integrity of the international sites. However, mitigation and policy amendments were recommended which would negate these potential impacts on the sites. Therefore it is considered that there will be no in-combination impacts with policies proposed as part of the Taunton Deane Core Strategy.

North Devon Council undertook a joint Core Strategy with Torridge District Council in 2009. Due to the location of the District, no impacts on the Somerset Levels and Moors were anticipated as a result of any of the policies proposed within the strategy. Therefore, no in-combination impacts between Taunton Deane Published Plan Core Strategy and the Joint Core Strategy are expected.

South Somerset District Council draft Core Strategy HRA concluded that there would not be any adverse effects on the Somerset Levels and Moors from implementation of any policies. Therefore, no in-combination impacts between it and Taunton Deane Published Plan Core Strategy are anticipated.

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Somerset Minerals Local Plan 2004-2011

The Somerset Minerals Local Plan sets out the broad land use framework for future mineral development in Somerset. It will be replaced by the Somerset Minerals Core Strategy post-2011.

The plan sets out the detailed environmental and other criteria against which the county judges all applications for mineral extraction or quarrying. The proposed re-routing Public Rights of Way (Policy M16) could result in in-combination impacts to the Somerset Levels and Moors sites through disturbance impacts associated with increased levels of visitation.

Additionally, the proposed peat extraction policy (M40) at the Somerset Levels and Moors could result in in-combination impacts with the Taunton Deane Borough Core Strategy; potentially resulting in increased disturbance to bird species and, potentially, water quality-related impacts on Ramsar-designated invertebrates.

Somerset Rights of Way Improvement Plan 2006

The Somerset Rights of Way Improvement Plan, prepared by Somerset County Council, sets out the context of the existing public rights of way network in the county and the results of a consultation to determine the best ways of improving the networks to meet the current and future needs of users.

The plan seeks to maintain the existing network of rights of way, whilst aiming to improve access throughout the county by adding to the network. Improved public access particularly close to or through the designated sites has the potential for in-combination impacts with the core strategies, particularly in relation to disturbance to bird species. However, such a plan offers the opportunity to better manage visitor pressures away from the sensitive areas. No significant in-combination effect is currently anticipated. Future iterations of this plan offer the opportunity for Somerset County Council to limit the impact of visitors on international sites in the area. We recommend that Taunton Deane Borough Council work with the county council to encourage this.

Somerset Local Transport Plan 2006 -2011

Local Transport Plans (LTPs) are aimed at tackling congestion and reducing pollution, improving accessibility and safety, and are used by central government to determine borrowing approvals for funding transport schemes for the next five years. The final Somerset ‘Local Transport Plan 2006-2011 (LTP 2)’ was submitted to central government in March 2006.

The LTP outlines specific plans for controlling pollution and any air or water quality impacts related to growth are likely to be minimised. It also recognises a range of quality of life indicators that must be incorporated into regional transport policy including sustainable communities, conservation of biodiversity, quality of public spaces and landscapes and community safety. One of the key aims of the LTP is ‘to champion Somerset’s economy whilst maintaining and enhancing the character and diversity of its environment’.

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With the Somerset Levels and Moors sites, particularly those in Taunton Deane, not being in close proximity to urban areas and also being, on the whole, not in close proximity to major highways, the LTP is not expected to have any in-combination impacts. Additionally, an objective of the LTP is to reduce the growth of congestion and pollution. The LTP also seeks to encourage the use of cycling routes and to also improve and maintain existing routes.

Catchment Area Management Strategies (CAMS)

Catchment Area Management Strategies (CAMS) are produced by the Environment Agency to indicate the balance of abstraction and river health on a catchment basis. There is one CAMS which is of relevance to the Taunton Deane Borough Council Core Strategy; the River Tone CAMS (Environment Agency, 2004). The River Tone CAMS includes the Hillfarrance, Halsewater, Back Stream, Haywards water, Three Bridges Stream and Sherford Stream tributaries. The Management Unit which is responsible for the Somerset Levels and Moors sites within the CAMS area is currently assessed as having no water available for abstraction. This level will be maintained in the future. However, water going into the Somerset Levels and Moors sites will be maintained and under the Habitats Regulations, the Environment Agency must assess the effects of existing abstraction licences and any new applications to ensure they are not, or will not, impact the integrity of any international sites.

With abstraction being subject to HRA and the known importance of the international sites, it is not expected that the Tone CAMS will have any in-combination impacts with the Taunton Deane Borough Council Core Strategy.

7.2 Conclusion

It is not expected that the majority of the strategies, policies and plans detailed in this section will result in in-combination effects with the Taunton Deane Draft Core Strategy.

East Devon Core Strategy is currently being developed, and will be subject to revision, refinement and the HRA process. The nature of the potential impacts is unclear at this stage, and it is considered that they could in any case be avoided through clear protection being integrated into the final policy suites. If this is the case, we recommend that Taunton Deane Borough Council (through this document if necessary) highlight the potential for in-combination effects. The impacts identified are considered to be additive and as such should be mitigated within the plans themselves. Any residual impacts are not considered likely to have an adverse effect on site integrity.

Somerset Minerals Local Plan contains a policy (Policy M3) which indicates that proposals for mineral development which are likely to harm the integrity of a European site, proposed European site or a Ramsar site will not be permitted unless there are imperative reasons of overriding public interest for which there are no suitable alternative solutions. It is considered that this offers sufficient protection within that plan that the potential for in-combination impact is not significant.

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8 CONCLUSION AND NEXT STEPS

8.1 Conclusions of the HRA Process

Following this assessment of the Taunton Deane Borough Council Published Plan Core Strategy policy suite, it can be concluded that there will be no adverse effect on the integrity of the Somerset Levels and Moors international sites either alone or in- combination with other plans and policies.

8.2 Further Activities and Recommendations

Following rigorous assessment we consider that Taunton Deane Borough Council, as the competent authority under the Habitats Regulations, can conclude that any effects of the Published Plan Core Strategy policies will have no adverse effect upon the integrity of the Somerset Levels and Moors SPA and Ramsar international sites.

In adopting a precautionary approach to enabling future development and recognising the existing limited information relating to visitor behaviour and impact, we recommend that Taunton Deane Borough Council commit to discussions with Natural England and other relevant Local Authorities (including Somerset County Council, as well as the RSPB and the Environment Agency) into visitor level monitoring and further surveying at international sites within the Borough. A monitoring programme would enable early identification of any unforeseen future pressures and targeted actions could be determined and implemented.

Early implementation of this programme will enable pre-development baseline information to be collated. Over time it will be possible to assess the impact, if any, of future development on visitation and behaviour.

Consultation with interested parties, and in particular advice from Natural England, should be sought to ensure appropriate design of the monitoring strategy and to ensure the programme’s ambitions are met.

8.3 Next Steps

This document represents the assessment of policies contained within the Taunton Deane Borough Council Published Plan Core Strategy (as provided February 2011). We anticipate that the findings of the HRA will remain robust unless material changes are made as a result of the public consultation, and subsequent Examination in Public, of this policy suite. Where material changes are required, we recommend that a re- assessment of the findings of this report is carried out to confirm that its conclusions remain valid and that the Core Strategy for adoption remains compliant with the Habitats Regulations.

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Chown D (2002). Assessment of the Potential for Disturbance to Winter Waterfowl at Moorlinch SSSI, with Emphasis on the Raised Water Level Area.

Department for Communities and Local Government (DCLG) (2006). Planning for the Protection of European Sites: Appropriate Assessment - Guidance for Regional Spatial Strategies and Local Development Documents. Accessed on 14/01/2011.

English Nature (1997). Somerset Levels and Moors Natural Area – A nature conservation profile. English Nature (S omerset Team) July 1997.

English Nature (2005). Dogs, Access and Nature Conservation.

English Nature (2006). The Assessment of Regional Spatial Strategies under the Provisions of the Habitats Regulations – Draft Guidance.

Environment Agency (2004). The Tone Catchment Abstraction Management Strategy.

JNCC 2010(a). Joint Nature Conservation Committee - Natura 2000 standard data form – the Somerset Levels and Moors Special Protection Area (SPA). Accessed on 14/01/2011.

JNCC 2010(b). Joint Nature Conservation Committee - Information sheet on Ramsar wetlands. Accessed on 14/01/2011.

Royal Haskoning (2009). Stage 1 Scoping Report for Somerset Authorities Core Strategies: Somerset Levels and Moors and Severn Estuary ( Bay) Natura 2000 sites. Report for Somerset County Council.

Royal Haskoning (2010). Sedgemoor District Council Core Strategy Habitat Regulations Assessment Volume 1 - HRA for the Somerset Levels and Moors and Severn Estuary International Sites

Tyldesley D. and Hoskin R. (2008). Assessing projects under the Habitats Directive: guidance for competent authorities. Report to the Countryside Council for Wales, Bangor.

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APPENDIX A: DETAILED ASSESSMENT TABLES

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Taunton Deane Borough Council Final Report to accompany Taunton Deane Borough Council Published Plan Core Strategy HRA Policy CP4 –Housing; and Policy SP1 – Sustainable Development Locations

Designated sites Site Designation Key features Ramsar Criterion 2 The site supports 17 species of British Red Data Book invertebrates

Ramsar Criterion 5 Somerset Levels Ramsar The site supports assemblages of waterfowl of international importance and Moors

Ramsar Criterion 6 The site supports species/populations occurring at levels of international importance Annex I birds and regularly occurring migratory birds: common teal Annas crecca, Bewick’s swan Cygnus columbianus bewickii, golden plover Pluvialis apricaria and northern lapwing Vanellus vanellus.

Article 4.1 Qualification. Over winter the area regularly supports: Bewick’s Somerset Levels swan, golden plover SPA and Moors Article 4.2. Qualification. Over winter the area regularly supports: common teal and northern lapwing

Article 4.2 Qualification. An internationally important assemblage of birds Over winter the area regularly supports 73,014 wildfowl

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Ramsar Site Somerset Levels and Moors Feature Sub Feature(s) Sensitivity Conservation Target Potential effect of Implications Preventative Mitigation Compensation Impact on policy for integrity measures integrity (without action) Site supports 17 The Somerset Levels and Moors Monitor the invertebrate Reduced water quality N/A N/A N/A N/A No species of British is one of the largest and richest assemblage on a 6 yearly cycle arising from increased adverse Red Data Book areas of traditionally managed using defined invertebrate effluent outflow from impact invertebrates wet grassland and fen habitats sampling methods. upstream water upon in lowland UK. The network of treatment works, with integrity rhynes and ditches support an adverse impacts on outstanding assemblage of invertebrates aquatic invertebrates, particularly beetles. Assemblages of 97,155 waterfowl (5 year peak Maintain population within Recreational N/A N/A N/A N/A No waterfowl of mean 1998/99-2002/03) acceptable limits. Maintain the disturbance to adverse international area of habitats used by designated bird impact importance wintering birds within acceptable species upon limits (loss of 5% or more are integrity unacceptable). Where the limits of natural fluctuations are not known, maintain the population above 50%. Bewick's swan 112 individuals, representing an Maintain the area of habitats Recreational N/A N/A N/A N/A No average of 1.3% of the GB used by wintering birds within disturbance to adverse population acceptable limits (loss of 5% or designated bird impact more are unacceptable). Based species upon on known natural fluctuations of integrity the population on the site, maintain the population at or

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above the minimum for the site. Common teal 21,231 individuals, representing Maintain the area of habitats Recreational N/A N/A N/A N/A No an average of 5.3% of the used by wintering birds within disturbance to adverse population acceptable limits (loss of 5% or designated bird impact more are unacceptable). species upon integrity Northern lapwing 36,580 individuals, representing Maintain the area of habitats Recreational N/A N/A N/A N/A No an average of 1% of the used by wintering birds within disturbance to adverse population acceptable limits (loss of 5% or designated bird impact more are unacceptable). species upon integrity Potential effect A reduction in water quality leading to adverse impacts on Red Data Book invertebrates and increasing incidence of recreational disturbance due to a growing local population of policy on the which causes disturbance to over wintering birds. site Implications for the integrity of the site: Preventative measures: Mitigation: Compensation Consultation with Wessex Water concluded that as proposed N/A N/A N/A developments will not result in exceedance of consented outflow limits, it is not expected that water quality will be reduced owing to them. Analysis of visitor figures led to conclusion that a growing population in the District will not lead to disturbance to bird species.

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SPA Site Somerset Levels and Moors Feature Sub Feature(s) Sensitivity Conservation Target Potential Implications Preventative Mitigation Compensation Impact on effect of for integrity measures integrity policy (without action) Common teal 3.3% of the population Maintain the area of habitats used by Recreational N/A N/A N/A N/A No wintering birds within acceptable limits disturbance adverse (loss of 5% or more are unacceptable). to impact Based on the known natural designated upon fluctuations of the population in the bird species integrity site, maintain the population at or above the minimum for the site. Bewick's swan 2.7% of the GB population Maintain the area of habitats used by Recreational N/A N/A N/A N/A No wintering birds within acceptable limits disturbance adverse (loss of 5% or more are unacceptable). to impact Based on the known natural designated upon fluctuations of the population in the bird species integrity site, maintain the population at or above the minimum for the site. Golden plover 1.2% of the GB population Maintain the area of habitats used by Recreational N/A N/A N/A N/A No wintering birds within acceptable limits disturbance adverse (loss of 5% or more are unacceptable). to impact Based on the known natural designated upon fluctuations of the population in the bird species integrity site, maintain the population at or above the minimum for the site. Northern lapwing 0.5% of the population Maintain the area of habitats used by Recreational N/A N/A N/A N/A No wintering birds within acceptable limits disturbance adverse (loss of 5% or more are unacceptable). to impact Based on the known natural designated upon

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fluctuations of the population in the bird species integrity site, maintain the population at or above the minimum for the site. Assemblages of 73,014 waterfowl (5 year peak Maintain population within acceptable Recreational N/A N/A N/A N/A No waterfowl of mean 01/04/98). Sites are limits. Maintain the area of habitats disturbance adverse international sensitive and vulnerable to used by wintering birds within to impact importance conversion of grassland to acceptable limits (loss of 5% or more designated upon arable, land drainage, increased are unacceptable). Where the limits of bird species integrity applications of inorganic natural fluctuations are not known, fertilisers and silage cutting maintain the population above 50%. Potential effect Increasing incidence of recreational disturbance as a growing local population results in increased visitation to the site, and subsequent disturbance to over wintering birds and of policy on the their habitats. site Implications for the integrity of the site: Preventative measures: Mitigation: Compensation Analysis of visitor figures led to conclusion that a growing population will not N/A N/A N/A lead to disturbance to bird species. People visiting the site for recreation (walking, dog walking) were tending to travel shorter distances than those visiting to specifically to birdwatch, who, by their nature, would not be expected to disturb the wildlife they had come to observe. Furthermore, the designated species are present on the site over-winter, when far fewer people can be expected out on the Levels and Moors.

Overall Summary

Potential / likely effect of policy Recreational disturbance to designated bird species, and adverse impacts upon Red Data Book invertebrates owing to reduced water quality. Implications for the integrity of the site: Preventative measures: Mitigation: Compensation Consultation with Wessex Water concluded that as proposed developments will not result in exceedance of N/A N/A N/A consented outflow limits, it is not expected that water quality will be reduced owing to them. Analysis of visitor figures led to conclusion that a growing population in the District will not lead to disturbance to bird species.

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APPENDIX B: WESSEX WATER SEWAGE TREATMENT WORKS INFORMATION

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STW Abstraction/ Available capacity Percentage of serving water supply for development Consented Consented Settlement settlement point within consent DWF m3/d DWF Works p.e. Further comments Wimbleball/ AMP5 scheme to increase DWF Taunton Clatworthy and consent to 30,595m3/d will provide for Taunton (Ham) Fulwood Yes 21,680 80% 84,760 increased loads from development Wimbleball/ Wellington Wellington Clatworthy Yes 3,750 78% 14,092 No exceedence expected 2010 -2015 No exceedence expected during 2010 Wimbleball/ -2015. Hillsmoor STW recently Hillsmoor Clatworthy Yes 627 37% 2,832 expanded. Wiveliscombe Styles Yes 318 110% 1,288 Consent under review No exceedence expected during 2010 -2015. New works to be constructed to meet consent tightening. Depending Bishops Bishops Wimbleball/ on development location flow could go Lydeard Lydeard Clatworthy Yes 677 80% 2,068 to Bishops Lydeard or Sandhill Park. Cotford St Wimbleball/ Luke Clatworthy Yes In Taunton catchment see above Wimbleball/ Milverton Milverton Clatworthy Yes 400 67% 1,555 No exceedence expected 2010 -2015 No exceedence expected 2010 -2015. Capacity of transfer pumping station, Wimbleball/ rising main and sewers needs to be Oake Milverton Clatworthy Yes 400 67% 1,555 reviewed Creech St Wimbleball/ Michael Clatworthy Yes In Taunton catchment see above Stoke St Wimbleball/ No exceedence expected during 2010 North Curry Gregory Clatworthy Yes 310 66% 1,638 -2015 Churchinford Fulwood Yes Located in South West Water region

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