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Draft Water Resources Management Plan 2019 Annex 14: SEA Main Report

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Draft Water Resources Management Plan 2019 Annex 14: SEA Main Report Draft Water Resources Management Plan 2019 Annex 14: SEA Main Report Appendix A: Consultee responses to the scoping report and amendments made as a consequence November 30, 2017 Version 1 Appendix A Statement of Response Southern Water issued its Strategic Environmental Assessment (SEA) Scoping Report for its Draft Water Resources Management Plan 2019 for public consultation from 28th April 2017 to 2nd June 2017. Comments on the SEA Scoping Report were received from the following organisations: Natural England Environment Agency Historic England Howard Taylor, Upstream Dry Fly Sussex Wildlife Trust The Test & Itchen Association Ltd Wessex Chalk Stream Rivers Trust Forestry Commission England Hampshire and Isle of Wight Wildlife Trust Longdown Management Limited Amanda Barker-Mill C. H. Layman These comments are set out in Table 1 together with Southern Water’s response as to how it intends to take account of them in developing the SEA of the Draft Water Resources Management Plan. Table 1 Draft Water Resources Management Plan: SEA Scoping Report – responses to comments received How comments have been addressed in the Ref Consultee Comment Draft Water Resources Management Plan Environmental Report Plans programmes or policies I recommend you add the following to your list of plans programmes or policies: National. - Defra strategy for the environment creating a great place for These policies, plans and programmes have Natural living. been included in the SEA Environmental Report 1 England - The national conservation strategy conservation-21 and considered in the assessment of potential effects of the WRMP. - The 5 point plan to salmon conservation in the UK National Nature Reserve Management Plans (though you may not be able to, or need to, list all of these, please just reference them as a source of information for assessment of any relevant options). Designated sites Natural England has not fully reviewed the long list of sites in Appendix B – which appears comprehensive at first look. Natural England will send you a note separately on any recent additions or amendments to the list should any be required. Note that figures B1, B2 and B3 showing designated sites and national conservation Natural and landscape features were missing from the appendices received The condition of SSSIs are considered where 2 England by Natural England. relevant in the individual option assessments. Appendix B should be amended to include a map of the current condition of the SSSIs. A summary of the overarching condition of SSSIs in the supply area (in broad terms e.g. percentage in favourable condition) should be provided in Section 4.2.1. This will provide a helpful baseline for designated sites which will help with the SEA of the dWRMP. 3 Marine Conservation Zones 3 Draft Water Resources Management Plan 2019 Annex 16: SEA Main Report Appendix A: Statement of Response How comments have been addressed in the Ref Consultee Comment Draft Water Resources Management Plan Environmental Report Appendix B should be revised to include a list of all Marine Natural The appendix has been updated to reflect this Conservation Zones within the assessment boundary coastal water England comment. bodies. Biodiversity The biodiversity key threats has been updated to reflect this comment. Many of the key threats and changes are captured including New key message added: The need to recognise climate change and invasive none native species. The high the potential issues relating to high population population and development pressure in the Southern Water and development pressures in the water supply Natural 4 Supply area however is not referenced as a pressure in the area which are likely to impact on the need for England baseline of the biodiversity. The high levels of anthropogenic water and related condition of the environment, pressure are of significant relevance to both the need for water and and subsequently its ability to withstand the baseline condition of the environment and therefore its ability to additional pressures of climate change, new withstand additional pressures of climate change, new water water resources and future growth. resources and future growth. Landscape Natural 5 Noted and thank you for your comment. England Natural England welcomes the use of NCA and LCA appraisals in the baseline review. Natural Natural England welcomes the document structure which is clear 6 Noted and thank you for your comment. England transparent and has a good use of plain English. The map showing the geographical scope of the report shows the core study area and includes an extended northern boundary to Reference to impacts from the source of the encompass the spatial scope of options being considered water for bulk transfers and relevant environmental receptors has been identified in Natural (reflecting the potential for bulk supply import options). It may be 7 the individual option assessments. The full England that the impacts of the source waters from cross regional transfers will extend well beyond the northern border shown. Though the environmental assessments will be carried out by impacts of such cross regional transfers should be assessed in the the donor companies of bulk transfers. donor company plan, reference to impacts from the source of the water and relevant environmental receptors should be referenced 4 Draft Water Resources Management Plan 2019 Annex 16: SEA Main Report Appendix A: Statement of Response How comments have been addressed in the Ref Consultee Comment Draft Water Resources Management Plan Environmental Report in the cumulative and in combination assessments for Southern The transitional and coastal water bodies and Waters’ SEA. biodiversity within them are included within the Relevant coastal water bodies are also illustrated but the map SEA boundary shows an open boundary to the SEA. Natural England have assumed that the coastal water bodies and biodiversity within them are within the study boundary. The summary table 3.1 and appendices appears to be very thorough and lists the majority of plans and programmes relevant to Natural this SEA. References to Site Improvement Plans, green 8 Noted and thank you for your comment. England infrastructure plans and Natural England’s standing advice are particularly welcome. References to National Park and AONB management plans are also welcome. Please seen annex 1 and annex 2 for our detailed comments on Natural sources of helpful environmental data. Please forward Natural 9 The figures will be forwarded to NE. England England a copy of the figures as these were missing from the copy of the consultations documents received by Natural England. Priority species (and habitats) were discussed at a strategic level in the Scoping Report and were Natural England strongly recommends that the local records Natural considered as part of the SEA. 10 centres and the local catchment groups are approached for England information on priority habitats and species. More detailed assessment will be required as detailed design of schemes included in the plan included within the plan are progressed. The proposed approach is clear and simple, and links to the SEA Protected species (and habitats) were discussed objectives are clear in table 5.2. What is less clear is how the very at a strategic level in the Scoping Report and Natural good SEA key questions in table 5.1 will be linked to the 11 were be considered as part of the SEA. England assessment matrices described in section 5.2. Clarification of this point would be helpful. I note that the SEA matrices will only show MCZs have been considered where appropriate the residual (post mitigation) impacts in the assessment matrices. as part of Objective 1.1 in the SEA. 5 Draft Water Resources Management Plan 2019 Annex 16: SEA Main Report Appendix A: Statement of Response How comments have been addressed in the Ref Consultee Comment Draft Water Resources Management Plan Environmental Report Natural England welcomes the habitats regulations assessment using conservation objectives for the relevant Natura 2000 sites. Natural England strongly recommends that individual assessments of options, that are likely to impact priority habitats or species, are included in addition to those impacting national and international sites. Note that reference to assessment of Marine Conservation Zones has not been made. The landscapes and habitats in Southern Waters supply area include very high proportions of high value landscapes and habitats. Standard construction mitigation methodologies do not always work to remove impacts on such habitats. It is essential that the assessment methodology and mitigation assumptions can be The SEA Environmental Report has made it clear teased apart to ensure that all assumptions are appropriate to the what mitigation measures have been assumed for Natural 12 environmental receptors. It may not be necessary to amend the for the schemes and which have therefore England final matrices table if sufficient information on each options informed the assessment of each option post- assessment is available. Other companies are producing individual mitigation. options reports for key options so the likely efficacy of proposed mitigation can be clearly assessed. Natural England welcomes the proposals to assess any options on or likely to affect a SSSI against the sites favourable condition tables. Designated sites The SEA Environmental Report should assess the potential for the proposal to affect nationally and internationally important designated
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