Habitats Regulations Assessment of the South Worcestershire Development Plan Review

Interim HRA to support the plan making process

November 2019

Interim HRA to support the plan making process Preferred Options

LC-578 Document Control Box

Client Malvern Hills District Council

Habitats Regulations Assessment of the South Worcestershire Development Report Title Plan: Preferred Options

Status Final Interim HRA

Filename LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx

Date November 2019

Author LB

Reviewed SC

Approved ND

Photo: Bredon Hill by Lepus Consulting

South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx Contents 1 Introduction ...... 1 1.2 The HRA process ...... 2 2 SWDPR ...... 5 2.1 South Worcestershire Development Plan Review ...... 5 2.2 Background to the Local Plan Development ...... 5 2.3 Previous HRA Work ...... 7 2.4 Purpose of Report ...... 8 3 Methodology ...... 10 3.1 HRA guidance ...... 10 3.2 Identification of European sites ...... 10 3.3 HRA methodology ...... 12 3.4 Stage 1: Screening for likely significant effects ...... 12 3.5 What is a Likely Significant Effect? ...... 14 3.6 In-combination effects ...... 16 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 3.11 European sites ...... 21 3.12 Ecological information ...... 24 4 Threats and pressures ...... 27 4.2 Air quality ...... 33 4.3 Hydrology ...... 38 4.4 Habitat fragmentation and loss ...... 44 4.5 Public access and disturbance ...... 45 4.6 In-combination screening ...... 47 5 Screening ...... 48 5.1 Bredon Hill SAC ...... 48 5.2 Lyppard Grange Ponds SAC ...... 50 5.3 Dixton Wood SAC ...... 52 5.4 Downton Gorge SAC ...... 54 5.5 River Clun SAC ...... 57 5.6 River Wye SAC ...... 59 5.7 Severn Estuary SAC/SPA/Ramsar/EMS ...... 61 5.8 Walmore Common SPA/Ramsar ...... 64 5.9 Fens Pools SAC ...... 66 5.10 Draft policy screening ...... 68 5.11 Sites screening ...... 69 6 Next Steps ...... 70 6.1 Summary ...... 70 6.2 Recommendations ...... 70 6.3 Next steps ...... 70

Appendix A: Draft policies – screening Appendix B: In-combination assessment Appendix C: Europoean site conservation objectives Appendix D: European sites and corresponding SSSI conservation status Appendix E: European sites threats/pressures

© Lepus Consulting for Malvern Hills District Council i South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx List of Figures

Figure 1.1: Stages in the Habitats Regulations Assessment process...... 4 Figure 3.1: Outline of steps in stage 1; the whole screening process...... 13 Figure 3.2: Outline of the in-combination pre-screening assessment methodology ...... 16 Figure 3.3: European sites within HRA study area ...... 23 Figure 4.1: Traffic contribution to pollution concentration at different distances from road centre ... 35

List of Tables

Table 2.1: Potential LSEs upon European sites identified in SWDP Pre-Submission HRA 2012...... 7 Table 3.1: Assessment and reasoning categories from Part F of the DTA Handbook ...... 14 Table 4.1: Pressures and threats for Qualifying Features of European sites that may potentially be affected by the Local Plan...... 29 Table 4.2: Inflow and outflow traffic over 1,000 AADT for each district within South Worcestershire ...... 38 Table 5.1: Summary of screened in policies ...... 69

© Lepus Consulting for Malvern Hills District Council ii South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx Abbreviations

AA Appropriate Assessment AADT Annual Average Daily Traffic APIS Air Pollution Information System 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 EMS European Marine Site EU European Union EUNIS European Nature Information System GIS Geographic Information System ha Hectares HDV Heavy Duty Vehicles HRA Habitats Regulations Assessment IRZ Impact Risk Zone IUCN International Union for Conservation of Nature JNCC Joint Nature Conservation Committee km Kilometre LPA Local Planning Authority LSE Likely Significant Effect m Metre N Nitrogen NE Natural England NO2 Nitrogen Dioxide NOx Nitrogen Oxides NPPF National Planning Policy Framework NPPG National Planning Practice Guidance OAHN Objectively Assessed Housing Need PRoW Public Right of Way RBMP River Basin Management Plan RSPB Royal Society for the Protection of Birds SAC Special Area of Conservation SIP Site Improvement Plan SPA Special Protection Area

SPZ Source Protection Zone SSSI Site of Special Scientific Interest STW Severn Trent Water SuDS Sustainable Urban Drainage SWCs South Worcestershire Councils SWDP South Worcestershire Development Plan SWDPR South Worcestershire Development Plan Review UK United Kingdom WFD Water Framework Directive WWT Wildfowl and Wetlands Trust WwTW Wastewater Treatment Works

© Lepus Consulting for Malvern Hills District Council iv South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx 1 Introduction

1.1.1 The South Worcestershire Development Plan (SWDP) was adopted in February 2016. It forms a sub-regional land use plan, prepared jointly by the three South Worcestershire Councils (SWCs); Malvern Hills, Worcester City and Wychavon, working together under informal plan making arrangements. The SWDP deals with both strategic cross boundary matters, including overall housing and employment requirements, and also includes detailed policies that are used in decisions on planning applications on a day to day basis by the SWCs.

1.1.2 Following recent changes to national legislation and the revision of the National Planning Policy Framework (NPPF)1 and National Planning Practice Guidance (NPPG) 2, the SWCs are working together to undertake a review of the SWDP, known as the South Worcestershire Development Plan Review (SWDPR).

1.1.3 Lepus Consulting has prepared this report to inform the Habitats Regulations Assessment (HRA) of the SWDPR (referred to hereafter as the ‘Local Plan’) on behalf of the SWCs. The Local Plan will cover the period from 2016 to 2041 and extends across the whole of South Worcestershire comprising the three districts of Malvern Hills, Wychavon and Worcester (referred to hereafter as the ‘Plan area’).

1.1.4 The HRA has been prepared in accordance with the Conservation of Habitats and Species Regulations 20173 (the Habitats Regulations). When preparing development plan documents, Councils are required by law to carry out an 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 Ministry of Housing, Communities & Local Government (2019) National Planning Policy Framework. Available at: https://www.gov.uk/government/publications/national-planning-policy-framework--2 [Date Accessed: 05/11/19] 2 National Planning Practice Guidance. Available at: https://www.gov.uk/government/collections/planning-practice- guidance [Date Accessed: 05/11/19] 3 The Conservation of Habitats and Species Regulations 2017 (2017) SI No. 2017/1012, TSO (The Stationery Office), London.

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 Habitats4 and Birds5 Directives. These sites form a system of internationally important sites throughout Europe known collectively as the ‘Natura 2000 Network’.

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)6. Additionally, paragraph 176 of the National Planning Policy Framework (NPPF)7 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 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 Regulations’8, which forms part F, has therefore been 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.

4 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. 5 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. 6 A European Marine Site is a European site (SPAs or SACs) so far as it consists of marine areas (are below the Mean High Water Mark) and to the 12nm limit of territorial seas. 7 Ministry of Housing, Communities & Local Government (2019). National Planning Policy Framework. 8 Tyldesley, D., and Chapman, C. (2013) The Habitats Regulations Assessment Handbook (September) (2013) edition UK: DTA Publications Limited. Available at: www.dtapublications.co.uk

1.2.4 A step-by-step guide to the 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’: 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 the SWCs). This stage comprises an impact assessment and evaluation in view of a European site’s conservation objectives. Where adverse impacts on 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 Stage 1 of the HRA process.

1.2.6 This report is structured as follows:

• Chapter 1: Introduction; • Chapter 2: Local Plan; • Chapter 3: Methodology; • Chapter 4: Screening; and • Chapter 5: Next steps.

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 Assessment process9.

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

© Lepus Consulting for Malvern Hills District Council 4 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx 2 SWDPR

2.1 South Worcestershire Development Plan Review

2.1.1 The SWCs are in the process of undertaking the South Worcestershire Development Plan Review (SWDPR). The review began in late 2017, in line with government requirements that Local Plans should be updated every five years. The adopted South Worcestershire Development Plan covers the period up until 203010. Following the SWDPR, the emerging Local Plan will cover the period to 2041.

2.1.2 The Local Plan will replace the existing SWDP and provide an update in terms of the Vision, Objectives, Spatial Strategy, policies and site allocations in order to meet the needs of the population throughout the Plan period.

2.1.3 The policies that form the Local Plan sit under a number of sections as follows:

• Vision and Objectives; • Strategic Policies; • Non-Strategic Policies; • Site Allocations; and • Implementation and Monitoring.

2.2 Background to the Local Plan Development

2.2.1 The emerging Local Plan will update the existing SWDP and development strategy. It is likely that many of the existing allocated sites that have not yet been developed will continue to be allocated for development, and a number of the existing policies will be carried forward. New sites will also be considered in order to meet the updated housing requirements for the extended Plan period.

10 South Worcestershire Councils (2019) South Worcestershire Development Plan. Available at: https://www.swdevelopmentplan.org/ [Date Accessed: 29/10/19]

2.2.2 In 2017, the SWCs began collating a technical evidence base to inform the Regulation 18(I) Issues and Options consultation paper. This set out the main challenges and issues in South Worcestershire and options to plan for future growth. The SWCs consulted on the Issues and Options Regulation 18(I) paper between November and December 2018. It included options for the quantity of residential, employment and gypsy and traveller development that should be delivered through the Local Plan as well as various spatial strategy options which would help to deliver development.

2.2.3 The SWCs are now progressing the review of the Local Plan and the Regulation 18(II) Preferred Options Consultation is currently being undertaken and will run from November to December 2019. This HRA report has been produced to inform and support this stage of the plan- making process.

2.2.4 The Regulation 18(II) stage will take into consideration the evidence produced to date and findings from the previous Issues and Options Consultation (Regulation 18(II)).

2.2.5 A full list of the proposed draft policies (and draft site allocations which sit within Policies SWDPR 49 to 55) are presented in Appendix A11.

11 SWCs. SWDPR Preferred Options Document. Version 2. Available at: https://moderngov.malvernhills.gov.uk/documents/s30600/C446%20APP1%20- %20SWDPR%20Preferred%20Options%20Document%20V2.pdf?J=1

2.3 Previous HRA Work

2.3.1 As part of the existing SWDP12 a Habitats Regulations Assessment13 was undertaken on behalf of the SWCs. The purpose of the report was to identify any aspects of the SWDP that would have the potential to cause a likely significant effect on a number of European sites either in isolation or in-combination with other plans and projects.

2.3.2 The initial HRA screening concluded that there was uncertainty in terms of potential significant effects as a result of the Plan at two European sites; Bredon Hill SAC and Lyppard Grange Ponds SAC. In addition, uncertainties in regard to potential in-combination effects at a number of European sites were identified. A summary of these potential significant effects is set out in Table 2.1 below.

Table 2.1: Potential LSEs upon European sites identified in SWDP Pre-Submission HRA 2012.

European Site Potential Significant Effect

Bredon Hill SAC Recreational disturbance Recreational activity can have adverse impacts on the characteristics of the site such as physical disturbance/removal of decaying wood that supports the Violet Click Beetle.

Lyppard Grange Ponds Recreational disturbance SAC Recreational disturbance can have adverse impacts on the characteristics of the site such as physical disturbance/littering of habitats that support the Great Crested Newt.

In-combination – water quantity Increased abstraction, pressure on sewerage capacity and surface water runoff could potentially result in reduced water levels and, as such, impact the integrity of water-dependent European sites.

River Wye SAC In-combination – water quantity Increased abstraction, pressure on sewerage capacity and surface water runoff could potentially result in reduced water levels and, as such, impact the integrity of water-dependent European sites.

Severn Estuary In-combination – water quality and quantity SAC/SPA/Ramsar/EMS Increased abstraction, pressure on sewerage capacity and surface runoff could potentially result in reduced water levels. Increased Walmore Common SPA/Ramsar discharge and surface runoff could potentially result in increased transfer of pollutants, and as such reduce water quality in the River Severn including the Severn Estuary and adjacent Walmore Common.

12 South Worcestershire Development Plan (2016) The Adopted South Worcestershire Development Plan (SWDP) 2016. Available at: https://www.swdevelopmentplan.org/?page_id=12262 [Date Accessed: 05/11/19] 13 Enfusion (2012) South Worcestershire Development Plan Pre-Submission Consultation Habitats Regulations Assessment (Appropriate Assessment) Report. Available at: https://www.swdevelopmentplan.org/wp- content/uploads/2013/05/PreSubmissionHR_AA_Report.pdf [Date Accessed: 28/10/19]

2.3.3 After consideration of the site-specific information, the location of the proposed development within the Plan and the mitigating impact of the SWDP policies, the Appropriate Assessment (AA) concluded that the SWDP would not have an adverse impact on the integrity of the identified European sites, alone or in-combination.

2.3.4 Following the SWDP Proposed Main Modifications, which included a review of the total housing requirements in line with the new Objectively Assessed Housing Need (OAHN), a further HRA Addendum Report (September 2014)14 was produced.

2.3.5 HRA screening of the key changes proposed in the Main Modifications in 2014, and further amendments in 201515, concluded that the findings of the previous HRA work were not significantly affected, and that the Plan would have no adverse effects on the integrity of European sites, alone or in- combination.

2.4 Purpose of Report

2.4.1 The purpose of this HRA report is to ensure that the Local Plan maintains the integrity of European sites in line with the requirements of the Habitats Regulations. It is not intended to provide information to allow the SWCs, as the Competent Authority, to make the Integrity Test (Stage 2 of the HRA process) since the detail of the plan is still being prepared. The Report to Inform the HRA, and enable the SWCs to make the Integrity Test, will be produced at the Regulation 19 stage of the plan-making process.

14 Enfusion (2014) South Worcestershire Development Plan: Habitats Regulations Assessment Addendum Report. Available at: https://www.swdevelopmentplan.org/wp- content/uploads/2014/09/HabitatRAAddendumReportSept2014.pdf [Date Accessed: 28/10/19] 15 Enfusion (2015) South Worcestershire Development Plan: Habitats Regulations Assessment Further Addendum Report. Available at: https://www.swdevelopmentplan.org/wp-content/uploads/2015/09/Habitat-Regulation- Assessment-Main-Report-Sept2015.pdf [Date Accessed: 28/10/19]

2.4.2 The final components of the Local Plan (policies and site allocations etc) are not known at this stage of the plan-making process and associated therefore impacts on European sites cannot be assessed with certainty. This report provides information to allow the SWCs to ensure that the plan- making process proceeds in accordance with the Habitats Regulations and avoids adverse impacts on the integrity of European sites. It is also intended to explore, and if necessary, identify any requirements for supplementary detailed technical studies that may be required to input to the HRA process and inform an Appropriate Assessment (Stage 2 of the HRA process).

2.4.3 This report comprises a preliminary screening assessment (Stage 1 of the HRA process – see Figure 1.1) of the preferred draft policies and allocations16 and sets the scope of work for more detailed appropriate assessment (Stage 2 of the HRA process – see Figure 1.1). All HRA work will be refreshed and updated alongside preparation of the Regulation 19 version of the Local Plan once selection of the final preferred policies and allocations have been defined.

16 WCs. SWDPR Preferred Options Document. Version 2. Available at: https://moderngov.malvernhills.gov.uk/documents/s30600/C446%20APP1%20- %20SWDPR%20Preferred%20Options%20Document%20V2.pdf?J=1

© Lepus Consulting for Malvern Hills District Council 9 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Screening Report_11_141119SC.docx 3 Methodology

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 (as amended)17, 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, 200118; • Planning Practice Guidance: Appropriate Assessment19; • 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, 200720.

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 The Conservation of Habitats and Species Regulations (Various Amendments) (England and Wales) 2018. Regulation SI No. 1307.

18 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 19 Ministry of Housing, Communities and Local Government (July 2019) Planning Practice Guidance Note, Appropriate Assessment, Guidance on the use of Habitats Regulations Assessment 20 RSPB (2007). The Appropriate Assessment of Spatial Plans in England. A Guide to How, When and Why to do it.

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 Local Plan and their relationship to European sites.

3.2.4 The 2012 HRA reports on the previous SWDP (see Section 2.3) considered the scope of the HRA using a ‘source-pathway-receptor’ model. The 2012 HRA provided an assessment of the previous SWDP on ten European sites within the influence of the SWDP.

3.2.5 The European sites to be assessed in this HRA report, taking into consideration impact pathways and previous HRA work undertaken in 2012, include the following:

• Bredon Hill SAC (located wholly within the Plan area); • Lyppard Grange Ponds SAC (located wholly within the Plan area); • Dixton Wood SAC (located approximately 2.3km to the south of the Plan area); • River Wye SAC (located approximately 8.7km to the south west of the Plan area); • Downton Gorge SAC (located approximately 11.6km to the north west of the Plan area); • Walmore Common SPA/Ramsar (located approximately 15.2km to the south of the Plan area); • Fens Pools SAC (located approximately 15.8km to the north of the Plan area); • River Clun SAC (located approximately 16km to the north west of the Plan area); and • Severn Estuary SAC/SPA/Ramsar/ European Marine Site (EMS) (located approximately 21.8km to the south of the Plan area).

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 of the HRA process.

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 (LSEs) 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.

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 whole screening process.

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 Chapter 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 identified during the HRA screening process. 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’”21.

21Tyldesley, D. (2013) The Habitats Regulations Assessment Handbook – Chapter F. DTA Publications

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 ‘Sweetman’22 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 SWCs to show that the Local Plan will result in no effects whatsoever on any European site. Instead, the SWCs are required to show that the Local Plan, 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’23 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”.

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

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

3.6 In-combination effects

3.6.1 As well as considering the LSEs of the Local Plan 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 Local Plan 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.

Outline of the in-combination pre-screening assessment methodology

Assembling basic information about the effects of the subject plan (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 plan provides 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 might be significant (step 9)

Noting the outcome of the in-combination pre-screening process (step 10)

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

3.6.3 Plans and projects which are considered to be of most relevance to the in- combination assessment of the Local Plan include those that have similar impact pathways. These include those plans that have the potential to increase development in the HRA 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 Local Plan, such as transport, waste and mineral plans and projects, have also been taken into consideration. Plans which allocate water resources or are likely to influence water quality in the study area have also been considered. Finally, neighbouring authority local plans which may increase development public access and disturbance pressures at European sites have also been considered.

3.6.4 It is recognised that the status of other plans and projects will change over the timescale of the SWDPR process. As such, and for the purposes of this stage of the HRA process, a high-level review of relevant plans and projects has been undertaken (see Appendix B). A more detailed review and assessment will take place at Regulation 19. The plans and projects which have been included in the in-combination assessment include the following:

• Borough of Redditch Local Plan; • Bromsgrove District Plan; • Cotswold District Local Plan; • Forest of Dean District Local Plan; • Herefordshire Local Plan Core Strategy; • Shropshire Local Plan; • Stratford-on-Avon District Core Strategy; • Tewkesbury Borough Plan; • Wyre Forest District Local Plan; • Worcestershire Local Transport Plan; • Worcestershire Minerals Local Plan; • Worcestershire Waste Core Strategy; • Severn River Basin Management Plan; • Severn Trent Water Resource Management Plan; and • Worcestershire Middle Severn CaBA Catchment Management Plan.

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)24.

3.7 Case law

3.7.1 The recent European Court Judgement on the interpretation of the Habitats Directive in the case of People Over Wind and Sweetman vs Colitte Teoranta (Case C-323/1725) 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:

• “Measures intended to avoid or reduce harmful effects on a European site; or

24 National Infrastructure Planning (2012) Available at: https://infrastructure.planninginspectorate.gov.uk/projects/ [Date Accessed: 05/11/19] 25 InfoCuria (2018) Case C-323/17. Available at: http://curia.europa.eu/juris/document/document.jsf?docid=200970&doclang=EN [Date Accessed: 05/11/19]

• 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 process undertaken for the Local Plan 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 LSE of the Local Plan 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 ruling26 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 also 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 borough’s 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 the Local Plan both alone and in-combination with other plans and projects. This approach is compliant with the Wealden Judgement.

26 Wealden District Council & Lewes District Council before Mr Justice Jay. Available at: http://www.bailii.org/ew/cases/EWHC/Admin/2017/351.html [Date Accessed: 28/10/19]

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 consideration 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 risk, 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 Local Plan 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 Local Plan 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 Local Plan 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’ ruling27:

27EC Case C-127/02 Reference for a Preliminary Ruling ‘Waddenzee’ 7th September 2004 Advocate General’s Opinion (para 107)

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”.

3.11 European sites

3.11.1 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).

3.11.2 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.

3.11.3 As set out in Section 3.2.4, the HRA provides an assessment of adverse effects associated with the Local Plan (both alone and in-combination) on a number of European sites as illustrated in Figure 3.3.

Figure 3.3: European sites within HRA study area

3.12 Ecological information

3.12.1 The CJEU ruling in the Holohan case (C-461/1728) 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”.

3.12.2 This report 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.

28 EUR-Lex (2018) Case C-461/17. Available at: https://eur-lex.europa.eu/legal- content/EN/TXT/PDF/?uri=CELEX:62017CJ0461&from=EN [Date Accessed: 05/11/19]

3.12.3 Appendix C 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)29 and Natural England30.

3.12.4 SSSIs 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.

3.12.5 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 D 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.

3.12.6 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.

29 JNCC (2019) Available at: http://jncc.defra.gov.uk/page-1458 [Date Accessed: 05/11/19] 30 Natural England (2019) Available at: http://publications.naturalengland.org.uk/ [Date Accessed: 05/11/19]

3.12.7 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”31. 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 Local Plan.

31 Natural England (2019) Natural England’s Impact Risk Zones for Sites of Special Scientific Interest User Guidance. Available at: https://magic.defra.gov.uk/Metadata_for_magic/SSSI%20IRZ%20User%20Guidance%20MAGIC.pdf [Date Accessed: 05/11/19]

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4.1.1 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 E.

4.1.2 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.

4.1.3 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 Local Plan. The following threats and pressures are, therefore, not considered further in this assessment:

• Change in land management; • Changes in species distributions; • Climate change; • Coastal squeeze; • Deer; • Disease; • Energy production; • Feature location/extent unknown; • Fisheries (including commercial, fish stocking and freshwater); • Forestry and woodland management; • Game management; • Inappropriate scrub control; • Invasive species; • Low breeding success/poor recruitment; • Marine consents and permits; • Marine litter; • Marine pollution incidents; • Overgrazing; • Physical modification; • Siltation; • Transportation and service corridors; and

• Undergrazing.

4.1.4 Following a review of HRA assessment work undertaken to date for the previous SWDP and an identification of causal connections and links, the remaining threats and pressures that were considered to be within the scope of influence of the Local Plan include:

• Air pollution; • Habitat loss and fragmentation (to include offsite habitat availability/management); • Hydrological changes (to include water abstraction and water pollution); and • Public access and disturbance (to include impacts of development and recreational impacts).

4.1.5 A summary of the threats and pressures identified within SIPs are presented in Table 4.1 below, and further information from supplementary advice and other potential vulnerabilities are discussed within Section 5.

Table 4.1: Pressures and threats for Qualifying Features of European sites that may potentially be affected by the Local Plan. Severn Threats/ Lyppard Walmore Downton Estuary Pressures Bredon Hill Dixton Wood Fens Pools Grange River Clun River Wye Common Gorge (SPA, SAC, data from (SAC)32 (SAC)33 (SAC)35 Ponds (SAC)37 (SAC)38 (SPA and (SAC)34 Ramsar and SIPs (SAC)36 Ramsar)40 EMS)39 A051(NB) Gadwall H1130 Estuaries H9180 Mixed H7140 Very H1330 woodland on wet mires Atlantic salt base-rich often meadows S1079 Violet Air Pollution - soils - - - identified by S1095 Sea - click beetle associated an unstable lamprey with rocky ‘quaking’ S1099 River slopes surface lamprey S1103 Twaite shad Waterbird assemblage

32 Natural England (2015) Site Improvement Plan: Bredon Hill. Available at: http://publications.naturalengland.org.uk/file/5656925612015616 [Date Accessed: 24/10/19] 33 Natural England (2015) Site Improvement Plan: Dixton Woods. Available at: http://publications.naturalengland.org.uk/file/5985381096882176 [Date Accessed: 24/10/19] 34 Natural England (2014) Site Improvement Plan: Downton Gorge. Available at: http://publications.naturalengland.org.uk/file/6447596417581056 [Date Accessed: 24/10/19] 35 Natural England (2014) Site Improvement Plan: Fens Pools. Available at: http://publications.naturalengland.org.uk/file/4872756676001792 [Date Accessed: 30/10/19] 36 Natural England (2014) Site Improvement Plan: Lyppard Grange Ponds. Available at: http://publications.naturalengland.org.uk/file/5540066784968704 [Date Accessed: 24/10/19] 37 Natural England (2014) Site Improvement Plan: River Clun. Available at: http://publications.naturalengland.org.uk/file/5739115140087808 [Date Accessed: 30/10/19] 38 Natural England (2014) Site Improvement Plan: River Wye. Available at: http://publications.naturalengland.org.uk/file/5550181483282432 [Date Accessed: 24/10/19] 39 Natural England (2015) Site Improvement Plan: Severn Estuary Mor Hafren. Available at: http://publications.naturalengland.org.uk/file/4856107648417792 [Date Accessed: 24/10/19] 40 Natural England (2014) Site Improvement Plan: Walmore Common. Available at: http://publications.naturalengland.org.uk/file/6299182977515520 [Date Accessed: 24/10/19]

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Severn Threats/ Lyppard Walmore Downton Estuary Pressures Bredon Hill Dixton Wood Fens Pools Grange River Clun River Wye Common Gorge (SPA, SAC, data from (SAC)32 (SAC)33 (SAC)35 Ponds (SAC)37 (SAC)38 (SPA and (SAC)34 Ramsar and SIPs (SAC)36 Ramsar)40 EMS)39 H9180 Mixed Habitat loss woodland on and base-rich A037(NB) fragmentation S1166 Great - - soils - - - - Bewick's (to include crested newt associated Swan offsite habitat with rocky availability) slopes H3260 Rivers A037(NB) with floating Bewick's vegetation swan often A048(NB) dominated by Common watercrowfoot shelduck S1092 White- A051(NB) clawed (or Gadwall Atlantic A149(NB) stream) Dunlin Hydrological crayfish A162(NB) changes (to S1029 S1095 Sea Common A037(NB) include water S1166 Great - - - - Freshwater lamprey redshank Bewick's abstraction crested newt mussel S1096 Brook A394(NB) Swan and water lamprey Greater pollution) S1099 River white- lamprey fronted S1102 Allis goose shad H1110 S1103 Twaite Subtidal shad sandbanks S1106 Atlantic H1130 salmon Estuaries S1163 Bullhead H1140 S1355 Otter Intertidal

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Severn Threats/ Lyppard Walmore Downton Estuary Pressures Bredon Hill Dixton Wood Fens Pools Grange River Clun River Wye Common Gorge (SPA, SAC, data from (SAC)32 (SAC)33 (SAC)35 Ponds (SAC)37 (SAC)38 (SPA and (SAC)34 Ramsar and SIPs (SAC)36 Ramsar)40 EMS)39 mudflats and sandflats H1170 Reefs H1330 Atlantic salt meadows S1095 Sea lamprey S1099 River lamprey S1103 Twaite shad Waterbird assemblage A037(NB) H3260 Rivers Bewick's with floating swan vegetation A048(NB) often Common dominated by Public shelduck watercrowfoot access/ A051(NB) S1092 White- disturbance Gadwall clawed (or A037(NB) (to include A149(NB) ------Atlantic Bewick's impacts of Dunlin stream) Swan development A162(NB) crayfish and Common S1095 Sea recreation) redshank lamprey A394(NB) S1096 Brook Greater lamprey white- S1099 River fronted lamprey goose

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4.2 Air quality

4.2.1 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)41. Deposition of air pollutants can alter the soil and plant composition and species which depend upon these.

4.2.2 Excess atmospheric nitrogen deposition within an ecosystem or habitat can disrupt the delicate balance of ecological processes interacting with one another. As the availability of nitrogen increases in the local environment, some plants that are characteristic of that ecosystem may become competitively excluded in favour of more nitrophilic plants. It also upsets the ammonium and nitrate balance of the ecosystem, which disrupts the growth, structure and resilience of some plant species.

4.2.3 Excess nitrogen deposition often leads to the acidification of soils and a reduction in the soils’ buffering capacity (the ability of soil to resist pH changes). It can also render the ecosystem more susceptible to adverse effects of secondary stresses, such as frost or drought, and disturbance events, such as foraging by herbivores.

4.2.4 As an attempt to manage the negative consequences of atmospheric nitrogen deposition, ‘critical loads’ have been established for ecosystems in Europe. Each European site is host to a variety of habitats and species, the features of which are often designated a critical load for nitrogen deposition. The critical loads of pollutants are defined as a:

4.2.5 “…quantitative estimate of exposure to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge”42.

41 APIS (2016) Ecosystem Services and air pollution impacts. Available at: http://www.apis.ac.uk/ecosystem- services-and-air-pollution-impacts. [Date Accessed: 05/11/19] 42 UNECE (date unavailable) ICP Modeling and Mapping Critical loads and levels approach. Available at: http://www.unece.org/env/lrtap/WorkingGroups/wge/definitions.html [Date Accessed: 07/08/19]

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4.2.6 Natural England’s advice on the assessment of air quality impacts under the Habitats Regulations states that consideration should be given to the risk of road traffic emissions associated with a Local Plan43. This advice states that an assessment of the risks from road traffic emissions can be expressed in terms of the average annual daily traffic flow (AADT as a proxy for emissions). The use of the AADT screening threshold is advocated by Highways England in their Design Manual for Roads and Bridges (DMRB). This screening threshold is intended to be used as a guide to determine whether a more detailed assessment of the impact of emissions from road traffic is required. This non-statutory or guideline threshold is based on a predicted change of daily traffic flows of 1,000 AADT or more (or heavy-duty vehicle flows on motorways (HDV) change by 200 AADT or more).

4.2.7 The AADT thresholds do not themselves imply any intrinsic environmental effects and are used solely as a trigger for further investigation. Widely accepted environmental benchmarks for imperceptible impacts are set at 1% of the critical load or level, which is considered to be roughly equivalent to DMRB thresholds for changes in traffic flow of 1,000 AADT and for HDV of 200 AADT. This has been confirmed by modelling using the DMRB Screening Tool that used average traffic flow and speed figures from the Department of Transport

(DfT) data to calculate whether the NOx outputs could result in a change of >1% of critical load / level on different road types. A change of >1,000 AADT on a road was found to equate to a change in traffic flow which might increase emissions by 1% of the Critical Load or Level and might consequentially result in an environmental effect nearby (e.g. within 10 metres of roadside).

4.2.8 The AADT thresholds and 1% of critical load/level are considered by Natural England to be suitably precautionary as any emissions below this level are widely considered to be imperceptible and, in the case of AADT, undetectable through the DMRB model. There can, therefore, be a high degree of confidence in its application to screen for risks of an effect.

43 Natural England (2018) Natural England’s approach to advising competent authorities on the assessment of road traffic emissions under the Habitats Regulations (NEA001). Available at: http://publications.naturalengland.org.uk/publication/4720542048845824 [Date Accessed: 28/10/19]

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4.2.9 It is widely accepted that the effects of air pollutants from road transport decrease with distance from the source of pollution i.e. the road carriageway44,45,46. The Department for Transport (DfT) in their Transport Analysis Guidance (TAG) consider that, “beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”47. This is illustrated in Figure 4.1. This statement is supported by Highways England and Natural England based on evidence presented in a number of research papers48,49. However, it is also noted that effects can, in some circumstances, occur beyond 200m.

Figure 4.1: Traffic contribution to pollution concentration at different distances from road centre

44 The Highways Agency, Transport Scotland, Welsh Assembly Government, The Department for Regional Development Northern Ireland (2007) Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1: Air Quality. 45 Natural England (2016) The ecological effects of air pollution from road transport: an updated review. Natural England Commissioned Report NECR 199. 46 Bignal, K., Ashmore, M. & Power, S. (2004) The ecological effects of diffuse air pollution from road transport. English Nature Research Report No. 580, Peterborough. 47 Department for Transport (2015) TAG UNIT A3 Environmental Impact Appraisal. Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/487684/TAG_unit_a3_envir_imp _app_dec_15.pdf’ [Date Accessed: 28/10/19] 48 Bignal, K., Ashmore, M & Power, S. (2004) The ecological effects of diffuse air pollution from road transport. English Nature Research Report No. 580, Peterborough. 49 Ricardo-AEA (2016) The ecological effects of air pollution from road transport: an updated review. Natural England Commissioned Report No. 199.

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4.2.10 Advice from Natural England50 states that a four-step process for screening if there will be an LSE from air pollution should be adopted as follows:

• Step 1: Does the proposal give rise to emissions which are likely to reach a European site? As noted above, distance-based criteria have been established by Natural England and Highways England to determine the likely impact of air pollution from a road source on a European site. This distance was taken as 200m for the purposes of this assessment. For the purpose of this screening assessment it has been assumed that roads forming part of the strategic road network (motorways, ‘A’ roads and ‘B’ roads) are likely to experience the most significant increases in vehicle traffic as a result of development (i.e. greater than 1,000 AADT). However, where a European site is located within 200 metres of a minor road, LSEs from traffic-related air pollution have been screened in on a precautionary basis. These road links will be subject to further analysed following receipt of traffic modelling data which has been commissioned to inform the SWDPR process. • Step 2: Are the qualifying features of sites within 200m of a road sensitive to air pollution? The sensitivity of qualifying features was determined following a review of broad category and site relevant information which in some cases required site surveys. • Step 3: Could the sensitive qualifying features of the site be exposed to emissions? • Step 4: Application of screening thresholds: o Step 4a: Apply the thresholds alone. Where a proposal is considered to have an LSE because it breaches the screening threshold alone it should go through to an appropriate assessment ‘alone’. There is no need to consider the potential for in-combination effects at the screening step as an appropriate assessment is needed in any event. If the predicted change in traffic flow is less than 1,000 AADT (or the level of emissions is <1% of the critical load/level), the associated emissions are not likely to have a significant effect alone, but the risk of in-combination effects should be considered further. o Step 4b: Apply the threshold in-combination with emissions from other road traffic plans and projects. Where a proposal is below the screening threshold ‘alone’ (step 4a), step 4b must be considered to apply the same screening threshold ‘in-combination’.

50 Natural England (2018). Natural England’s approach to advising competent authorities on the assessment of road traffic emissions under the Habitats Regulations. Version June 2018.

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o Step 4c: Apply the threshold in-combination with emissions from other non-road plans and projects. Consider non-road plans and projects to recognise in-combination effects from other pollution sources.

4.2.11 Consideration of the screening thresholds set out above must be applied for both the Local Plan alone and in-combination with other plans and projects. This is because any increase in traffic flows may lead to in- combination effects on the European sites. Vehicle movements generated by different plans and projects are likely to increase the traffic on the same roads. This approach is compliant with the Wealden Judgement which determined that traffic and roads are a cross boundary issue (see Box 2). The high court ruling on 20 March 201751 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. If the combined effects of borough’s development will lead to increases of traffic of more than 1,000 AADT or if air quality modelling data indicates that there is going to be an increase in deposition loads of more than 1% on background levels; an LSE is anticipated.

4.2.12 The Office for National Statistics commuting data52 inflow and outflow traffic over 1,000 AADT for South Worcestershire (excluding travel between the three districts within South Worcestershire) is presented in Table 4.2 below.

51 Wealden District Council & Lewes District Council before Mr Justice Jay. Available at: http://www.bailii.org/ew/cases/EWHC/Admin/2017/351.html [Date Accessed: 28/10/19] 52 Office for National Statistics (2011) Location of usual residence and place of work by method of travel to work (2011 census data). Available at: https://www.nomisweb.co.uk/census/2011/wu03uk/chart [Date accessed: 28/10/19]

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Table 4.2: Inflow and outflow traffic over 1,000 AADT for each district within South Worcestershire Malvern Hills Wychavon Worcester

• Herefordshire – inflow • Wyre Forest – inflow • Wyre Forest – inflow 1,835 / outflow 1,341. 3,377 / outflow 1,043; 2,387; • Bromsgrove – inflow 1,556 • Bromsgrove – inflow 1,176; / outflow 1,522; • Herefordshire – inflow • Redditch – inflow 1,149 / 1,144; and outflow 1,198; • Birmingham – outflow • Birmingham – inflow 1,017 1,343. / outflow 1,952; • Stratford-upon-Avon – outflow 2,315; • Tewkesbury – outflow 1,865; • Cheltenham – outflow 1,073; and • Cotswolds – outflow 1,460.

4.2.13 Traffic modelling has been commissioned to support the SWDPR. This data will be analysed in the context of Natural England’s screening methods and, where required, further assessment will be undertaken. At the time of writing, the traffic modelling was not available and as such this screening assessment focuses on determining whether there are roads within 200m of a European site which may result in increased traffic flows as a consequence of the Local Plan and whether European sites have the potential to be sensitive to a reduction in air quality.

4.3 Hydrology

4.3.1 Potential hydrological effects of urbanisation within European sites can be associated with an alteration in water balance and reduced water quality.

4.3.2 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.

4.3.3 In addition, urbanisation 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. Water quality may also be reduced through effluent discharges and pollution as well as an increased water temperature.

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4.3.4 Features for which a European site is designated are often sensitive to changes in water balances and water quality. Therefore, urbanisation affecting drainage streams which flow through a European site has the potential to adversely affect the features for which it is designated.

4.3.5 Within South Worcestershire there are two major rivers; the River Severn and the River Avon. The River Severn enters the Plan area in the north at Stourport-on-Severn, where it forms the boundary between Wychavon and Malvern Hills, into the Worcester city centre and then south west into Gloucestershire at Tewkesbury. The River Salwarpe, Laughern Brook, River Teme and the Bushley Brook comprise some of the main tributaries of the River Severn, within the Plan area. The River Avon, meanwhile, enters South Worcestershire in the east from Bidford-on-Avon, before flowing west passing through Evesham and Pershore and joining the River Severn at Tewkesbury. The main tributaries of the River Avon within the Plan area include the Badsey Brook, River Isbourne, Merry Brook, Piddle Brook and the Bow Brook.

Water management plan review

4.3.6 The Plan area lies within the Severn Basin District area53. The Water Framework Directive (WFD) provides an indication of the health of the water environment and whether a water body is at good status or potential. This is determined through an assessment of a range of elements relating to the biology 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 single 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.

53 Environment Agency (2019) Catchment Data Explorer. Available at: https://environment.data.gov.uk/catchment- planning/RiverBasinDistrict/9 [Date Accessed: 05/11/19]

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4.3.7 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)”54.

4.3.8 A review of Environment Agency monitoring data55 indicated that in 2016 the Severn Basin District Area, which comprises 478 waterbodies, contained only 10 surface waterbodies which were classified as being of bad ecological status and 13 failing chemical status testing.

4.3.9 The Severn River Basin Management Plan (RBMP)56 provides a framework for protecting and enhancing the benefits provided by the water environment. To achieve this, and because water and land resources are closely linked, it also informs decisions on land-use planning. It provides strategic level policy guidance in relation to baseline classification of water bodies, statutory objectives for protected areas and water bodies and a summary of measures to achieve statutory protection.

4.3.10 The Severn RBMP sets out a number of water management issues to rivers within this river basin as follows:

• Physical modification; • Pollution from wastewater; • Pollution from towns cities and transport; • Changes to the natural flow and level of water; • Negative effects of invasive non-native species; • Pollution from rural areas; • Pollution from abandoned mines; and • Tackling climate change.

54 Official Journal of the European Communities (2000) 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. Available at: https://eur-lex.europa.eu/resource.html?uri=cellar:5c835afb-2ec6-4577-bdf8- 756d3d694eeb.0004.02/DOC_1&format=PDF [Date Accessed: 05/11/19] 55 Environment Agency (2019) Water Quality Monitoring Data Archive. Available at: https://environment.data.gov.uk/water-quality/view/landing [Date Accessed: 30/10/19] 56 Environment Agency (2015) Severn River Basin Management Plan. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/718336/Sever n_RBD_Part_1_river_basin_management_plan.pdf [Date Accessed: 30/10/19]

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4.3.11 The Severn RBMP outlines a number of measures to tackle these water management issues and achieve a series of environmental objectives set out within the plan. These are set out on a catchment basis. The Plan area sits within the Worcestershire Middle Severn catchment. Within this catchment the priority river basin management issues include reducing urban and rural pollution and seeking opportunities for natural solutions, such as woodlands for water.

4.3.12 An HRA was prepared alongside the development of the Severn RBMP. This concluded the following with respect to impacts on European sites: “It is determined that, at this strategic plan level, the range of potential mitigation options available allow a conclusion that the RBMP is not likely to have any significant effects on any European sites, alone or in combination with other plans or projects. Given this conclusion, there is no requirement, at this strategic plan level, to progress to the next stage of the Habitats Regulations Assessment (an ‘appropriate assessment’ to examine the question of adverse effects on the integrity of European sites)” 57. It notes that HRA requirements will continue to apply to lower tier plan and project level assessments.

4.3.13 It is a statutory requirement that every five years water companies produce and publish a Water Resources Management Plan (WRMP). The WRMP demonstrates long term plans to accommodate the impacts of population growth, drought, environmental obligations and climate change uncertainty in order to balance supply and demand.

4.3.14 South Worcestershire lies within the Severn Trent Water (STW) area. STW provide wastewater services to the whole of South Worcestershire and its WRMP in August 201958. This plan forecasts a significant deficit between supply and demand for water. The key difference from previous plans is the need to prevent the risk of future environmental deterioration, which is a fundamental requirement of the WFD. This means that, in order to protect the environment, a number of current sources of water cannot be relied upon in the future and an alternative ways of meeting demand has been identified.

57 Environment Agency (2015) River basin management plan for the Severn River Basin District Habitats Regulations Assessment Updated December 2015. 58 Severn Trent (2019) Water Resources Management Plan 2019. Available at: https://www.severntrent.com/content/dam/stw-plc/our-plans/severn-trent-water-resource-management-plan.pdf [Date Accessed: 30/10/19]

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4.3.15 The plan seeks to use demand management measures to reduce the amount of water needed to put into supply by:

• Reducing leakage; • Improving water efficiency; and • Reducing consumption.

4.3.16 An HRA was published alongside this plan59. It concluded the following:

4.3.17 “Severn Trent’s’ Final WRMP19 will have no adverse effects on the site integrity of any European sites, either alone or in-combination with any other plans, programmes or projects. As the solutions in the Final WRMP19 are brought forward for development in the future, project- specific HRA will be carried out in support of the necessary applications for planning permission and/or environmental permits. The project- specific HRA will need to consider the prevailing conditions and European site conservation objectives and Site Improvement Plans in place at the time, as well as the final detailed design of the solution”.

4.3.18 The Water Act (2003) made it a statutory requirement for water companies to produce and maintain a Drought Plan. Severn Trent Water update these plans every five years. The Drought Plan sets out how resources and supply will be managed in dry years. In February 2018 Severn Trent Water published draft Drought Plan for consultation to cover the period from 2019 – 202460.

59 Ricardo (2019) Final Water Resources Management Plan 2019 Habitats Regulations Assessment. Available at: https://www.severntrent.com/content/dam/stw-plc/water-resource-zones/2019/WRMP19-HRA-Final-Report.pdf [Date Accessed: 30/10/19] 60 Severn Trent Water (2018) Draft Drought Plan 2019 – 2024. Available at: https://www.severntrent.com/content/dam/stw-plc/water-resource-zones/Draft-drought-plan-PUBLIC.pdf [Date Accessed: 05/11/19]

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Water Cycle Study findings

4.3.19 As part of the evidence base that supported the Core Strategy a Water Cycle Study (WCS) was prepared61. This was updated in 2019 to inform the SWDPR process, with a preliminary Phase 1 Scoping Study undertaken62. The next stage in the process will comprise completion of a Phase 2 Study which will be undertaken when there is greater certainty as to which sites will be brought forward for development. The Scoping Study therefore highlights areas for further investigation.

4.3.20 The purpose of the WCS was to “assesses the potential issues relating to future development within South Worcestershire and the impacts on water supply, wastewater collection and wastewater treatment. The Water Cycle Study is required to assess the constraints and requirements on the water infrastructure that will arise from potential growth”.

4.3.21 The WCS was undertaken through consultation with STW, the Environment Agency and neighbouring Local Planning Authorities (LPAs). This Phase 1 – Scoping Study WCS assessed the issues associated with five options for spatial growth in South Worcestershire. The study aimed to provide evidence to guide development towards the most sustainable option or combination of options.

4.3.22 The Phase 1 Scoping WCS confirmed that STW does not expect water supply to be a constraint to development within South Worcestershire.

4.3.23 As noted above, STW provide wastewater services to the whole of South Worcestershire. The WCS notes that early consultation with STW should be undertaken to ensure that sewerage capacity can be provided for future development. This will be investigated further as part of the Phase 2 WCS.

61 JBA Consulting (2010) South Worcestershire Joint Core Strategy Water Cycle Study. Available at: http://www.worcestershire.gov.uk/download/downloads/id/5196/south_worcestershire_water_cycle_studies.pdf [Date Accessed: 30/10/19] 62 JBA Consulting (2019) South Worcestershire Councils Water Cycle Study – Phase 1 Scoping Study.

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4.3.24 In terms of wastewater treatment capacity, once the preferred sites have been identified, STW have confirmed that, where capacity is not available, they will undertake improvements to provide capacity at wastewater treatment works (WwTW). This will be further investigated as part of the Phase 2 WCS.

4.3.25 The WCS concluded that the increased wastewater discharges at the WwTW serving growth in South Worcestershire have the potential to impact downstream water quality in the receiving watercourses. This will be further investigated as part of the Phase 2 WCS.

4.3.26 The WCS provides an assessment on the impact of development proposed in the Local Plan on the aquatic environment and thus the quality and quantity of water at European sites. It concludes that there is no hydrological pathway from WwTW or the five growth scenarios to any European site. It however recommends the incorporation of Sustainable Urban Drainage Systems (SuDS) in new development to deal with water quality management. When there is greater certainty over which sites will be brought forward for development, the WCS recommends that water quality modelling be undertaken as part of the Phase 2 work. This study will be reviewed in detail as part of the Regulation 19 HRA work.

4.4 Habitat fragmentation and loss

4.4.1 The Local Plan will not result in the direct loss of land within an area designated as a European site. However, there is potential for the Local Plan to result in the loss of habitat outside a European site. Supporting habitat, also referred to as functionally linked habitat63, may be located some distance from a European site. The fragmentation of habitats through the loss of connecting corridors would have the potential to hinder the movement of qualifying species.

63 “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. 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.

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

4.4.3 Areas of potentially functionally linked habitat likely to be lost to development were 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 sites. Where suitable habitat was identified, its potential to provide an important role in maintaining or restoring the qualifying features at a favourable conservation status was taken into consideration.

4.5 Public access and disturbance

4.5.1 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.

4.5.2 Elsewhere in the UK, public access and disturbance threats have been considered in terms of buffer distances. These have been determined through analysis of visitor and recreational survey data and baseline information.

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4.5.3 An example of this is the Thames Basin Heaths Special Protection Area Delivery Framework64. This makes recommendations for accommodating development while also protecting the SPA's qualifying features. 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 Framework 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. 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.

4.5.4 In circumstances where buffer zones have not been established, best practice examples, such as the Thames Basin Heaths SPA Delivery Framework, can be drawn upon to inform screening assessments. It is however recognised that European sites are designated for different site- specific qualifying features which may not reflect those for which the Thames Basin Heaths SPA has been designated.

4.5.5 The broad principle of buffer zones is one component of the HRA screening process for public access and disturbance. This process also takes into consideration other factors such as recreational management at sites, proximity to settlements and existing recreational resources.

64 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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4.6 In-combination screening

4.6.1 As set out in Section 3.6, and in compliance with Regulation 105 of the Habitats Regulations, a high-level in-combination assessment has been undertaken as part of the screening exercise (Appendix B). The potential for the effects of these plans to combine with the effects of the Local Plan will be considered in more detail at Regulation 19. 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.

4.6.2 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 Local Plan have been identified. In particular the in-combination air quality effect of the Local Plan within other plans and projects will be considered at Stage 2 of the HRA process through a detailed review of traffic data. The Phase 2 WCS, the result of which will feed into the HRA process, will also consider the impact of development within neighbouring authority areas on the aquatic environment and in terms of public access and disturbance.

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5.1 Bredon Hill SAC

5.1.1 Bredon Hill SAC is an outlier of the Cotswold Hills with habitats that are dominated by mixed broad-leaved woodland and calcareous rich grasslands. This historic management has resulted in a number of veteran and ancient trees on the site that give rise to deadwood habitat that is key to the survival of many saproxylic invertebrates, notably the violet click beetle (Limoniscus violaceus)65. The SSSI condition data (Appendix D) indicates that this site is in a favourable condition, with the exception of two grassland units. Bredon Hill SAC is one of only three sites in the UK, alongside Windsor Forest and Great Park SAC and Dixton Wood SAC, known to support the violet click beetle. Potential habitat linkages between these sites, in particular between Bredon Hill and Dixton Wood which are approximately 7.5km apart, need to be identified in order to help maintain and restore this species.

5.1.2 The SIP identified that Bredon Hill SAC is vulnerable to air pollution and in particular atmospheric nitrogen deposition (see Table 4.1). Natural England’s supplementary advice66 indicates that this site may also be vulnerable to hydrological changes, noting that “the moist soils of the SAC help to sustain a humid microclimate which probably enhances the wood-decay process to benefit the beetle. These damp woodland floor conditions rely on subsurface water passing through the SAC”.

65 Natural England. 2019. European Site Conservation Objectives: Supplementary advice on conserving and restoring site features Bredon Hill Special Area of Conservation (SAC). Available at: http://publications.naturalengland.org.uk/file/4991509330132992 [Date Accessed: 30/10/19] 66 Natural England (2019) Bredon Hill SAC Conservation Objectives supplementary advice. Available at: http://publications.naturalengland.org.uk/file/4991509330132992 [Date Accessed: 30/10/19]

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Air Quality

5.1.3 The supporting habitat of the violet click beetle, broadleaved mixed and yew woodland, is known to be sensitive to changes in air quality. Nitrogen is currently exceeding the 10-20 kg/ha/yr critical load for this habitat type at an average of 27.9 kg/ha/yr67. There are no strategic roads (A and B grade roads) within 200m of Bredon Hill SAC. However, a small proportion of the SAC is located within 200m of a minor road network, Lampitt Lane, Woollas Hill and Hill Lane. As such potential LSEs associated with reductions in air quality as a result of the Local Plan, both alone and in-combination, will be investigated further following receipt of traffic modelling data. This site has therefore been screened in for further assessment in the HRA process in terms of air quality.

Hydrology

5.1.4 As noted above, Natural England’s supplementary advice indicates that Bredon Hill SAC requires an appropriate hydrological regime to be maintained on site in order to sustain the deadwood habitat, including moist decaying timber, upon which the violet click beetle relies.

5.1.5 Taking into account the location and topography of the site, there are no surface water receptors that connect development proposed in the Local Plan with the SAC. The closest proposed site allocation is located approximately 1327m to the south of the SAC (Site SWDP61/10).

5.1.6 Furthermore, as discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. It is therefore considered unlikely that the Plan would result in significant hydrological issues at Bredon Hill SAC either alone or in-combination with other plans and projects. Bredon Hill SAC has therefore been screened out of further assessment in the HRA process in terms of hydrology.

67 Air Pollution Information System (APIS). Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0012587&SiteType=SAC&submit=Next [Date Accessed: 15/07/19]

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Public Access and Disturbance

5.1.7 Public access and disturbance are not identified as a threat / pressure at Bredon Hill SAC within the SIP or Natural England’s supplementary advice. However, given the location of this SAC within the Plan area, it is considered that public access may have implications for the violet click beetle. The veteran trees at Bredon Hill SAC provide ideal conditions which support the violet click beetle. Public access has the potential to disturb / damage these veteran trees and therefore compromise the habitat upon which the violet click beetle relies. There are a number of site allocations located within 5km of the SAC which are allocated for housing. The closest are located approximately 1.3km to the south of the SAC in Kemerton and Overbury. As such LSEs associated with public access and disturbance are considered possible. Bredon Hill SAC has therefore been screened in for further assessment in the HRA process in terms of public access and disturbance.

5.2 Lyppard Grange Ponds SAC

5.2.1 Lyppard Grange Ponds SAC includes two field ponds located in the grounds of the former Lyppard Grange Farm, situated to the east of Worcester city. These two ponds, along with the surrounding terrestrial habitats, support a large breeding colony of great crested newts (Triturus cristatus), and are a remnant of a formerly more widespread newt habitat where large numbers of ponds were maintained for agricultural purposes68. The SSSI condition data (Appendix D) indicates that one SSSI unit is in favourable condition with the second classed as unfavourable recovering due to issues with water quality and quantity.

5.2.2 Natural England’s supplementary advice69 identified potential sensitivity of the SAC to air quality in terms of the deposition of airborne pollutants, as well as to changes in water quantity and quality.

68 Natural England (2019) European Site Conservation Objectives: Supplementary advice on conserving and restoring site features Lyppard Grange Ponds Special Area of Conservation (SAC). Available at: http://publications.naturalengland.org.uk/file/6272367249063936 [Date Accessed : 05/11/19] 69 Natural England (2016) Lyppard Grange Ponds SAC Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/6272367249063936 [Date Accessed: 30/10/19]

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Air Quality

5.2.3 The supporting habitat of the great crested newt is known to be sensitive to changes in air quality. No Critical Load has been assigned to the European Nature Information System (EUNIS) classes for meso/eutrophic systems as these systems are often Phosphorus limited (or Nitrogen/Phosphorus co-limiting)70. There are no strategic roads (A and B grade roads) within 200m of the Lyppard Grange Ponds SAC. However, there are several minor roads surrounding the SAC including access road to the adjacent Tesco supermarket. Potential LSEs associated with reductions in air quality as a result of the Plan, both alone and in-combination with other plans and projects, should be investigated further following receipt of traffic modelling data. This site has therefore been screened in for further assessment in the HRA process in terms of air quality.

Hydrology

5.2.4 Great crested newts require the maintenance of suitable water levels and quality in order to support a healthy breeding population. Adequate quantity and quality of water is also required in order to support the presence of an abundant and diverse community of freshwater invertebrates to provide food for newt larvae and adults.

5.2.5 In terms of water quantity, as discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. However, due to the location of Lyppard Grange Ponds SAC amongst the built-up area of Worcester and its close proximity to the draft site allocations (the closest being Site which is located approximately 536m to the south west of the SAC (Site SWDP 43/1)), there is potential for LSEs as a result of a reduction in water quality at the ponds as a result of the Local Plan alone. This site has therefore been screened in for further assessment in the HRA process in terms of hydrology.

70 Air Pollution Information System (APIS). Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0030198&SiteType=SAC&submit=Next [Date Accessed: 15/07/19]

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Public Access and Disturbance

5.2.6 Public access and disturbance are not identified as a threat / pressure at Lyppard Grange Ponds SAC within the SIP or Natural England’s supplementary advice. However, given the location of this SAC within the Plan area, it is considered that public disturbance LSEs may include physical disturbance and littering of this habitat with adverse effects for great crested newts. There are a number of site allocations located within 5km of the SAC which are allocated for housing. The closest being located approximately 536m to the south west of the SAC (Site SWDP 43/1)). As such LSEs associated with public access and disturbance are considered possible. Lyppard Grange Ponds SAC has therefore been screened in for further assessment in the HRA process in terms of public access and disturbance.

5.3 Dixton Wood SAC

5.3.1 Dixton Wood SAC comprises a steep east facing woodland surrounded by permanent grassland, situated in the foothills of the Cotswold Scarp. The wood represents an atypical ash (Fraxinus excelsior), field maple (Acer campestre), dog’s mercury (Mercuralis perennis) community, with an unusual structure derived from wood pasture management. The historic management of the site has resulted in a number of very large, low ash pollards with a range of deadwood types, from split ash boles, shattered tree limbs, old and active pollards and cut stumps. The moist clay soils, the aspect and ground and scrub cover sustain a humid microclimate which probably enhances the decay process.

5.3.2 The beetle fauna associated with the decaying wood habitats of Dixton Wood is very rich and includes the violet click beetle. Hawthorn (Crataegus monogyna) hedges and flowering bramble (Rubus fruticosus agg.) both provide important nectar sources for the deadwood fauna71.

71 Natural England (2019) Dixton Wood SAC Conservation Objectives supplementary advice. Available at: http://publications.naturalengland.org.uk/file/5630793703751680 [Date Accessed: 30/10/19]

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5.3.3 The SSSI condition data (Appendix D) indicates that this site is in an unfavourable condition as the ground flora is generally poor, there is poor regeneration in the canopy gaps, and there is vigorous vegetation growth (mainly nettles and brambles) which may compete with the young tree growth. The condition data notes that whilst the poor ground flora does not affect the special interest (and was poor at the time of notification), the lack of replacement trees (particularly in the canopy gaps) is of more concern.

5.3.4 Natural England’s supplementary advice72 identified potential sensitivity of the SAC to air quality in terms of the deposition of airborne pollutants, as well as to hydrological changes.

Air Quality

5.3.5 The supporting habitat of the violet click beetle, broadleaved mixed and yew woodland, is known to be sensitive to changes in air quality. Nitrogen is currently exceeding the 10-20 kg/ha/yr critical load for this habitat type at an average of 30.2kg/ha/yr73. There are no roads within 200m of Dixton Wood SAC. As such, LSEs associated with reductions in air quality as a result of the Local Plan alone or in-combination are not likely to be significant. Dixton Wood SAC has therefore been screened out of further assessment in the HRA process in terms of air quality.

Hydrology

5.3.6 As mentioned above, Natural England’s supplementary advice indicates that Dixton Wood SAC requires an appropriate hydrological regime to be maintained on site in order to sustain the deadwood habitat, including moist decaying timber, upon which the violet click beetle relies.

5.3.7 However, taking into account the location of the site, there are no surface water receptors that connect development proposed in the Local Plan with the SAC. In addition, Natural England’s supplementary advice notes that there are no abstraction licences identified as impacting this site. The closest proposed draft site allocation is located approximately 5500m to the north of the SAC (Site SWDP61/3).

72 Ibid 73 Air Pollution Information System (APIS). Sourced 15.07.19. Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0030135&SiteType=SAC&submit=Next

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5.3.8 Furthermore, as discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. It is therefore considered unlikely that the Plan would result in LSEs in terms of hydrological issues alone or in-combination at Dixton Wood SAC. Dixton Wood SAC has therefore been screened out of further assessment in the HRA process in terms of hydrology.

5.4 Downton Gorge SAC

5.4.1 Downton Gorge SAC lies alongside the River Teme, within the county of Herefordshire, and is located approximately 11.6km north west of the South Worcestershire boundary. The SAC also coincides with the Downton Gorge National Nature Reserve, which is managed by Natural England74.

5.4.2 The gorge was formed by the river cutting through a ridge of limestones, siltstones and sandstones of the late Silurian age. The southern section of the site comprises a deep ravine with steep cliffs, whereas in the northern section the river valley is joined by a series of small side valleys known as ‘dingles’ whose streams drain into the main river.

5.4.3 Downton Gorge SAC supports the qualifying feature Tilio-Acerion forest, present in a narrow ravine with a distinctive microclimate and a variety of slopes and aspects. Small-leaved lime (Tilia cordata) and large-leaved lime (T. platyphyllos) are plentiful within the SAC, as well as occurrences of ash and elm (Ulmus spp) surrounded by the rich woodland ground flora. The gorge cliffs are rich in ferns, reflecting the humidity of the site, with a wide range of species recorded including the uncommon oak fern (Gymnocarpium Dryopteris) and brittle bladder-fern (Cystopteris fragilis). Furthermore, the woodland supports a vast array of lichen species including tree lungwort (Lobaria pulmonaria), which is only found at one other site in central England.

74 Natural England (2017) Downton Gorge SAC Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/4961228332466176 [Date Accessed: 05/11/19]

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5.4.4 The SSSI condition data (Appendix D) indicates that this site is in an unfavourable condition. The condition data notes that one unit is recovering, largely due to the implementation of deer fences to allow natural flora regeneration. In contrast, the other three SSSI units are declining due to overgrazing by deer, as well as woodland and game management issues.

5.4.5 The SIP indicates that Downton Gorge SAC is vulnerable to air pollution and habitat fragmentation (see Table 4.1). According to Natural England’s supplementary advice75, Downton Gorge SAC is also sensitive to changes in water levels and quality and public disturbance from illumination from artificial light sources.

Air Quality

5.4.6 The broad habitat associated with the Tilio-Acerion forests, broadleaved mixed and yew woodland, is known to be sensitive to changes in air quality. Nitrogen is currently exceeding the 15-20 kg/ha/yr critical load for this habitat type at an average of 29.9kg/ha/yr76. There are no strategic roads (A and B grade roads) within 200m of Downton Gorge SAC. A network of narrow country lanes surrounds the site, with only a small proportion of the SAC located within 200m of these minor roads.

5.4.7 Potential LSEs associated with reductions in air quality as a result of the Plan, both alone and in-combination with other plans and projects, should be investigated further following receipt of traffic modelling data. Therefore, this site has been screened in for further assessment in the HRA process in terms of air quality.

75 Natural England (2017) Downton Gorge SAC Conservation Objectives supplementary advice. Available at: http://publications.naturalengland.org.uk/file/4961228332466176 [Date Accessed: 24/10/19] 76 Air Pollution Information System (APIS). Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0012735&SiteType=SAC&submit=Next [Date Accessed: 30/10/19]

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Habitat Loss and Fragmentation

5.4.8 The Tilio-Acerion forests and associated woodland and cliff habitats within Downton Gorge are identified as being vulnerable to habitat loss and fragmentation. The SIP notes that the isolation of the site increases its vulnerability to the extinction of species through disease or climate change.

5.4.9 Downton Gorge SAC is located over 11km from the South Worcestershire boundary. No development associated with the Local Plan would be anticipated to coincide with the SAC or functionally linked habitat and as such there would be no LSEs in terms of habitat loss or fragmentation. Therefore, this site has been screened out of further assessment in the HRA process in terms of habitat loss and fragmentation.

Hydrology

5.4.10 As noted above, the supplementary advice from Natural England indicates that Downton Gorge SAC requires an appropriate hydrological regime to be maintained on site in order to sustain humid environment which supports the Tilio-Acerion forests.

5.4.11 The site is located approximately 11.6km north west of the Plan area, upstream, and therefore, it is considered unlikely that adverse impacts in terms of changes in water quality would arise as a result of the Local Plan. Furthermore, as discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. It is therefore considered unlikely that the Plan would result in LSEs in terms of hydrological issues at Downton Gorge SAC either alone or in-combination. Downton Gorge SAC has therefore been screened out of further assessment in the HRA process in terms of hydrology.

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Public access and disturbance

5.4.12 The Tilio-Acerion forests within Downton Gorge SAC are identified as being vulnerable to public disturbance from illumination impacts associated with artificial lighting. Downton Gorge SAC is located over 11km from the South Worcestershire boundary. No development associated with the Local Plan would be located within close proximity of the SAC. Development related illumination impacts are therefore considered unlikely. This site has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

5.5 River Clun SAC

5.5.1 The River Clun SAC comprises the lower reaches of the River Clun, which extends upstream from its confluence with the River Teme to Broadward Bridge near Marlow. The River Clun is a tributary of the River Teme, which in turn flows into the River Severn. The section of the river encompassed by the SAC holds an important population of the freshwater pearl mussel (Margaritifera margaritifera), which is one of the few remaining populations in the lowlands of the UK.

5.5.2 The freshwater pearl mussel, which, along with its habitat, is protected by law under the Wildlife and Countryside Act 1981, favours cool and well- oxygenated soft water that is fast-flowing and free of pollution or turbidity. This species is known for being extremely long-lived, with individuals known to survive beyond 100 years. The UK is now the remaining European stronghold for this species, which has faced population declines as a result of human disturbance from pearl-fishing, pollution, acidification, nutrient enrichment, siltation, river engineering, and declining salmonid stocks77.

5.5.3 The SSSI condition data (Appendix D) indicates that this site is in an unfavourable condition, due to a number of issues with the river including inappropriate water levels as a result of weirs and dams, invasive freshwater species, siltation and water pollution.

77 Natural England (2018) River Clun SAC Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/6079231448842240 [Date Accessed: 30/10/19]

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5.5.4 The SIP indicates that the River Clun SAC is vulnerable to hydrological changes (see Table 4.1). According to Natural England’s supplementary advice78, the River Clun SAC is also sensitive to disturbance from human activity (including engineering, recreation and fishing).

Hydrology

5.5.5 A regular flow regime, including water levels, dissolved oxygen and temperature, are important for the survival and success of the freshwater pearl mussel. In addition, freshwater pearl mussels are sensitive to changes in water quality including from organic pollution79.

5.5.6 The site is located upstream of the Local Plan area, and therefore, it is considered unlikely that adverse impacts in terms of changes in water quality would arise as a result of development specified in the Local Plan.

5.5.7 Furthermore, as discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. It is therefore considered unlikely that the Local Plan would result in significant hydrological issues at the River Clun SAC either alone or in-combination. The River Clun SAC has therefore been screened out of further assessment in the HRA process in terms of hydrology.

Public Access and Disturbance

5.5.8 The freshwater pearl mussel is known to be vulnerable to disturbance from human activities including pearl extraction, engineering, water- based recreation and fishing. This site is however located approximately 16km from the South Worcestershire boundary. It can therefore be reasonably concluded that impacts associated with public access and disturbance as a result of the Local Plan alone or in-combination are not likely to be significant. The River Clun SAC has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

78 Ibid 79 Ibid

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5.6 River Wye SAC

5.6.1 The River Wye SAC encompasses sections of the River Lugg and Lower River Wye. The River Wye itself is one of the longest near natural rivers in the UK, with its source in the mountains of Wales (Powys), flowing through Hay-on-Wye, Hereford and Ross-on-Wye and eventually meeting the Severn Estuary at Chepstow.

5.6.2 The geology and morphology of the River Wye is varied in nature, ranging from boulders to silt, with some areas of bedrock outcrops, carboniferous limestone outcrops and in others more gentle sandstone and mudstone slopes80. Key habitat features of the SAC include the watercourse itself, transition mires and quaking bogs.

5.6.3 This variety of habitat types helps the River Wye to support a diverse range of species including a rich submerged aquatic and riparian flora, diverse invertebrate communities and a wide range of internationally important migratory and non-migratory fish species. The River Wye SAC also supports a varied bird assemblage and provides the low wet lying grassland habitat essential for wading birds.

5.6.4 The SSSI condition data (Appendix D) indicates that this site is generally in an unfavourable condition, with one unit favourable and six units unfavourable recovering. According to a technical report81 produced for the restoration of the river, this is due to a number of reasons including siltation and eutrophication from agriculture, over abstraction, invasive flora and physical modification.

5.6.5 The SIP indicates that the River Wye SAC is vulnerable to air pollution (atmospheric nitrogen deposition), hydrological changes and public access and disturbance (see Table 4.1).

80 Natural England (2019) Rivery Wye SAC Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/4538349180420096 [Date Accessed: 05/11/19] 81 Jacobs (2015) River Wye SSSI Restoration Technical Report. Available at: https://www.therrc.co.uk/sites/default/files/files/Designated_Rivers/wyedrafttechnicalreport.pdf [Date Accessed: 31/10/19]

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Air Quality

5.6.6 All of the qualifying features of the River Wye SAC (see Appendix C for full list) are known to be sensitive to changes in air quality, with the ‘transition mires and quaking bogs’ habitat being the most sensitive to nitrogen deposition. Nitrogen is currently exceeding the 10-15 kg/ha/yr critical load for these habitat types at an average of 16.3kg/ha/yr82. No critical loads are available for the other qualifying features.

5.6.7 There are several strategic roads (A and B grade roads) within 200m of the River Wye SAC, including major roads linking South Worcestershire to Hereford (such as the A417, A465, A4103 and A38) that pass over the river. Analysis of commuting traffic patterns indicates that there are daily traffic flows between Herefordshire and both Malvern Hills and Worcester, with flows exceeding 1,000 AADT (see Table 4.2). Therefore, this site has been screened in for further assessment in the HRA process in terms of air quality.

Hydrology

5.6.8 The River Wye SAC is sensitive to changes in water levels and quality. There is potential for hydrological links between South Worcestershire and the River Wye, particularly towards the north west of Malvern Hills district, which is located upstream, with tributaries such as the Humber Brook feeding into the upper reaches of the SAC.

5.6.9 As discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues.

5.6.10 Given that potential hydrological pathways existing from the Plan area to this SAC, LSEs in terms of hydrology are considered possible. Following confirmation of preferred site locations, further investigation into the potential for adverse hydrology effects of the Local Plan alone and in- combination on site integrity will therefore be undertaken. This site has therefore been screened in for further assessment in the HRA process in terms of hydrology.

82 Air Pollution Information System (APIS). Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0012642&SiteType=SAC&submit=Next [Date Accessed: 31/10/19]

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Public Access and Disturbance

5.6.11 A number of the qualifying features for the River Wye SAC are known to be vulnerable to disturbance from human activities, including the white- clawed crayfish, lamprey species and otter. The SIP83 notes that anglers and canoeists in particular pose threats to the qualifying species and habitats of the SAC, as well as the supporting flora and fauna. Further examples of threats associated with human access include the impacts of dogs disturbing otters (Lutra lutra) and the cutting of water crowfoot (Ranunculus spp.) beds for navigation.

5.6.12 At its closest point, this SAC is located approximately 8.7km from the Plan area boundary. Given the distance of the River Wye SAC from the Plan boundary, it can reasonably be concluded that impacts associated with public access and disturbance as a result of the Plan alone and in- combination are not likely to be significant. The River Wye SAC has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

5.7 Severn Estuary SAC/SPA/Ramsar/EMS

5.7.1 The Severn Estuary is located in the south west of England, and at this point the River Severn, Wyke, Usk and Avon meet. The estuary is large in size, and due to its high turbidity and strong tidal streams it has created a diverse range of habitat types including sandbanks, mudflats and sandflats, salt meadows and reefs.

5.7.2 The intertidal zone supports an array of estuarine flora and fauna including nationally and internationally important invertebrates, waterfowl and migratory fish. It is classified as a wetland of international importance as it regularly supports overwintering waterfowl in excess of 20,000 individuals84.

83 Natural England (2014) Site Improvement Plan: River Wye. Available at: http://publications.naturalengland.org.uk/file/5550181483282432 [Date Accessed: 05/11/19] 84 Natural England (2015) Site Improvement Plan: Severn Estuary Mor Hafren. Available at: http://publications.naturalengland.org.uk/file/4856107648417792 [Date Accessed: 05/11/19]

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5.7.3 The SSSI condition data (Appendix D) indicates that this site is generally in a favourable condition, with 66 units favourable, however, 16 of the units are classed as unfavourable. This is due to a number of reasons including overgrazing, coastal squeeze and man-made defences resulting in losses of habitat and inappropriate sward heights to support some of the important fauna. In the upper reaches of the Severn Estuary, issues are identified due to managed realignment schemes.

5.7.4 The SIP for this site (Table 4.1) notes that the Severn Estuary is vulnerable to changes in air pollution, hydrology and public access and disturbance. The Severn Estuary is also designated as a European Marine Site (EMS). The conservation advice package for this EMS85 also identifies sensitivity of the site to hydrology in terms of changes in water flow rate, physical disturbance (including from sea-based recreation) and pollution particularly from riverine inputs.

Air Quality

5.7.5 The qualifying habitats and species of the Severn Estuary SAC/SPA/Ramsar/EMS (see Appendix C for full list) are known to be sensitive to changes in air quality, with the estuary habitat being the most sensitive to nitrogen deposition. Critical loads have been identified for the estuaries and Atlantic salt meadows habitats. Both these habitats have a critical load of 20-30 kg/ha/yr, of which neither are currently exceeded, with average deposition at 9.1 kg/ha/yr86.

5.7.6 There are several strategic roads including the M4 and M48 within 200m of the Severn Estuary, however none of these would be expected to be directly linked to traffic impacts arising from South Worcestershire as it lies, at its closest, approximately 21.8km from the Plan area boundary. The areas in which the Severn Estuary designation lies are not identified as key commuting locations for South Worcestershire (these are presented in Table 4.2). Therefore, potential impacts as a result of air pollution from proposals within the Local Plan alone and in-combination are unlikely to be significant. This site has therefore been screened out of further assessment in the HRA process in terms of air quality.

85 Natural England (2012) Severn Estuary EMS Regulation 33 Conservation Advice Package. Available at: http://publications.naturalengland.org.uk/file/3977366 [Date Accessed: 31/10/19] 86 Air Pollution Information System (APIS). Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0013030&SiteType=SAC&submit=Next [Date Accessed: 31/10/19]

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Hydrology

5.7.7 The Severn Estuary SAC/SPA/Ramsar/EMS is sensitive to changes in water levels and quality. The River Avon and the River Severn flow through Worcestershire, meeting at Tewkesbury before flowing through to join the Severn Estuary. The Local Plan therefore has the potential to impact this European site through introduction of pollutants and changes in water levels through abstraction.

5.7.8 As discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues.

5.7.9 Potential hydrological pathways exist from the Local Plan area to this European site. Following confirmation of preferred site locations, further investigation into the potential for adverse hydrology effects on site integrity from the Local Plan alone and in-combination will be undertaken. This site has therefore been screened in for further assessment in the HRA process in terms of hydrology.

Public Access and Disturbance

5.7.10 A number of the qualifying features for the Severn Estuary SAC/SPA/Ramsar/EMS are known to be vulnerable to disturbance from human activities, including the intertidal mudflats and sandflats, and the species they support.

5.7.11 At its closest point, this site is located approximately 21.8km from the South Worcestershire boundary. Given this distance it can be reasonably concluded that impacts associated with public access and disturbance as a result of the Local Plan both alone and in-combination are not likely to be significant. The Severn Estuary SAC/SPA/Ramsar/EMS has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

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5.8 Walmore Common SPA/Ramsar

5.8.1 Walmore Common SPA/Ramsar lies within the River Severn basin in Gloucestershire. The site itself contains unimproved and improved neutral grassland, marshy grassland and a network of open water ditches. These grassland areas support a diverse range of plants including wavy hair grass (Deschampsia caespitosa), perennial rye grass (Lolium perenne) as well as several rush and sedge species.

5.8.2 Due to the low-lying nature of this grassland site, it is subject to annual flooding in the winter which is now artificially maintained using a weir. This wetland area supports a large assemblage of waterfowl including the qualifying feature Bewick’s swan (Cygnus columbianus bewickii) and other birds moving between the site and the nearby Slimbridge Wildfowl and Wetlands Trust (WWT) reserve in the Severn Estuary87.

5.8.3 The SSSI condition data (Appendix D) indicates that this site is in an unfavourable condition, with all three units unchanged. This is primarily due to water pollution associated with runoff from agricultural land and septic tanks resulting in elevated concentrations of phosphate and nitrate.

5.8.4 The SIP for this site (Table 4.1) notes that Walmore Common is vulnerable to habitat loss, hydrological changes and access and disturbance from humans.

Habitat Loss and Fragmentation

5.8.5 The grassland and marshland habitats associated with Walmore Common SPA and Ramsar are identified as being vulnerable to habitat loss and fragmentation. The site is located over 15km from the South Worcestershire boundary. No development associated with the Local Plan would be anticipated to coincide with the SPA/Ramsar and as such there would be no risk of habitat loss or fragmentation. Walmore Common SPA/Ramsar has therefore been screened out of further assessment in the HRA process in terms of habitat loss and fragmentation.

87 Natural England (2018) Walmore Common SPA Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/6301378498789376 [Date Accessed: 05/11/19]

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Hydrology

5.8.6 Walmore Common SPA/Ramsar is potentially sensitive to changes in water levels and quality, due to the reliance of the Bewick’s swan on the flood waters for winter feeding and roosting. The River Avon and the River Severn flow through Worcestershire, meeting at Tewkesbury before flowing through to join the Severn Estuary. Walmore Common lies approximately 6km upstream of the Severn Estuary SAC/SPA/Ramsar/EMS, but approximately 15.2m downstream of the Local Plan area.

5.8.7 The Local Plan has the potential to impact Walmore Common SPA/Ramsar through introduction of pollutants and changes in water levels through abstraction. As discussed in Section 4.3, the WCS, WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues.

5.8.8 Potential hydrological pathways existing from the Plan area to this European site. Following confirmation of preferred site locations, further investigation into the potential for adverse hydrology effects of the Local Plan alone and in-combination on site integrity will be undertaken. This site has therefore been screened in for further assessment in the HRA process in terms of hydrology.

Public Access and Disturbance

5.8.9 The Bewick’s swan at Walmore Common SPA/Ramsar are known to be vulnerable to disturbance from human activities, including barriers to their successful movement between feeding and roosting areas, such as light, sound, vibration, and presence of people and animals88.

5.8.10 At its closest point, this site is located approximately 15.2km from the South Worcestershire boundary. Given this distance it can be reasonably concluded that impacts associated with public access and disturbance as a result of the Plan alone and in-combination are not likely to be significant. Walmore Common SPA/Ramsar has therefore been screened out of further assessment in the HRA process in terms of public access and disturbance.

88 Natural England (2018) Walmore Common SPA Conservation Objectives Supplementary Advice. Available at: http://publications.naturalengland.org.uk/file/6301378498789376 [Date Accessed: 05/11/19]

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5.9 Fens Pools SAC

5.9.1 Fens Pools SAC covers 20ha and is situated in the suburban borough of Dudley in Staffordshire. The site comprises three canal feeder reservoirs and a series of smaller pools. The site shows evidence of past industrial activities and includes a wide range of habitats from open water, swamp, fen and inundation communities to unimproved neutral and acidic grassland and scrub.

5.9.2 Great crested newts occur as part of a nationally significant amphibian assemblage. The SSSI condition data (Appendix D) indicates that the site is in a favourable condition and current management appears to be appropriate to maintain suitable conditions for the great crested newt population.

5.9.3 The SIP indicates the site is sensitive to habitat loss and fragmentation and hydrological changes (see Table 4.1). Natural England’s supplementary advice89 suggests the site is also vulnerable to changes in air quality.

Air Quality

5.9.4 The supporting habitat of the great crested newt is known to be sensitive to changes in air quality. No Critical Load has been assigned to the European Nature Information System (EUNIS) classes for meso/eutrophic systems as these systems are often Phosphorus limited (or Nitrogen/Phosphorus co-limiting)90.

5.9.5 There are two strategic roads (A and B grade roads) within 200m of the Fens Pools SAC; the A4101 and A461. Although the SAC is located over 15km from the South Worcestershire boundary, analysis of commuting traffic patterns indicates that there are daily traffic flows between Birmingham and both Wychavon and Worcester, with flows exceeding 1,000 AADT (see Table 4.2). Therefore, this site has been screened in for further assessment in the HRA process in terms of air quality.

89 Natural England (2018) Fens Pools SAC Conservation Objectives supplementary advice. Available at: http://publications.naturalengland.org.uk/file/5386159160557568 [Date Accessed: 31/10/19] 90 Air Pollution Information System (APIS). Sourced 15.07.19. Available at: http://www.apis.ac.uk/srcl/select-a- feature?site=UK0030150&SiteType=SAC&submit=Next

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Habitat Loss and Fragmentation

5.9.6 The habitats associated with the Fens Pools SAC are identified as being vulnerable to habitat loss and fragmentation. However, the site is located over 15km from the Local Plan boundary. Great crested newts are known to travel approximately 500m from their breeding pond habitat during the terrestrial phase of their lifecycle91. No development associated with the Local Plan would be anticipated to coincide with the SAC or affect habitat within 500m of the SAC. As such this site has been screened out of further assessment in the HRA process in terms of habitat loss and fragmentation.

Hydrology

5.9.7 Great crested newts require the maintenance of suitable water levels and quality in order to support a healthy breeding population. Adequate quantity and quality of water is also required in order to support the presence of an abundant and diverse community of freshwater invertebrates to provide food for newt larvae and adults.

5.9.8 The site is located upstream of the Local Plan area, and therefore, it is considered unlikely that adverse impacts in terms of changes in water quality would arise as a result of the Local Plan.

5.9.9 As discussed in Section 4.3, the WCS concluded no LSEs on European sites as a result of water quantity issues, and the WRMP and RBMP concluded no LSEs on European sites as a result of water quality or quantity issues. As such, it is unlikely that the Plan alone or in- combination would result in likely significant effects regarding water quantity at Fens Pools SAC. As such this site has been screened out of further assessment in the HRA process in terms of hydrology.

91 Natural England (2015) Great crested newts: protection and licences. Available at: https://www.gov.uk/guidance/great-crested-newts-protection-surveys-and-licences [Date Accessed: 05/11/19]

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5.10 Draft policy screening

5.10.1 Each draft Local Plan policy has been appraised against the HRA screening criteria (see Table 3.1), taking into consideration case law and best practice. Appendix A provides the output of this screening exercise.

5.10.2 It is concluded that LSEs, either from the Local Plan 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 (see Table 3.1 for a description of each category):

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

5.10.3 A number of policies were however considered likely to have an LSE. On the basis of this assessment, the following LSEs will be explored in an appropriate assessment (Stage 2 of the HRA process) in more detail at Regulation 19. Table 5.1 provides a summary of policies that have been screened in.

• Air quality impacts – to be confirmed by air quality modelling work; • Public access and disturbance; and • Hydrological impacts.

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Table 5.1: Summary of screened in policies Screening Policy Number Policy Name Category

SWDPR 1 Employment, Housing and Retail Provision Requirements Category I and L and Delivery

SWDPR 2 The Spatial Development Strategy and Associated Category I and L Settlement Hierarchy

SWDPR 8 Providing the Right Land and Buildings for Jobs Category I and L

SWDPR 19 Meeting the Needs of Travellers and Travelling Category I and L Showpeople

SWDPR 49 Worcestershire Parkway Category I and L

SWDPR 50: Land at Throckmorton Airfield Category I and L

SWDPR 51 Rushwick Expanded Settlement Category I and L

SWDPR 52 Directions for Growth Outside the City Administrative Category I and L Boundaries: Existing Urban Extensions to be Reallocated

SWDPR 53 Worcester City Allocations Category I and L

SWDPR 54 Wychavon Allocations Category I and L

SWDPR 55 Malvern Hills Allocations Category I and L

5.11 Sites screening

5.11.1 Site allocations sit under Policies SWDPR 49 to SWDPR 54. Individual site allocations will be screened individually at the Regulation 19 stage of the SWDPR process. This will take place once final sites have been selected and the evidence base, in terms of the traffic modelling and the Phase 2 WCS, has been reviewed.

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6.1 Summary

6.1.1 The following European sites have been screened in as they were identified as having an LSE and will be explored again at Regulation 19:

• Bredon Hill SAC (air quality and public access and disturbance); • Lyppard Grange Ponds SAC (air quality, hydrology and public access and disturbance); • Downton Gorge SAC (air quality); • River Wye SAC (air quality and hydrology); • Severn Estuary SAC/SPA/Ramsar/EMS (hydrology); • Walmore Common SPA/Ramsar (hydrology); and • Fens Pools SAC (air quality).

6.2 Recommendations

6.2.1 A number of recommendations are set out in Appendix A. These are intended to help ensure that the Local Plan does not affect the integrity of any European site. It is recommended that these be incorporated into the policies as they develop. Once the final site allocations have been selected, site specific wording may be recommended through the HRA process.

6.3 Next steps

6.3.1 The purpose of this report is to ensure that the HRA forms an integral element of the plan-making process and that best practice is followed.

6.3.2 The HRA screening stage will be revisited as part of the Regulation 19 stage in the SWDPR process. Where required, an appropriate assessment will be undertaken (Stage 2 of the HRA process). This is likely to include a more detailed analysis of traffic data in line with Natural England’s guidance on the assessment of traffic emissions in HRA. A ‘Report to Inform the HRA’ will then be prepared at this stage of the plan making process to support the SWCs, as the Competent Authority, make the Integrity Test in terms of the HRA.

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South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix A_Policies_4_141119SC.docx Appendix A: Draft policies - screening

Table A.1: Screening summary of draft policies in the SWDPR

Policy Name Screening for LSE Conclusion Recommendations

Vision and Objectives

These are general statements of policy Vision and Screened and are therefore screened out under Objectives out. Category A.

Strategic Policies

This policy identifies a quantum of development. Dependent on the location and types of development proposed this policy is likely to result in SWDPR1: the following impact pathways at Employment, European sites: Housing and Screened in. Retail Provision - Air quality Requirements - Public access and disturbance and Delivery - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy identifies a quantum of development. Dependent on the location and types of development proposed this policy is likely to result in SWDPR 2: The the following impact pathways at Spatial European sites: Development Strategy and - Air quality Screened in. Associated - Public access and disturbance Settlement - Hydrology Hierarchy LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy aims to promote a modal shift to sustainable modes of transport and is therefore likely to have positive SWDPR 3: implications in terms of local air quality. Screened Strategic This policy does not trigger change or out. Transport Links development within the Plan area. It is therefore screened out under Category F. This is a positive policy as it provides This policy would for the retention and extension of green benefit from infrastructure which has potential to wording which SWDPR 4: divert recreational pressure away from Screened seeks to ensure that Green European sites. This policy does not out. green infrastructure Infrastructure trigger change or development within does not increase the Plan area and would therefore not inappropriate have an impact upon designated sites. accessibility to any

Policy Name Screening for LSE Conclusion Recommendations It is therefore screened out under other European Categories B and F. site.

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 Screened SWDPR 5: European sites. The policy is positive in out. Historic nature, does not trigger any Environment development or change and can therefore be screened out under Category F.

This policy sets out requirements to deliver and to contribute towards infrastructure to meet the needs of the Plan. It does not however on its own Screened SWDPR 6: trigger change or development within out. Infrastructure the Plan area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F. This policy sets out the requirement to consider impacts of development on health and wellbeing. SWDPR 7: Screened Health & It does not trigger change or out. development within the Plan area and Wellbeing would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Non-Strategic Policies

This policy identifies the location of employment sites to meet employment land needs. Dependent on the location and types of development proposed this policy is likely to result in the SWDPR 8: following impact pathways at European Providing the sites: Screened in. Right Land and - Air quality Buildings for - Public access and disturbance Jobs - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out the requirements and provisions for non-allocated employment development but does not specify a quantum or location. On its SWDPR 9: Screened own this policy does not trigger change Employment out. or development within the Plan area Exception Sites and would therefore not have an impact upon designated sites. It is therefore screened out under Category F.

Policy Name Screening for LSE Conclusion Recommendations

This policy sets out the requirements and provisions for retail, leisure and tourism development but does not specify a quantum or location. On its SWDPR 10: City, own this policy does not trigger change Screened Town and Local or development within the Plan area out. Centres and would therefore not have an impact upon designated sites. It is therefore screened out under Category F. This policy safeguards employment land in rural areas and sets out provisions to support employment in SWDPR 11: rural areas. This policy does not trigger Screened Employment in change or development within the Plan out. Rural Areas area and would therefore not have an impact upon designated sites. It is therefore screened out under Category F. This policy sets out the requirements for effective use of land – including housing density, reusing previously developed land and making only SWDPR 12: exceptional use of Best and Most Screened Effective Use of Versatile Agricultural Land. It does not out. Land 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. This policy sets out the requirements housing mix. It does not trigger change SWDPR 13: or development within the Plan area Screened Market Housing and would therefore not have an out. Mix impact upon designated sites. It is therefore screened out under Category F. This policy sets out the requirements for affordable housing. It does not SWDPR 14: trigger change or development within Meeting Screened the Plan area and would therefore not Affordable out. have an impact upon designated sites. Housing Needs It is therefore screened out under Category F. This policy set out the requirements to SWDPR 15: provide dwelling plots for self or Providing custom build. It does not trigger Opportunities change or development within the Plan Screened for Self-Build area and would therefore not have an out. and Custom impact upon designated sites. It is Housebuilding therefore screened out under Category F. This policy set out the requirements for SWDPR 16: access at residential units. It does not Residential Screened trigger change or development within Access out. the Plan area and would therefore not Standards have an impact upon designated sites.

Policy Name Screening for LSE Conclusion Recommendations It is therefore screened out under Category F. This policy set out the requirements for residential space standards. It does not SWDPR 17: trigger change or development within Residential Screened the Plan area and would therefore not Space out. have an impact upon designated sites. Standards It is therefore screened out under Category F. This policy set out the requirements for rural exception sites. It does not SWDPR 18: trigger change or development within Screened Rural Exception the Plan area and would therefore not out. Sites have an impact upon designated sites. It is therefore screened out under Category F. This policy sets out design requirements for gypsies and travellers’ sites and five-year supply targets. Item C notes that larger strategic sites shall each include a traveller site of up to 10 pitches. Where the supply cannot be met at these sites a separate Traveller and Travelling Showpeople SWDPR 19: Development Plan Document (DPD) Meeting the which will be subject to HRA. This Needs of policy on its own would trigger Screened in. Travellers and development and is likely to result in Travelling the following impact pathways at Showpeople European sites: - Air quality - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy set out the requirements for replacement dwellings in the open SWDPR 20: countryside. It does not trigger change Replacement or development within the Plan area Screened Dwellings in the and would therefore not have an out. Open impact upon designated sites. It is Countryside therefore screened out under Category F. This policy set out the requirements for dwellings for rural workers. It does not SWDPR 21: trigger change or development within Screened Dwellings for the Plan area and would therefore not out. Rural Workers have an impact upon designated sites. It is therefore screened out under Category F. This policy set out the requirements SWDPR 22: older residents and residents with Meeting the Screened special needs. It does not trigger Needs of Older out. change or development within the Plan Residents and area and would therefore not have an

Policy Name Screening for LSE Conclusion Recommendations Residents with impact upon designated sites. It is Special Needs therefore screened out under Category F. This policy set out the requirements for reuse of rural buildings. It does not SWDPR 23: Re- trigger change or development within Screened use of Rural the Plan area and would therefore not out. Buildings have an impact upon designated sites. It is therefore screened out under Category F. This policy set out the requirements for extensions to rural curtilage. It does SWDPR 24: not trigger change or development Extensions to Screened within the Plan area and would Residential out. therefore not have an impact upon Curtilage designated sites. It is therefore screened out under Category F. This policy relates to design. It is a positive policy as it includes text relating to high quality design. This SWDPR 25: policy itself does not trigger change or Screened Design development within the Plan area and out. would therefore not have an impact upon designated sites. It is therefore screened out under Category B. This policy could be strengthened by noting the requirement for HRA of future developments to protect the integrity of European sites at the project level This policy relates to the protection of prior to the designated sites and protected species determination of and improving biodiversity. It includes planning text that states, ‘Development which is applications(s). It likely to compromise the integrity of a should also note Special Area of Conservation (SAC) or that where mitigation is SWDPR 26: other international designations or the Screened required to mitigate Biodiversity and favourable conservation status of out. adverse effects on Geodiversity internationally or nationally protected species or habitats will not be the integrity of permitted.’ This policy will have positive European sites that effects for the protection of European these are submitted sites and their qualifying features and and agreed with the has therefore been screened out under Council and Natural Category D. England prior to the determination of planning application(s). Such measures will need to be implemented prior to the completion / occupation of development as appropriate.

Policy Name Screening for LSE Conclusion Recommendations

This policy relates to the protection of SWDPR 27: The the AONB. It will have a positive Cotswolds and contribution to the protection of Malvern Hills landscape features. This policy itself Screened Areas of does not trigger change or out. Outstanding development within the Plan area and Natural Beauty would therefore not have an impact (AONBs) upon designated sites. It is therefore screened out under Category F. This policy relates to the protection of the historic environment. This policy SWDPR 28: itself does not trigger change or Management of Screened development within the Plan area and the Historic out. would therefore not have an impact Environment upon designated sites. It is therefore screened out under Category F. This policy relates to the protection of landscape character. This policy itself SWDPR 29: does not trigger change or Screened Landscape development within the Plan area and out. Character would therefore not have an impact upon designated sites. It is therefore screened out under Category F. This policy relates to the provision of electronic communication. This policy SWDPR 30: itself does not trigger change or Screened Electronic development within the Plan area and out. Communications would therefore not have an impact upon designated sites. It is therefore screened out under Category F. This policy requires development to SWDPR 31: incorporate renewable and low carbon Incorporating energy into development. This policy Renewable and itself does not trigger change or Screened Low Carbon development within the Plan area and out. Energy into New would therefore not have an impact Development upon designated sites. It is therefore screened out under Category F. A number of recommendations are made in the This policy sets out the sequential WCS in terms of approach to be adopted for water quality and developments in terms of flood risk. It water resources – notes the benefits of SuDS for see section 13.3 of improvement in water quality and the WCS. Of SWDPR 32: states that all SuDS schemes must Screened particular Management of protect water quality. This would have out. importance for the Flood Risk secondary positive impacts in terms of HRA are the improving water quality. The policy is environmental positive in nature, does not trigger any recommendations. development or change and can These therefore be screened out under recommendations Category F. should be incorporated into policy wording.

Policy Name Screening for LSE Conclusion Recommendations

A number of recommendations are made in the WCS in terms of This policy sets out the requirements to water quality and incorporate SuDS in all development water resources – proposals. It notes the benefits of see section 13.3 of SWDPR 33: SuDS for improvement in water quality. the WCS. Of Sustainable This would have secondary positive Screened particular Drainage impacts in terms of improving water out. importance for the Systems quality. The policy is positive in nature, HRA are the does not trigger any development or environmental change and can therefore be screened recommendations. out under Category F. These recommendations should be incorporated into policy wording. A number of recommendations are made in the WCS in terms of water resources and This policy sets out the requirements efficiency and water for water resources, efficiency and quality – see section SWDPR 34: treatment. This would have secondary 13.3 of the WCS. Of Water positive impacts on the protection of Screened particular Resources, water resource and water quality. The out. importance for the Efficiency and policy is positive in nature, does not HRA are the Treatment trigger any development or change and environmental can therefore be screened out under recommendations. Category F. These recommendations should be incorporated into policy wording. This policy sets out the requirements for amenity. This would have secondary positive impacts in terms of SWDPR 35: controlling noise, lighting, odour and Screened Amenity effluvia. The policy is positive in nature, out. does not trigger any development or change and can therefore be screened out under Category F. This policy sets out the requirements This policy could be for air quality impacts. This would have strengthened by secondary positive impacts in terms of requiring air quality SWDPR 36: Air improving air quality. The policy is Screened assessments to Quality positive in nature, does not trigger any out. consider habitat as development or change and can well as human therefore be screened out under receptors to air Category F. quality. This policy sets out the requirements This policy could be SWDPR 37: for consideration of contamination and strengthened to Land Stability mitigation where required. This would ensure that habitats Screened and have secondary positive impacts in / protected sites are out. Contaminated terms of preventing contaminated included in the list Land discharge from sites. The policy is of receptors to be positive in nature, does not trigger any protected.

Policy Name Screening for LSE Conclusion Recommendations development or change and can therefore be screened out under Category F. This policy sets out the requirements to safeguard mineral sites. The policy does SWDPR 38: Screened not in itself trigger any development or Minerals out. change and can therefore be screened out under Category F. This policy sets out the requirements for tourist related development. The SWDPR 39: policy does not in itself trigger any Screened Tourist development or change and can out. Development therefore be screened out under Category F. This policy sets out the requirements for visitor accommodation. The policy SWDPR 40: does not in itself trigger any Screened Visitor development or change and can out. Accommodation therefore be screened out under Category F. This policy sets out the requirements for static and routing caravans, chalets SWDPR 41: and camping sites. It sets provisions Static and for foul drainage, water supply and Touring waste disposal which will have positive Screened Caravans, effects for water quality and quantity. out. Chalets and The policy does not in itself trigger any Camping Sites development or change and can therefore be screened out under Category F. This policy sets out the requirements for built community facilities. The policy SWDPR 42: does not in itself trigger any Screened Built Community development or change and can out. Facilities therefore be screened out under Category F. This policy sets out the requirements for the protection of green space. The SWDPR 43: policy does not in itself trigger any Screened Green Space development or change and can out. therefore be screened out under Category F. This policy sets out the requirements for the provision of green space and SWDPR 44: outdoor community uses in new Provision of development. This policy may have Green Space positive effects by providing on site Screened and Outdoor recreational opportunities for new out. Community residents. The policy does not in itself Uses in New trigger any development or change and Development can therefore be screened out under Category F. This policy could be This policy sets out the requirements strengthened to SWDPR 45: for waterfront developments. The Screened ensure that any Waterfronts policy does not in itself trigger any out. waterfront development or change and can development

Policy Name Screening for LSE Conclusion Recommendations therefore be screened out under specifically Category F. considers impacts on downstream European sites through the process of HRA before determination of planning application(s). This policy could be strengthened to ensure that development of marinas and This policy sets out the requirements moorings for marinas and moorings. The policy SWDPR 46: specifically does not in itself trigger any Screened Marinas and considers impacts development or change and can out. Moorings on downstream therefore be screened out under European sites Category F. through the process of HRA before determination of planning application(s). This policy could be strengthened to ensure that residential moorings This policy sets out the requirements specifically consider for residential moorings. The policy SWDPR 47: impacts on does not in itself trigger any Screened Residential downstream development or change and can out. Moorings European sites therefore be screened out under through the process Category F. of HRA before determination of planning application(s). This policy sets out the requirements for equestrian development. The policy SWDPR 48: does not in itself trigger any Screened Equestrian development or change and can out. Development therefore be screened out under Category F.

Site Allocations

This policy sets out a quantum and Specific site location of development at allocations which Worcestershire Parkway. form SWDPR 49 will be screened in This policy has the potential to result in detail at Regulation LSEs on the following impact pathways 19. SWDPR 49: at European sites: Worcestershire - Air quality Screened in. Parkway - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

Policy Name Screening for LSE Conclusion Recommendations

This policy sets out a quantum and Specific site location of development at Land at allocations which Throckmorton Airfield. form SWDPR 50 will be screened in This policy has the potential to result in detail at Regulation LSEs on the following impact pathways 19. SWDPR 50: at European sites: Land at Screened in. Throckmorton - Air quality Airfield - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out a quantum and Specific site location of development at Rushwick allocations which Expanded Settlement. form SWDPR 51 will be screened in This policy has the potential to result in detail at Regulation LSEs on the following impact pathways 19. SWDPR 51: at European sites: Rushwick Screened in. Expanded - Air quality Settlement - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out a quantum and Specific site location of development at Broomhall allocations which Community and Norton Barracks form SWDPR 52 will Community, Temple Laugherne and be screened in SWDPR 52: Worcester Technology Park. detail at Regulation Directions for 19. Growth Outside This policy has the potential to result in the City LSEs on the following impact pathways Administrative at European sites: Screened in. Boundaries: - Air quality Existing Urban - Public access and disturbance Extensions to be - Hydrology Reallocated LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out a quantum and Specific site location of development in Worcester allocations which City. form SWDPR 53 will be screened in This policy has the potential to result in detail at Regulation LSEs on the following impact pathways 19. SWDPR 53: at European sites: Worcester City - Air quality Screened in. Allocations - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L.

Policy Name Screening for LSE Conclusion Recommendations

This policy sets out a quantum and Specific site location of development in Wychavon. allocations which form SWDPR 54 will This policy has the potential to result in be screened in LSEs on the following impact pathways detail at Regulation at European sites: SWDPR 54: 19 Wychavon - Air quality Screened in. Allocations - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out a quantum and Specific site location of development in Malvern allocations which Hills. form SWDPR 55 will be screened in This policy has the potential to result in detail at Regulation LSEs on the following impact pathways 19. SWDPR 55: at European sites: Malvern Hills - Air quality Screened in. Allocations - Public access and disturbance - Hydrology LSEs at European sites are therefore considered possible and this policy is therefore screened in under Category I and L. This policy sets out the requirements for implementation of planning obligations, CIL and monitoring of the SWDPR 56: Screened Local Plan. The policy does not in itself Implementation out. trigger any development or change and can therefore be screened out under Category F. This policy sets out the requirements The outputs of the for monitoring of the Local Plan. The HRA process may SWDPR 57: policy does not in itself trigger any Screened feed into ongoing Monitoring development or change and can out. monitoring Framework therefore be screened out under arrangements. Category F.

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Appendix B: In-Combination Assessment

Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE

th Borough of Redditch Adopted (30 January Approximately 6,400 dwellings between 2011 and 2030 Yes. Local Plan No.41 2017) (3,000 in Redditch Borough, and 3,400 exported to This plan will trigger change or Bromsgrove). development adjacent to the Plan Approximately 55ha of employment land (27.5ha within area. There is potential for in- Redditch Borough, 10 Bromsgrove and 19ha Stratford-on- combination air quality, hydrology Avon). and public access and disturbance LSEs. 2 th Bromsgrove District Plan Adopted (25 January Approximately 7,000 dwellings over the period 2011-2030. Yes. 2017) A minimum of 28ha employment growth. This plan will trigger change or development adjacent to the Plan area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs. rd Cotswold District Local Adopted (3 August At least 8,400 dwellings and 24ha for B class employment Yes. Plan3 2018) use over the period 2011-2031. This plan will trigger change or development adjacent to the Plan area. There is potential for in- combination air quality, hydrology

1 Redditch Borough Council (2017) Borough of Redditch Local Plan No.4. Available at: https://www.redditchbc.gov.uk/media/2751956/Adopted-BORLP4-low-res-17-02-17.pdf [Date Accessed: 29/10/19] 2 Bromsgrove District Council (2017) Bromsgrove District Plan 2011-2030. Available at: https://www.bromsgrove.gov.uk/media/2673698/Adopted-BDP-January-2017.pdf [Date Accessed: 29/10/19] 3 Cotswold District Council (2018) Cotswold District Local Plan 2011-2031. Available at: https://www.cotswold.gov.uk/media/1621895/Cotswold-District-Local-Plan-2011-2031-Adopted- 3-August-2018-Web-Version.pdf [Date Accessed: 29/10/19]

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Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE and public access and disturbance LSEs. Forest of Dean District Issues and Options Estimated 7,420 houses for 2021-2041. Yes. Local Plan4 consultation (October This plan will trigger change or 2019) development adjacent to the Plan area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs. th Herefordshire Local Plan Adopted (16 October Minimum of 6,500 new homes and overall target of 148ha Yes. Core Strategy5 2015) of employment land over the period 2011-2031. This plan will trigger change or development adjacent to the Plan area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs. 6 Shropshire Local Plan Local Plan partial review Housing need for 2016-2036 is 25,178 dwellings. Yes. (Strategic Sites This plan will trigger change or consultation ended Employment need not yet established for the plan period. development adjacent to the Plan September 2019) area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs.

4 Forest of Dean District Council (2019) Forest of Dean District Local Plan 2021-2041 Issues and Options September 2019. Available at: https://www.fdean.gov.uk/media/6966/final- document-with-latest-cover-17sept19.pdf [Date Accessed: 29/10/19] 5 Herefordshire Council (2015) Herefordshire Local Plan Core Strategy 2011-2031. Available at: https://www.herefordshire.gov.uk/download/downloads/id/1788/core_strategy_sections_combined.pdf [Date Accessed: 30/10/19] 6 Shropshire Council (2019) Local Plan partial review 2016-2036. Available at: https://shropshire.gov.uk/planning-policy/local-planning/local-plan-partial-review-2016-2036/ [Date Accessed: 30/10/19]

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Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE

th Stratford-on-Avon District Adopted (11 July 2016) At least 14,600 homes and 35ha employment land over the Yes. Core Strategy7 period 2011-2031. This plan will trigger change or development adjacent to the Plan area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs. Tewkesbury Borough Pre-Submission A minimum of 9,899 new homes between 2011-2031. Yes. Plan8 consultation (October This plan will trigger change or 2019) development adjacent to the Plan area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs. Wyre Forest District Local Local Plan Pre- 5,520 dwellings and 29ha employment land for 2016-2036. Yes. Plan9 submission publication th This plan will trigger change or (consultation ended 14 development adjacent to the Plan October 2019) area. There is potential for in- combination air quality, hydrology and public access and disturbance LSEs.

7 Stratford-on-Avon District Council (2016) Stratford-on-Avon District Core Strategy 2011 to 2031. Available at: https://www.stratford.gov.uk/templates/server/document- relay.cfm?doc=173518&name=SDC%20CORE%20STRATEGY%202011%202031%20July%202016.pdf [Date Accessed: 30/10/19] 8 Tewkesbury Borough Council (2019) Tewkesbury Borough Plan 2011-2031. Available at: https://www.tewkesbury.gov.uk/local-plan [Date Accessed: 29/10/19] 9 Wyre Forest District Council (2019) Wyre Forest District Local Plan 2016-36 Amendments to the Pre-Submission Publication Document. Available at: https://www.wyreforestdc.gov.uk/media/4656986/Amendments-document-2019.pdf [Date Accessed: 30/10/19]

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Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE

th Worcestershire Local Adopted (9 November The LTP sets out the issues and priorities for investment in Yes. Transport Plan10 2017) transport infrastructure, technology and services to support This plan will trigger change or travel by all relevant modes of transport, including walking, development adjacent to the Plan cycling, rail, highways (car, van, freight and motorcycles), area. There is potential for in- bus and community transport. combination air quality impacts. Promotion of alternative modes of transport to the private car may result in positive LSEs in- combination with the Local Plan. Worcestershire Minerals Emerging Minerals Local Long-term vision for mineral development in Yes. Local Plan11 Plan – Publication Worcestershire to 2035 which integrates economic, social This plan may increase vehicle version (consultation and environmental aims and responds to local issues. movements in the study area and ended September 2019) emissions to air. This plan has the potential to trigger LSEs in terms of air quality in-combination with the Local Plan. th Worcestershire Waste Adopted (15 November The Strategy informs and guides waste management Yes. Core Strategy12 2012) development by the private and public sectors and This plan may increase vehicle encourages businesses involved in the recycling and re-use movements in the study area and of resources for the period 2012 to 2027. emissions to air. This plan has the potential to trigger LSEs in terms of air quality in-combination with the Local Plan.

10 Worcestershire County Council (2017) Worcestershire’s Local Transport Plan (LTP) 2018-2030. Available at: http://www.worcestershire.gov.uk/downloads/file/9024/worcestershire_s_local_transport_plan_ltp_2018_-_2030 [Date Accessed: 30/10/19] 11 Worcestershire County Council (2019) Worcestershire Minerals Local Plan Publication Version. Available at: http://www.worcestershire.gov.uk/download/downloads/id/11410/minerals_local_plan_publication_version.pdf [Date Accessed: 30/10/19] 12 Worcestershire County Council (2012) Waste Core Strategy for Worcestershire. Adopted Waste Local Plan 2012-2027. Available at: http://www.worcestershire.gov.uk/download/downloads/id/940/waste_core_strategy_local_plan.pdf [Date Accessed: 30/10/19]

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Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE

th Severn River Basin Published 18 February The plan provides a framework for protecting and This plan aims to protect the 13 Management Plan 2016 enhancing the benefits provided by the water environment, water environment. It has the and aims: potential to have a positive in- • to prevent deterioration of the status of surface combination effect with the Local waters and groundwater; Plan on the water environment. • to achieve objectives and standards for protected areas; • to achieve good status for all water bodies or, for heavily modified water bodies and artificial water bodies, good ecological potential and good surface water chemical status; • to reverse any significant and sustained upward trends in pollutant concentrations in groundwater; • the cessation of discharges, emissions and loses of priority hazardous substances into surface waters; and • progressively reduce the pollution of groundwater and prevent or limit the entry of pollutants. Severn Trent Water Published August 2019 Severn Trent’s fourth published WRMP demonstrates the This plan aims to protect the Resources Management long-term plans in place to accommodate the impacts of water environment. It has the 14 Plan population growth, drought, our environmental obligations potential to have a positive in- and climate change uncertainty in order to balance the combination effect with the Local supply and demand for water in the communities. Plan on the water environment.

13 Environment Agency (2016) Severn River Basin District River Basin Management Plan. Available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/718336/Severn_RBD_Part_1_river_basin_management_plan.pdf [Date Accessed: 30/10/19] 14 Severn Trent (2019) Water Resources Management Plan 2019. Available at: https://www.severntrent.com/content/dam/stw-plc/our-plans/severn-trent-water-resource- management-plan.pdf [Date Accessed: 30/10/19]

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Plans and Policies Plan Status Summary of housing/employment Potential in-combination LSE

Worcestershire Middle Published May 2019 The Worcestershire Middle Severn Catchment Partnership This plan aims to protect the Severn CaBA Catchment aims to: water environment. It has the Management Plan15 • Identify and remedy issues with water quality; potential to have a positive in- • Collate flood impact information and take a combination effect with the Local catchment wide, holistic approach to alleviating Plan on the water environment. problems in specific areas; • Actively seek opportunities for wildlife and general biodiversity and implement changes to benefit habitats and species; • Seek to engage communities in the area to increase awareness and enjoyment of the water environment; and • Improve access for all and encourage participation in maintaining a healthy river catchment.

15 Worcestershire Wildlife Trust & Severn Rivers Trust (2019) Worcestershire Middle Severn CaBA Catchment Management Plan 2019. Available at: https://severnriverstrust.com/wp- content/uploads/2017/03/Worcs-Mid-Severn-Catchment-Plan-2019-.pdf [Date Accessed: 30/10/19]

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Bredon Hill SAC1 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 habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying Features: S1079. Limoniscus violaceus; Violet click beetle.

Dixton Wood SAC2 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 habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying Features: S1079. Limoniscus violaceus; Violet click beetle.

Downton Gorge SAC3 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 and habitats of qualifying species;

1 Natural England (2018) Bredon Hill SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/6278893137035264 [Date Accessed: 24/10/19] 2 Natural England (2018) Dixton Wood SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/6243505357979648 [Date Accessed: 24/10/19] 3 Natural England (2018) Downton Gorge SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/5526526359764992 [Date Accessed: 24/10/19]

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• 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: H9180. Tilio-Acerion forests of slopes, screes and ravines; Mixed woodland on base-rich soils associated with rocky slopes.

Fens Pools SAC4 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 habitats of the qualifying species; • The structure and function of the habitats of the qualifying species; • The supporting processes on which the habitats of the qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying features: S1166. Triturus cristatus; Great crested newt. Lyppard Grange Ponds SAC5 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 habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying features: S1166. Triturus cristatus; Great crested newt.

4 Natural England (2018) Fens Pools SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/6642225895440384 [Date Accessed: 30/10/19] 5 Natural England (2018) Lyppard Grange Ponds SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/4836130474426368 [Date Accessed: 24/10/19]

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River Clun SAC6 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 habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying features: S1029. Margaritifera margaritifera; Freshwater pearl mussel. River Wye SAC7 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 habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site. Qualifying features: • H3260. Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation; Rivers with floating vegetation often dominated by water-crowfoot; • H7140. Transition mires and quaking bogs; Very wet mires often identified by an unstable ‘quaking’ surface; • S1092. Austropotamobius pallipes; White-clawed (or Atlantic stream) crayfish; • S1095. Petromyzon marinus; Sea lamprey; • S1096. Lampetra planeri; Brook lamprey; • S1099. Lampetra fluviatilis; River lamprey; • S1102. Alosa alosa; Allis shad; • S1103. Alosa fallax; Twaite shad; • S1106. Salmo salar; Atlantic salmon; • S1163. Cottus gobio; Bullhead; and • S1355. Lutra lutra; Otter.

6 Natural England (2018) River Clun SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/5106700017467392 [Date Accessed: 30/10/19] 7 Natural England (2018) River Wye SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/5099305425960960 [Date Accessed: 24/10/19]

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Severn Estuary SPA8 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: • A037 Cygnus columbianus bewickii; Bewick’s swan (Non-breeding); • A048 Tadorna tadorna; Common shelduck (Non-breeding); • A051 Anas strepera; Gadwall (Non-breeding); • A149 Calidris alpina alpina; Dunlin (Non-breeding); • A162 Tringa totanus; Common redshank (Non-breeding); and • A394 Anser albifrons albifrons; Greater white-fronted goose (Non-breeding) Waterbird assemblage.

Severn Estuary SAC9 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. Qualifying features: • H1110. Sandbanks which are slightly covered by sea water all the time; Subtidal sandbanks; • H1130. Estuaries; • H1140. Mudflats and sandflats not covered by seawater at low tide; Intertidal mudflats and sandflats; • H1170. Reefs; • H1330. Atlantic salt meadows (Glauco-Puccinellietalia maritimae); Atlantic salt meadows; • S1095. Petromyzon marinus; Sea lamprey; • S1099. Lampetra fluviatilis; River lamprey; and

8 Natural England (2019) Severn Estuary SPA Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/6288530213175296 [Date Accessed: 24/10/19] 9 Natural England (2019) Severn Estuary SAC Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/6377265718099968 [Date Accessed: 24/10/19]

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• S1103. Alosa fallax; Twaite shad.

Severn Estuary Ramsar10 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 JNCC 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

1 Due to immense tidal range (second-largest in world), this affects both the physical environment and biological communities. 3 Due to unusual estuarine communities, reduced diversity and high productivity. 4 This site is important for the run of migratory fish between sea and river via estuary. Species include: • Salmon Salmo salar; • Sea trout S. trutta; • Sea lamprey Petromyzon marinus; • River lamprey Lampetra fluviatilis; • Allis shad Alosa alosa; • Twaite shad A. fallax, and • Eel Anguilla anguilla. It is also of particular importance for migratory birds during spring and autumn. 5 Assemblages of international importance:

Species with peak counts in winter: 70919 waterfowl (5 year peak mean 1998/99-2002/2003)

10 JNCC (2008) Ramsar Information Sheet: UK11081 Severn Estuary. Available at: https://jncc.gov.uk/jncc- assets/RIS/UK11081.pdf [Date Accessed: 24/10/19]

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6 Species/populations occurring at levels of international importance. Qualifying species/populations (as identified at designation):

Species with peak counts in winter: Tundra swan, Cygnus 229 individuals, representing an columbianus bewickii, NW average of 2.8% of the GB Europe population (5 year peak mean 1998/9-2002/3) Greater white-fronted goose, 2076 individuals, representing an Anser albifrons albifrons, NW average of 35.8% of the GB Europe population (5 year peak mean for 1996/7-2000/01) Common shelduck, Tadorna 3223 individuals, representing an tadorna, NW Europe average of 1% of the population (5 year peak mean 1998/9-2002/3) Gadwall, Anas strepera strepera, 241 individuals, representing an NW Europe average of 1.4% of the GB population (5 year peak mean 1998/9-2002/3) Dunlin, Calidris alpina alpina, W 25082 individuals, representing an Siberia/W Europe average of 1.8% of the population (5 year peak mean 1998/9-2002/3) Common redshank, Tringa 2616 individuals, representing an totanus totanus average of 1% of the population (5 year peak mean 1998/9- 2002/3) Species/populations identified subsequent to designation for possible future consideration under criterion 6.

Species regularly supported during the breeding season: Lesser black-backed gull, 4167 apparently occupied nests, Larus fuscus graellsii, W representing an average of 2.8% of the Europe/Mediterranean/W breeding population (Seabird 2000 Africa Census) Species with peak counts in spring/autumn: Ringed plover, Charadrius 740 individuals, representing an average of hiaticula, 1% of the population (5 year peak mean Europe/Northwest Africa 1998/9- 2002/3) Species with peak counts in winter: Eurasian teal, Anas 4456 individuals, representing an average crecca, NW Europe of 1.1% of the population (5 year peak mean 1998/9-2002/3) Northern pintail, Anas 756 individuals, representing an average of acuta, NW Europe 1.2% of the population (5 year peak mean 1998/9- 2002/3)

8 The fish of the whole estuarine and river system is one of the most diverse in Britain, with over 110 species recorded. Salmon Salmo salar, sea trout S. trutta, sea lamprey Petromyzon marinus, river lamprey Lampetra fluviatilis, allis shad Alosa alosa, twaite shad A. fallax, and eel Anguilla anguilla use the Severn Estuary as a key migration route to their spawning grounds in the many tributaries that flow into the estuary. The site is important as a feeding and nursery ground for many fish species particularly allis shad Alosa alosa and twaite shad A. fallax which feed on mysid shrimps in the salt wedge. x

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Walmore Common SPA11 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: • A037 Cygnus columbianus bewickii; Bewick’s swan (Non-breeding).

Walmore Common Ramsar12 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 JNCC 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 Species/populations occurring at levels of international importance. Species with peak counts in winter: Tundra swan, Cygnus 43 individuals, representing an columbianus bewickii, NW average of 0.5% of the GB population Europe (5 year peak mean 1998/9-2002/3)

11 Natural England (2019) Walmore Common SPA Conservation Objectives. Available at: http://publications.naturalengland.org.uk/file/5326993688363008 [Date Accessed: 24/10/19] 12 JNCC (2008) Ramsar Information Sheet: UK11076 Walmore Common. Available at: https://jncc.gov.uk/jncc- assets/RIS/UK11076.pdf [Date Accessed: 24/10/19]

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No. of Conservation Reason for unfavourable status where European Site1 SSSIs Status of SSSIs2 applicable. Bredon Hill SAC

15 Favourable N/A

Condition of calcareous grassland has Bredon Hill SSSI 17 2 Unfavourable - declined. NNR management plan put in recovering place to restore this feature. Dixton Wood SAC Dixton Wood 1 Unfavourable – 1 No reason provided. SSSI recovering Downton Gorge SAC

1 Unfavourable - Deer fencing put in place to allow natural 1 Unfavourable – recovering recovering regeneration and improve ground flora. Downton Gorge 4 Failing due to lack of natural regeneration. SSSI 3 Unfavourable - Deer grazing, forestry and woodland declining management, game management (pheasant rearing). Fens Pools SAC

Fens Pools SSSI 6 6 Favourable N/A

Lyppard Grange Ponds SAC

1 Favourable N/A Lyppard Grange 2 Ponds SSSI 1 Unfavourable - Issues with water quality and quantity, recovering presence of ducks. River Clun SAC 5 Unfavourable – Inappropriate water levels, due to weirs, no change dams and other structures. Invasive freshwater species, issues with River Teme SSSI 6 siltation and water pollution, including 1 Unfavourable - from agricultural runoff. declining Requires implementation of river restoration plan. River Wye SAC

1 Favourable N/A River Wye SSSI 7 6 Unfavourable - No reason provided. recovering

1 Sites within the influence of the Local Plan 2 Natural England (2017). Designated Sites View. Available at: https://designatedsites.naturalengland.org.uk/ [Date Accessed: 25/10/19]

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No. of Conservation Reason for unfavourable status where European Site1 SSSIs Status of SSSIs2 applicable. Severn Estuary SAC/SPA/Ramsar

66 Favourable N/A Overgrazing of cattle on sward. Likely to 1 Unfavourable - recover once stock removed and recovering vegetation allowed to re-establish. Losses due to coastal squeeze and presence of man-made defences preventing rollback of saltmarsh habitat. 10 Unfavourable – Severn Estuary 82 no change Bird habitat targets met but under review. SSSI Disturbance of some estuary bird assemblages. Losses due to coastal squeeze and man- made defences preventing rollback of 5 Unfavourable - saltmarsh habitat. declining Sward height (grazing) targets not met. Vascular plant assemblage unsuitable for some species. 7 Favourable N/A Managed realignment at Steart Peninsula, 2 Unfavourable - relieved constraints on habitat and now recovering Upper Severn able to evolve naturally inland. 11 Estuary SSSI Uncertain if bird populations are affected 2 Unfavourable - by broad-scale population change or if site declining conditions are impacting the populations. Further investigation required. Walmore Common SPA/Ramsar Water pollution and elevated levels of Walmore 3 Unfavourable – nitrate and phosphate due to agricultural 3 Common SSSI no change runoff and septic tanks within the catchment.

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Appendix E: Threats and Pressures

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Table E.1: Pressures and threats for European sites that may be affected by the South Worcestershire Development Plan Review. Lyppard Walmore Threats/ Downton Severn Estuary Bredon Hill Dixton Wood Fens Pools Grange River Clun River Wye Common Pressures data Gorge (SPA, SAC and (SAC)1 (SAC)2 (SAC)4 Ponds (SAC)6 (SAC)7 (SPA and from SIPs (SAC)3 Ramsar)8 (SAC)5 Ramsar)9

A051(NB) Gadwall, H1130 Estuaries, H1330 H9180 Mixed H7140 Very wet Atlantic salt woodland on mires often meadows, S1095 S1079 Violet base-rich soils Air Pollution identified by an Sea lamprey, click beetle associated unstable S1099 River with rocky ‘quaking’ surface lamprey, S1103 slopes Twaite shad, Waterbird assemblage

1 Natural England (2015) Site Improvement Plan: Bredon Hill. Available at: http://publications.naturalengland.org.uk/file/5656925612015616 [Date Accessed: 24/10/19] 2 Natural England (2015) Site Improvement Plan: Dixton Woods. Available at: http://publications.naturalengland.org.uk/file/5985381096882176 [Date Accessed: 24/10/19] 3 Natural England (2014) Site Improvement Plan: Downton Gorge. Available at: http://publications.naturalengland.org.uk/file/6447596417581056 [Date Accessed: 24/10/19] 4 Natural England (2014) Site Improvement Plan: Fens Pools. Available at: http://publications.naturalengland.org.uk/file/4872756676001792 [Date Accessed: 30/10/19] 5 Natural England (2014) Site Improvement Plan: Lyppard Grange Ponds. Available at: http://publications.naturalengland.org.uk/file/5540066784968704 [Date Accessed: 24/10/19] 6 Natural England (2014) Site Improvement Plan: River Clun. Available at: http://publications.naturalengland.org.uk/file/5739115140087808 [Date Accessed: 30/10/19] 7 Natural England (2014) Site Improvement Plan: River Wye. Available at: http://publications.naturalengland.org.uk/file/5550181483282432 [Date Accessed: 24/10/19] 8 Natural England (2015) Site Improvement Plan: Severn Estuary Mor Hafren. Available at: http://publications.naturalengland.org.uk/file/4856107648417792 [Date Accessed: 24/10/19] 9 Natural England (2014) Site Improvement Plan: Walmore Common. Available at: http://publications.naturalengland.org.uk/file/6299182977515520 [Date Accessed: 24/10/19]

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A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, A149(NB) Dunlin, Change in S1029 A162(NB) A037(NB) land Freshwater Common Bewick's Swan management mussel redshank, A394(NB) Greater white- fronted goose, H1130 Estuaries, H1330 Atlantic salt meadows, Waterbird assemblage A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, S1166 Great A149(NB) Dunlin, Changes in A162(NB) S1079 Violet crested A037(NB) species Common click beetle newt Bewick's Swan distributions redshank, A394(NB) Greater white- fronted goose, H1170 Reefs, S1095 Sea lamprey, S1099 River lamprey, S1103 Twaite

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shad, Waterbird assemblage

Climate S1079 Violet

change click beetle A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, A149(NB) Dunlin, A162(NB) Common Coastal redshank, A394(NB) squeeze Greater white- fronted goose, H1130 Estuaries, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, Waterbird assemblage H9180 Mixed woodland on base-rich soils Deer associated with rocky slopes

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H9180 Mixed woodland on S1166 Great S1029 S1079 Violet S1079 Violet base-rich soils Disease crested Freshwater click beetle click beetle associated newt mussel with rocky slopes

Energy A037(NB)

production Bewick's Swan

Feature location/ extent/ S1079 Violet condition click beetle unknown A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, A149(NB) Dunlin, Fisheries: A162(NB) Commercial Common

marine and redshank, estuarine A394(NB) Greater white- fronted goose, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, S1095

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Sea lamprey, S1099 River lamprey, S1103 Twaite shad, Waterbird assemblage S1095 Sea lamprey, S1096 Brook lamprey, S1099 River Fisheries: Fish lamprey, S1102

stocking Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead S1095 Sea lamprey, S1096 Brook lamprey, S1099 River Fisheries: lamprey, S1102

Freshwater Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead A037(NB) Bewick's swan, A048(NB) Common Fisheries: shelduck, Recreational A051(NB)

marine and Gadwall, estuarine A149(NB) Dunlin, A162(NB) Common redshank, A394(NB)

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Greater white- fronted goose, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, S1095 Sea lamprey, S1099 River lamprey, S1103 Twaite shad, Waterbird assemblage H3260 Rivers with floating vegetation often dominated by watercrowfoot, H9180 Mixed S1095 Sea Forestry and woodland on lamprey, S1096 S1079 Violet S1079 Violet base-rich soils Brook lamprey, woodland click beetle click beetle associated S1099 River management with rocky lamprey, S1102 slopes Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead, S1355 Otter H9180 Mixed Game woodland on management: base-rich soils

pheasant associated rearing with rocky slopes

© Lepus Consulting for Malvern Hills District Council E7 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

H9180 Mixed woodland on S1166 Great Habitat base-rich soils crested associated fragmentation newt with rocky slopes H3260 Rivers with floating vegetation often dominated by watercrowfoot, S1092 White- clawed (or Atlantic stream) crayfish, S1095 Hydrological A037(NB) Sea lamprey, Bewick's Swan changes S1096 Brook lamprey, S1099 River lamprey, S1102 Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead, S1355 Otter A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Impacts of Gadwall, development A149(NB) Dunlin, A162(NB) Common redshank, A394(NB) Greater white-

© Lepus Consulting for Malvern Hills District Council E8 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

fronted goose, H1130 Estuaries, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, S1095 Sea lamprey, S1099 River lamprey, S1103 Twaite shad, Waterbird assemblage H7140 Very wet S1166 Great mires often Inappropriate crested identified by an scrub control newt unstable ‘quaking’ surface H3260 Rivers with floating vegetation often H1130 Estuaries, H9180 Mixed dominated by H1140 Intertidal woodland on S1029 watercrowfoot, mudflats and Invasive base-rich soils Freshwater S1092 White- sandflats, H1170 associated species mussel clawed (or Reefs, H1330 with rocky Atlantic stream) Atlantic salt slopes crayfish, S1102 meadows Allis shad, S1103 Twaite shad

Low breeding S1029 success/ poor Freshwater recruitment mussel

© Lepus Consulting for Malvern Hills District Council E9 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

H1110 Subtidal sandbanks, H1140 Intertidal Marine mudflats and consents and sandflats, H1170 Reefs, H1330 permits: Atlantic salt minerals and meadows, S1095 waste Sea lamprey, S1099 River lamprey, S1103 Twaite shad A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, A149(NB) Dunlin, A162(NB) Common redshank, A394(NB) Marine litter Greater white- fronted goose, H1130 Estuaries, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, S1095 Sea lamprey, S1099 River lamprey, S1103 Twaite shad,

© Lepus Consulting for Malvern Hills District Council E10 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

Waterbird assemblage

A037(NB) Bewick's swan, A048(NB) Common shelduck, A051(NB) Gadwall, A149(NB) Dunlin, A162(NB) Common redshank, A394(NB) Greater white- Marine fronted goose, pollution H1110 Subtidal incidents sandbanks, H1130 Estuaries, H1140 Intertidal mudflats and sandflats, H1170 Reefs, H1330 Atlantic salt meadows, S1095 Sea lamprey, S1099 River lamprey, S1103 Twaite shad, Waterbird assemblage Offsite habitat A037(NB) availability/ Bewick's Swan management

© Lepus Consulting for Malvern Hills District Council E11 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

S1166 Great Overgrazing crested newt H3260 Rivers with floating vegetation often dominated by watercrowfoot, S1095 Sea S1095 Sea lamprey, S1096 S1029 lamprey, S1099 Physical Brook lamprey, Freshwater River lamprey, S1099 River modification mussel S1103 Twaite lamprey, S1102 shad Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead, S1355 Otter H3260 Rivers A037(NB) with floating Bewick's swan, vegetation often A048(NB) dominated by Common watercrowfoot, shelduck, S1092 White- A051(NB) clawed (or Gadwall, Atlantic stream) A149(NB) Dunlin, crayfish, S1095 Public access/ A162(NB) A037(NB) Sea lamprey, Common Bewick's Swan disturbance S1096 Brook redshank, lamprey, S1099 A394(NB) River lamprey, Greater white- S1102 Allis shad, fronted goose, S1103 Twaite H1130 Estuaries, shad, S1106 H1170 Reefs, Atlantic salmon, H1330 Atlantic S1163 Bullhead, salt meadows, S1355 Otter

© Lepus Consulting for Malvern Hills District Council E12 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

Waterbird assemblage S1029 Siltation Freshwater mussel H3260 Rivers with floating vegetation often dominated by watercrowfoot, S1092 White- clawed (or Atlantic stream) Transportation crayfish, S1095 and service Sea lamprey, corridors S1096 Brook lamprey, S1099 River lamprey, S1102 Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead, S1355 Otter H7140 Very wet mires often Undergrazing identified by an unstable ‘quaking’ surface S1092 White- clawed (or Atlantic stream) Water crayfish, S1095

abstraction Sea lamprey, S1096 Brook lamprey, S1099 River lamprey,

© Lepus Consulting for Malvern Hills District Council E13 South Worcestershire Interim HRA Report to support the plan making process November 2019 LC-578_SWDPR_HRA_Appendix E_Threats and Pressures_3_301019LB.docx

S1102 Allis shad, S1103 Twaite shad, S1106 Atlantic salmon, S1163 Bullhead, S1355 Otter A037(NB) Bewick's swan, A048(NB) Common shelduck, H3260 Rivers A051(NB) with floating Gadwall, vegetation often A149(NB) Dunlin, dominated by A162(NB) watercrowfoot, Common S1092 White- redshank, clawed (or A394(NB) Atlantic stream) Greater white- S1166 Great S1029 crayfish, S1095 fronted goose, Water crested Freshwater Sea lamprey, H1110 Subtidal pollution newt mussel S1096 Brook sandbanks, H1130 lamprey, S1099 Estuaries, H1140 River lamprey, Intertidal S1102 Allis shad, mudflats and S1103 Twaite sandflats, H1170 shad, S1106 Reefs, H1330 Atlantic salmon, Atlantic salt S1163 Bullhead, meadows, S1095 S1355 Otter Sea lamprey, S1099 River lamprey, S1103 Twaite shad, Waterbird assemblage