Assessment of the Scottish Borders Local Plan in Terms of the Need for Appropriate Assessment

APPENDIX F: ASSESSMENT OF THE SCOTTISH BORDERS LOCAL PLAN IN TERMS OF THE NEED FOR APPROPRIATE ASSESSMENT

Appendix F. Assessment of the Scottish Borders Local Plan in Terms of the Need for Appropriate Assessment.

Purpose To advise Council on the output from assessing the Local Plan in terms of the need for Appropriate Assessment and to agree that this report is sent to the Scottish Ministers as part of the Council’s submission on the Local Plan.

Background Policy Context A recent European Court ruling has confirmed that Article 6(3) of the Habitats Directive applies to Development Plans. Where a Local Plan is likely to have a significant effect on a European site it should be subject to an Appropriate Assessment of the implications for the site’s conservation objectives.

The Scottish Executive produced Interim Guidance entitled “Assessing Development Plans in Terms of the Need for Appropriate Assessment” in May 2006. This outlines why consideration of this is necessary, what steps are required and how the Scottish Government and Scottish Natural Heritage can assist. In the future the Scottish Government intend to supersede this guidance by amending The Conservation (Natural Habitats, &c.) Regulations 1994 (“Habitats Regs”).

The Scottish Borders Local Plan does not need a Strategic Environmental Assessment. This is because the Strategic Environmental Assessment Gateway granted the Planning Authority exemption in spring 2006 in acknowledgement of the substantial consideration of environmental issues and public consultation.

Natura Sites Natura Sites are the collective term for internationally designated nature conservation sites including Special Areas of Conservation (SAC), Special Protection Areas (SPA) and Ramsar sites. There are fourteen Natura Sites in the Borders, some of which have more than one designation, see Annex 1 for their locations. These are designated because of their habitat and/or species interest and are of the following main type: rivers, birds, upland and/ or bogs, coastal or woodland. The “qualifying interests” and “conservation objectives” for these sites are listed in Annex 2.

Appraisal of Individual Policies It is considered that the likely significant effect of all Local Plan policies on Natura Sites is neutral, see Annex 3. It is considered that there will be no significant negative effects because Policy NE1 – International Nature Conservation Sites applies to any development proposal that has a possible link with a Natura site. The aim of Local Plan Policy NE1 is to give wildlife sites of international importance adequate protection from development, in accordance with European Directives and UK legislation. This policy applies to all development proposals that have a possible link to a Natura site and will ensure that any proposal that may have a significant impact on a Natura site would be subject to an Appropriate Assessment. The Waverley Line was identified on the Proposals Maps under Policy Inf1 – Transport Safeguarding. A full Appropriate Assessment was approved by the Scottish Parliament for the Waverley Railway Project from Edinburgh to Tweedbank. As an additional safeguard Local Plan policies that have the potential to have negative effects on Natura sites will be cross referenced to Policy NE1.

Appraisal of Land Use Allocations The Plan’s land use allocations and other key proposals were considered to identify the possibility of a significant effect on a Natura Site. The 2005 Biodiversity Risk Assessment of Local Plan Sites was the main source of information for this.

This Risk Assessment was carried out for land use allocations (allocations) in the Draft Local Plan 2004 and some allocations included in the Second Stage Consultation on the Draft Local Pan in 2005. This assessment considered potential risk to biodiversity, including Natura sites. It was a desk top study of known information, therefore there is not a complete coverage of habitats and species information. This assessment considered the proximity of each allocation to species of interest or habitat features, biodiversity connectivity and site size. Each of the sites was allocated to a category of risk to biodiversity, either major, moderate or minor.

The Biodiversity Risk Assessment was reviewed to identify allocations which were considered to be a moderate or major risk to the qualifying species or habitats of a Natura site, See Annex 4. These allocations were reported in a screening matrix where they had a potential link to a Natura site, see Annex 5. The allocations likely to have a minor or no risk to a Natura site were noted in Annex 6.

An in house study was carried out for sites that were first allocated in the Finalised Local Plan 2005 or included in the Proposed Modifications to the Finalised Local Plan, as they were not subject to the Biodiversity Risk Assessment. The Geographical Information System was used to identify which of these later sites were within 500 metres of a Natura site. If they were more than 500 metres from a Natura site they were considered to have minor or no impact. The sites within 500 metres of a Natura site were assessed in house, comparing them with sites in the Biodiversity Assessment which were similar in nature and nearby if possible. The remainder were identified as not assessed. These sites were also reported in the screening matrix if they had a potential link to a Natura site or had not been assessed, see Annex 5. If these sites are likely to have a minor or no risk to a Natura site they were noted in Annex 6.

The Proposed Modifications to the Finalised Local Plan include the deletion of some land use allocations. Therefore although these sites were part of the screening process they have not been included in Annexes 5 and 6.

The likely significant effect of all land use allocations on Natura Sites is considered to be neutral. It is considered that no further Appropriate Assessments are required at Local Plan stage for the land use allocations. Any potential significant effects of individual proposals will be assessed at the planning application stage when the requirement for Appropriate Assessment would be further considered. The likely effects on Natura sites from the allocations could be mitigated at planning application stage. The likely effects to be considered include disposal of construction material, disturbance, damage or destruction of qualifying habitats or species, pollution and discharges from foul and surface water. With regard to the River Tweed SAC there will be a focus on likely effects on river flow, channel substrate and water quality. SEPA regulates effects on water quality.

Cumulative Impact of Scottish Borders Local Plan Policies and Proposals on Natura Sites. Scottish Natural Heritage (SNH) and the Scottish Environment Protection Agency (SEPA) did not object to the Local Plan on the cumulative impact of Local Plan policies and proposals on Natura sites. They were further consulted on this matter as part of the Appropriate Assessment screening process on the Local Plan.

Further work was carried out to appraise the cumulative impact of Finalised Local Plan policies and proposals on the River Tweed SAC. SEPA were sent additional information on the potential cumulative impact of this on the River Tweed SAC and were asked for their comments, see Annex 7. Land Use Allocations under Policy H3, safeguarded sites under Policy BE10 Newtown St Boswells Expansion Safeguarding and the safeguarded site under Policy BE11 H1A Land Safeguarding were considered. They were identified if they fell within 500m of the River Tweed SAC, had a housing component and do not appear in an existing Local Plan. New Finalised Local Plan sites or policy safeguarding areas within 500m of the River Tweed include: 150ha of new land use with a total indicative capacity of 1950 units; Policy BE11 sites with an indicative capacity of 50 units on 4ha; the Policy BE10 site where 900 units are safeguarded. SEPA responded by stating that provided each development is considered appropriately in its own right and given that the planned Local Plan developments to date are relatively small to moderate at most it did not consider that there will be a deleterious cumulative impact form the Local Plan.

SNH considered that Local Plan policies and proposals have the potential to have a cumulative impact on the Borders Woods SAC. These include land use allocations and the Policy BE10 Newtown St Boswells Expansion Safeguarding. This impact is likely to come from the disturbance of increased recreational use and domestic dumping of rubbish. However SNH considered that these effects can be mitigated at the planning application stage and therefore are not significant.

It is therefore considered that the Local Plan policies and proposals will not have a cumulative impact on the Natura sites, including the River Tweed SAC.

Consultation SNH & SEPA have been consulted on the need for an Appropriate Assessment of the Local Plan. An initial scoping meeting was held with SNH on 18.4.07 and a joint meeting with SNH and SEPA was held on 12.7.07 to review the screening matrix, Annex 5, and discuss the cumulative impact of the Local Plan on Natura Sites.

SNH and SEPA were consulted on the Proposed Modifications to the Finalised Local Plan during the consultation period from November 2007 to January 2008. SNH’s comments on the potential impact of two proposed modifications sites on the Tweed SAC have been noted in Annex 5.

Risk Commentary This appraisal has been carried to meet the requirement of the European Union’s Habitats Directive and Scottish Government Guidance. This requires that where a Local Plan is likely to have a significant effect on a European site they should be subject to Appropriate Assessment of their implications for the site’s conservation objectives.

Summary This appraisal of the potential effects of the Scottish Borders Local Plan on Natura sites concludes that an Appropriate Assessment of the Local Plan is not necessary. It is considered that the potential effects on Natura sites from Local Plan policies and proposals are likely to be mitigated at the planning application stage. At planning application stage more detailed information may be provided that indicates that there may be a significant effect on a Natura site. However an Appropriate Assessment can be required at that stage under Policy NE1 - International Nature Conservation Sites.

Conclusions To advise Council that the assessment of the Local Plan in terms of the need for Appropriate Assessment has identified that Appropriate Assessment of the Local Plan is not required. To advise the Council to agree that this report is sent to the Scottish Ministers as part of the submission on the Local Plan.

Annexes:

Annex 1 – Location Map of the Natura Sites in the Scottish Borders.

Annex 2 – The Conservation Objectives for Natura Sites in the Scottish Borders and a List of their Qualifying Interests.

Annex 3 - Scottish Borders Local Plan Policies and Possible Links to Natura Sites.

Annex 4 – The Method Used to Interpret the Scottish Borders Biodiversity Risk Assessment of Local Plan Sites.

Annex 5 - Scottish Borders Local Plan Appropriate Assessment Screening Matrix

Annex 6 – List of Local Plan Proposals Which Are Likely to Have a Minor or No Impact on Natura Sites

Annex 7 – Additional Information Provided to SEPA on the Cumulative Impact of the Scottish Borders Finalised Local Plan on the River Tweed SAC.

4 1:500,000 7 ± i Annex 1 Eyemouth Natura Sites Key Major Settlement 1 i 2 Duns 8 i 5 i Natura Site i 6 3 i ( and i ) i 4 1 Craigengar SAC i 2 Westwater Peebles SPA/RAMSAR Innerleithen 3 Moorfoot Hills SAC Galashiels 4 Threepwood Moss SAC Melrose Kelso 12a 5 Dogden Moss SAC i i 6 Greenlaw Moor Selkirk 11 SPA/RAMSAR i 13b 7 St Abbs Head to Fast Castle SPA/SAC 8 Berwickshire & North Jedburgh Northumberland Coast SAC 9 Moffat Hills SAC Hawick 10 Newcastleton Hills SPA 9 11 Din Moss & Hoselaw i i12c Loch SPA/RAMSAR 13a i 12(a,b,c) Borders Woods SAC 13(a,b) Whitlaw & Branxholme i 12b SAC

River Tweed SAC

10 i

Annex 2 – The Conservation Objectives for Natura Sites in the Scottish Borders and a List of their Qualifying Interests.

SNH’s Conservation Objectives for SAC Qualifying Habitats “To avoid deterioration of the qualifying habitat (listed below) thus ensuring that the integrity of the site is maintained and the site makes and appropriate contribution to achieving favourable conservation status for each of the qualifying features; and

To ensure for the qualifying habitat that the following are maintained in the long term: • Extent of the habitat on site • Distribution of the habitat within site • Structure and function of the habitat • Processes supporting the habitat • Distribution of typical species of the habitat • Viability of typical species as components of the habitat • No significant disturbance of typical species of the habitat”

SNH’s Conservation Objectives for SAC or SPA Qualifying Species “To avoid deterioration of the habitats of the qualifying species (listed below) or significant disturbance to the qualifying species, thus ensuring that the integrity of the site is maintained *and the site makes an appropriate contribution to achieving favourable conservation status for each of the qualifying features; and

To ensure for the qualifying species that the following are maintained in the long term:

• Population of the species as a viable component of the site • Distribution of the species within site • Distribution and extent of habitats supporting the species • Structure, function and supporting processes of habitats supporting the species • No significant disturbance of the species”

* sentence in italics applies to SACs not SPAs

The Natura Sites’ Qualifying Interests

River River Tweed SAC Qualifying Species – Atlantic Salmon, Otter, Sea Lamprey, Brook Lamprey, River Lamprey Qualifying Habitats – Rivers with floating vegetation often dominated by water crowfoot.

Bird Interest Din Moss & Hoselaw Loch SPA/ Ramsar site Qualifying Species for Ramsar & SPA – pink footed geese and greylag geese

Greenlaw Moor SPA/ Ramsar site Qualifying Species for Ramsar & SPA – pink footed geese

Westwater Reservoir SPA/ Ramsar site Qualifying Species for Ramsar & SPA- pink footed geese and waterfowl

Newcastleton Hills SPA Qualifying Species – hen harrier

Uplands &/or Bogs Whitlaw & Branxholme SAC Qualifying Species – Slender green feather-moss Qualifying Habitats – Base-rich fens, Very wet mires often identified by an unstable ‘quaking’ surface

Craigengar SAC Qualifying Species – Marsh saxifrage Qualifying Habitats – Dry heaths, Species-rich grassland with mat-grass in upland areas

Moffat Hills SAC Qualifying Habitats – Alpine and subalpine healths, Blanket bog, Plants in crevices on base-rich rocks, Dry heaths, Tall herb communities, Montane acid grasslands, Plants in crevices on acid rocks, Acidic scree,

Moorfoot Hills SAC Qualifying Habitats – Blanket Bog, Dry heaths

Threepwood Moss SAC Qualifying Habitats – Active raised bogs, Degraded raised bogs still capable of natural regeneration

Dogden Moss SAC Qualifying Habitats – Active raised bogs

Coastal St Abbs Head to Fast Castle SPA/SAC Qualifying Species for SPA – eight species of seabird & guillemot Qualifying Habitat for SAC– Vegetated sea cliffs

Berwickshire & North Northumberland Coast SAC Qualifying Species – grey seal, Qualifying Habitats - shallow inlets and bays, intertidal mudflats and sand flats, reefs, sea caves

Woods Borders Woods SAC Qualifying Habitat – Mixed woodland on base-rich soils associated with rocky slopes

Annex 3 - Scottish Borders Local Plan Policies and Possible Links to Natura Sites.

Abbreviations : NE= Negative, P = Positive, No = None

Likely Significant Ref Policy Name PossibleLink Effect Education BE9 Safeguarding NE neutral H1A Safeguarding: Newtown St BE10 Boswells NE neutral H1A Land BE11 Safeguarding NE neutral Further Housing BE12 Land Safeguarding NE neutral Protection of ED1 Employment Land NE neutral Land Use H3 Allocations NE neutral Transport Inf1 Safeguarding NE neutral Protection of Access Inf2 Routes NE neutral Transport Inf10 Development NE neutral Renewable Energy D4 Development NE neutral Mineral and Coal R3 Extraction NE neutral Development Outwith Development G8 Boundaries NE neutral Quality Standards for New G1 Development P neutral G2 Contaminated Land P neutral Hazardous G3 Developments P neutral G4 Flooding P neutral Developer G5 Contributions P neutral Gardens and Designed BE3 Landscapes P neutral International Nature NE1 Conservation sites P neutral National Nature NE2 Conservation sites P neutral NE3 Local Biodiversity P neutral Trees, Woodlands NE4 and Hedgerows P neutral

Development Affecting the Water NE5 Environment P neutral River Engineering NE6 Works P neutral EP4 Coastline P neutral EP5 Air Quality P neutral Waste Water Treatment Inf5 Standards P neutral Sustainable Urban Inf6 Drainage P neutral Developer Contributions Related to Railway G6 Reinstatement No neutral G7 Infill Development No neutral BE1 Listed Buildings No neutral Archaeological Sites and Ancient BE2 Monuments No neutral BE4 Conservation Areas No neutral Protection of Open BE6 Space No neutral BE7 Care Homes No neutral Caravan and BE8 Camping Sites No neutral National Scenic EP1 Areas No neutral Areas of Great EP2 Landscape Value No neutral Prevention of Settlement EP3 Coalescence No neutral Employment Uses Outwith ED2 Employment Land No neutral Shopping ED3 Development No neutral Prime Retail ED4 Frontage No neutral ED5 Town Centres No neutral H1 Affordable Housing No neutral Protection of H2 Residential Amenity No neutral Road Adoption Inf3 Standards No neutral Inf4 Parking Standards No neutral Waste Management Inf7 Facilities No neutral Radio Inf8 Telecommunications No neutral Development within Inf9 Exclusion Zones No neutral

Developments that Generate Travel Inf11 Demand No neutral Business, Tourism and Leisure Development in the D1 Countryside No neutral Housing in the D2 Countryside No neutral Advertisements in D3 the Countryside No neutral Protection of Prime Quality Agricultural R1 Land No neutral Safeguarding of R2 Mineral Deposits No neutral BE5 Advertisements No neutral

Annex 4 – The Method Used to Interpret the Scottish Borders Biodiversity Risk Assessment of Local Plan Sites

The Biodiversity Risk Assessment screened Draft Local Plan land use allocations for natural heritage interest. This included species, habitats, features that provide connectivity of habitats and populations and area affected. The proximity of natural heritage interest to each site boundary was also considered. Each land use allocation was assessed to identify the risk to each of these four issues, major, moderate or minor. Then the land use allocation was allocated to an overall category of risk to biodiversity, major, moderate or minor.

The risk assessments for individual land use allocations (allocations) were reviewed to identify risk to the Natura sites. Natura sites are identified because of the presence of certain qualifying species or habitats. An allocation was identified as having a possible link to a Natura site and noted in the screening matrix where the following information was found:

• Allocations identified as moderate or major risk to species and habitats, where there are qualifying species and a Natura site within 500m. Particularly where qualifying species are mentioned in the commentary. • Allocations identified as moderate or major risk to habitats where there is a Natura site within 500m. Particularly where Natura sites are mentioned in the commentary. In this case if there is also a qualifying species within 500m of the allocation (despite being at minor risk) this is noted. • Allocations identified as moderate or major risk to the connectivity of biodiversity where Natura sites and their qualifying species are mentioned in the commentary.

1 Annex 5- Local Plan Appropriate Assessment Screening Matrix

Site Name Ref Type Possible Link Likely Action Notes Sig. Effect Settlement: ALL Policy: ALL ALLALL 364 ALL The cumulative impact of all Local Plan land use neutral Appropriate SEPA was provided with allocations and policies within the catchment of the River Assessment not additional information on Tweed (TSAC) on its qualifying interests. required the total area and capacity of new land use allocations with a housing component within 500 metres of the TSAC, see Annex 7. Policy: ALL POLICIES ALL ALL 359 ALL All Local Plan policies have either a positive or a neutral neutral Appropriate The aim of Local Plan POLICIES impact on Natura Sites because Policy NE1 International Assessment not Policy NE1 - Nature Conservation Sites applies to any development required International Nature proposal that has a possible link with a Natura site. The Conservation Sites is to policies in the Local Plan fall into four different categories. give wildlife sites of There are: general policies providing guidance for new international importance development, policies providing guidance on specific types adequate protection from of land uses and how they will be controlled, policies that development, in protect environmental assets and policies that safeguard accordance with exisiting land uses either to retain the current use or to European Directives and avoid prejudicing future development. UK legislation. This policy applies to all development proposals that have a possible link to a Natura site and will ensure that any proposal that may have a significant effect would be subject to an Appropriate Assessment.

Settlement: Bonchester Bridge Policy: H3 SRB5BCaravan Site 183 H General moderate risk to habitat and connectivity. Specific neutral Appropriate comments on connectivity: habitat corridor of river and Assessment not contiguous populations of riverine species. required Note - Rule Water (TSAC) forms E boundary of site. Likely to be Salmon, Lamprey & Otter in river.

Settlement: Broughton Policy: H3 TB200Dreva Road 372 H Site is within 100 to 500metres of the Broughton Burn neutral Appropriate (TSAC). Assessment not required TB10BSpringwell Brae 246 H Site is less than 100 metres from the Broughton Burn neutral Appropriate (TSAC). Assessment not required

Settlement: Clovenfords Policy: ALL ALLClovenfords 338 ALL Settlement adjacent to Caddon Water (TSAC). neutral Appropriate Assessment not required Policy: H3

Settlement: Coldstream Policy: ALL ALLColdstream 365 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required

Settlement: Darnick Policy: EM35DBroomilees Road 373 H Site is within 100 to 500metres of the TSAC. neutral Appropriate Assessment not required

Settlement: Earlston

Settlement: Eyemouth Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 5 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect Policy: ALL ALLEyemouth 347 ALL Settlement adjacent to Berwichire & North neutral Appropriate Northumberland Coast (SAC). Assessment not required Policy: H3 BEY1Barefoots 377 H Site is within 100 to 500metres of the Berwickshire and neutral Appropriate North Northumberland Coast SAC. Assessment not required zMU2Gunsgreen 308 MU Berwickshire and North Northumberland Coast SAC less neutral Appropriate SNH want to be involved than 100 metres to East. Assessment not in any masterplanning required exercise because of the high nature conservation status of the coast. They commented that development is unlikely to affect the qualifying interests of seals, bays and reefs but pollution and debris could affect the SAC.

Settlement: Galashiels Policy: ALL ALLGalashiels 339 ALL Settlement adjacent to Gala Water and Tweed (TSAC). neutral Appropriate Assessment not required Policy: BE9 zED2Heriot Watt 67 ED General risk to habitat and connectivity is moderate. neutral Appropriate Uni/Borders However there is a specific habitat reference that Gala Assessment not College, Netherdale Water (TSAC) is separated from the site by a road. Specific required Campus connectivity references to: habitat corridor of Gala Water and contiguous populations of Salmon, Lamprey & Otter. Policy: H3

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 6 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect EGL41Buckholm North 289 H Overall risk due to habitats & area moderate. Note - neutral Appropriate Salmon, Lamprey (sea & brook) and Otter within 1km. Assessment not Note - Gala Water (TSAC) within 100m. required zCR1Currie Road 71 CR General risk to species, habitat and connectivity is neutral Appropriate Site now developed with moderate. Specific habitat reference to Gala Water (TSAC) Assessment not Asda Supermarket & bordering site. Specific connectivity references to: required inner relief road. contiguous habitats and habitat corridor of Gala Water and contiguous populations of Salmon. Note - Salmon within 100m. EGL14BEaster Langlee 266 H General risk due to species, habitats and area is moderate neutral Appropriate Planning Brief addresses and risk to connectivity is major. Specific connectivity Assessment not ecological impacts and reference to contiguous populations of Otter. General required an Ecological Impact overall comment that the site currently acts as a buffer Assessment would be between the developed area and the Allan Water (TSAC). required. Note - site is within 100m of species: Salmon, Lamprey, Otter. It is also within 100m of habitats: Tweed (TSAC) and Allan Water (TSAC). zRO22Galafoot 76 RO No risk assessment for this site but there is one for zED2 neutral Appropriate nearby and similar issues apply. Overall moderate risk to Assessment not habitats and connectivity. Specific connectivity reference required as habitat corridor of Gala Water and contiguous populations of Salmon, Otter & Lamprey. Note - Tweed (TSAC) including Gala Water within 100m. zIR1Galashiels Inner 74 IR General risk to species, habitat and connectivity is neutral Appropriate Road & bridge Relief Road moderate. Specific species reference to a variety of wildlife Assessment not completed. that use Gala Water, such as Salmon & Otter. Specific required habitat reference to new bridge passing over Gala Water (TSAC). Specific connectivity references to: contiguous habitats and habitat corridor of Gala Water and contiguous populations of Salmon. Note - Salmon is within 100m of site.

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 7 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect zTI1Galashiels 64 TI General risk to species, habitat and connectivity is neutral Appropriate Transport moderate. Specific species reference to those in Gala Water Assessment not Interchange including Otter. Specific habitat reference to Gala Water required (TSAC) immediately adjacent to site. Specific connectivity references to: contiguous habitats and habitat corridor of Gala Water and contiguous populations of Salmon and other riverine wildlife. Note - Salmon 100 to 500 m from the site. zCR2Huddersfield 72 CR General risk to species is moderate. Comment on habitat - neutral Appropriate St/Hill Street separated from sensitive habitat by road & buildings. Assessment not Note - Salmon and Gala Water (TSAC) within 100m. required zRO202Melrose Road 379 RO Site is within 100 to 500metres of the Gala Water (TSAC). neutral Appropriate Assessment not required EGL200North Ryehaugh 378 H Moderate overall risk to habitats and connectivity. Specific neutral Appropriate habitat reference that a small wooded strip separated the Assessment not site from the River. Specific connectivity reference that required woodland forms a continuous corridor along the Gala Water. Note - site within 100m of Gala Water (TSAC). Salmon, Lamprey (Sea & Brook) and Otter within 1km. zRO4Plumtreehall Brae 65 RO General risk to species, habitat and connectivity is neutral Appropriate moderate. Specific habitat reference to Gala Water (TSAC) Assessment not forming southern boundary of site. Specific connectivity required references to: habitat corridor of Gala Water and contiguous populations of Salmon, Lamprey, Otter. Note - Salmon is within 100m of the site. zRO6Roxburgh Street 66 RO General risk to species is moderate and specific species neutral Appropriate reference to Lamprey using Gala Water. Note - Salmon & Assessment not Otter and Gala Water (TSAC) are 100 to 500 m from the required site. EGL32BRyehaugh 285 H Moderate overall risk to habitats and connectivity. Specific neutral Appropriate habitat reference that a small wooded strip separated the Assessment not site from the River. Specific connectivity reference that required woodland forma a continuous corridor along the Gala Water. Note - site within 100m of Gala Water (TSAC). Salmon, Lamprey (Sea & Brook) and Otter within 1km.

Settlement: Hawick Policy: ALL ALLHawick 337 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Policy: H3 RHA7BBurnflat Brae 244 H General moderate risk to habitats. Note - Borders Woods neutral Appropriate SAC within 100m, Slitrig Water (TSAC) within 100m to Assessment not east, Otter 100m to 500m from the site. required zRO8Commercial Road 187 RO General risk to species and habitat is moderate. Specific neutral Appropriate species reference: also Lamprey in Teviot. Specific habitat Assessment not reference to River Teviot (TSAC) which forms boundary of required site to East. Note - Otter 100m to 500m from the site.

Settlement: Innerleithen Policy: ALL ALLInnerleithen 331 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required

Settlement: Jedburgh Policy: ALL ALLJedburgh 350 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 9 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect Policy: H3 zRO1The Anna 25 RO General risk to species, habitat and connectivity is neutral Appropriate moderate. Specific species reference to: Jed Water used by Assessment not a variety of wildlife including some not recorded at this required location, such as Otter. Specific habitat reference to site immediately adjacent to Jed Water (TSAC). Specific connectivity references to: contiguous habitats and habitat corridor of Jed Water and contiguous populations of Salmon. RJ27DWildcat Cleuch 380 H Site is within 100 to 500metres of the Jed Water (TSAC). neutral Appropriate Assessment not required

Settlement: Kelso Policy: ALL ALLKelso 351 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Policy: H3 zEL206Pinnaclehill 392 EL Site is outwith 500metres of the River Tweed (TSAC) neutral Appropriate however a watercourse adjacent to the site links it to the Assessment not TSAC. Required zRD200Pinnaclehill Retail 381 RD Site is within 100 to 500metres of the Tweed (TSAC). neutral Appropriate Assessment not required

Settlement: Lauder Policy: ALL ALLLauder 327 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Policy: H3 Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 10 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect ELA9BWyndhead 306 H General risk to habitats & connectivity is moderate. neutral Appropriate Site largely developed. Specific habitat comment that the Lauder Burn (TSAC) Assessment not forms the south west boundary of the site. Specific required connectivity comments: habitat corridor is Lauder Burn, contiguous populations of aquatic species. Note - Salmon & Lamprey and Leader Water (TSAC) 100 to 500 metres from the site.

Settlement: Melrose Policy: ALL ALLMelrose 368 ALL Settlement is adjacent to the TSAC. neutral Appropriate Assessment not required

Settlement: Newtown St Boswells Policy: ALL

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 12 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect NSBESNewtown St 361 NSBES General risk to species, habitat and area is moderate and neutral Appropriate The Planning Brief for Boswells connectivity is major. Specific habitat references: Assessment not the Mart site considers Expansion Potentially substantial indirect effects on Newtown St required the Ecological Impact of Safeguarding (Mart Boswells Woods SSSI. This risk becomes major if any of development on these & East) the SSSI is encroached on. There is a risk of contamination Natura sites and an of burns leading to pollution of the Tweed (TSAC). Ecological Impact Specific connectivity references to: habitat corridor of all Assessment would be burns adjacent to the development blocks, they form required. SNH important riverine and woodland corridors (Holmes Burn, commented that all Newtown Burn, Bowden Burn and/ or Sprouston Burn) and development must contiguous populations of riverine species including fish recognise the proximity and Otter and ancient woodland species. Note: species of the Newtown St within 100m - Salmon, species 100 - 500m - Otter. Boswells Woods SAC Habitats within 100m - Tweed (TSAC) and Borders Woods and the River Tweed (SAC). SAC and incorporate good design principles in the planning process. NSBESNewtown St 362 NSBES General risk due to species, habitats, connectivity and area neutral Appropriate SNH commented that all Boswells is major. Specific habitat reference to substantial indirect Assessment not development must Expansion effects on ancient and semi natural woodland, including the required recognise the proximity Safeguarding Newtown St Boswells Woods SSSI. Specific connectivity of the Newtown St (South & West) references to: contiguous habitats of woodland; habitat Boswells Woods SAC corridors of all burns, they form important woodland and and the River Tweed riverine corridors (West Burn, Holmes Burn, Newtown SAC and incorporate Burn, Bowden Burn and Sprouston Burn) and contiguous good design principles in populations of riverine species including fish and Otter and the planning process. ancient woodland species. Note Salmon & Otter 100 - 500 metres from the site. Habitats of River Tweed SAC and Borders Woods SAC 100-500 metres from the site. Policy: H3

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 13 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect zRO21Depot 58 RO No risk assessment but there is an assessment for the neutral Appropriate SNH commented that all Newtown St Boswells safeguarding area nearby and similar Assessment not development must issues apply. General risk to species and habitat is required recognise the proximity moderate and connectivity is major. Specific habitat of the Newtown St references: Potentially substantial indirect effects on Boswells Woods SAC Newtown St Boswells Woods SSSI. This risk becomes and the River Tweed major if any of the SSSI is encroached on. There is a risk of SAC and incorporate contamination of burns leading to pollution of the Tweed good design principles in (TSAC). Specific connectivity references to: habitat the planning process. corridor of all burns adjacent to the development blocks, SNH commented that they form important riverine and woodland corridors potential contamination (Holmes Burn, Newtown Burn, Bowden Burn and/ or on the site would have to Sprouston Burn) and contiguous populations of riverine be investigated. species including fish and Otter and ancient woodland species. Note: species within 100m - Salmon, species 100 - 500m - Otter. Habitats within 100m - Tweed (TSAC) and Borders Woods (SAC). zRO20Garage 57 RO No risk assessment but there is an assessment for the neutral Appropriate Site Developed. SNH Newtown St Boswells safeguarding area nearby and similar Assessment not commented that all issues apply. General risk to species and habitat is required development must moderate and connectivity is major. Specific habitat recognise the proximity references: Potentially substantial indirect effects on of the Newtown St Newtown St Boswells Woods SSSI. This risk becomes Boswells Woods SAC major if any of the SSSI is encroached on. There is a risk of and the River Tweed contamination of burns leading to pollution of the Tweed SAC and incorporate (TSAC). Specific connectivity references to: habitat good design principles in corridor of all burns adjacent to the development blocks, the planning process. they form important riverine and woodland corridors (Holmes Burn, Newtown Burn, Bowden Burn and/ or Sprouston Burn) and contiguous populations of riverine species including fish and Otter and ancient woodland species. Note: species within 100m - Salmon, species 100 - 500m - Otter. Habitats within 100m - Tweed (TSAC) and Borders Woods (SAC).

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 14 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect zRO23Mills 60 RO No risk assessment but there is an assessment for the neutral Appropriate SNH commented that all Newtown St Boswells safeguarding area nearby and similar Assessment not development must issues apply. General risk to species and habitat is required recognise the proximity moderate and connectivity is major. Specific habitat of the Newtown St references: Potentially substantial indirect effects on Boswells Woods SAC Newtown St Boswells Woods SSSI. This risk becomes and the River Tweed major if any of the SSSI is encroached on. There is a risk of SAC and incorporate contamination of burns leading to pollution of the Tweed good design principles in (TSAC). Specific connectivity references to: habitat the planning process. corridor of all burns adjacent to the development blocks, they form important riverine and woodland corridors (Holmes Burn, Newtown Burn, Bowden Burn and/ or Sprouston Burn) and contiguous populations of riverine species including fish and Otter and ancient woodland species. Note: species within 100m - Salmon, species 100 - 500m - Otter. Habitats within 100m - Tweed (TSAC) and Borders Woods (SAC). ENT8BSprouston Cottages 54 H Risk due to species and connectivity is moderate. Specific neutral Appropriate Site Developed. SNH species comment: extensive ancient woodland flora in Assessment not commented that all Newtown St Boswells Woods SSSI. Specific habitat required development must comment: contiguous habitats of woodland, habitat recognise the proximity corridor of burn and riverine woodland and contiguous of the Newtown St populations of woodland and riverine species. Note site is Boswells Woods SAC within 100 to 500m of the Borders Woods SAC. and the River Tweed SAC and incorporate good design principles in the planning process.

Settlement: Peebles Policy: ALL ALLPeebles 332 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Policy: H3

Abbreviations: SAC=Special Area of Conservation, SPA=Special Protection Area, TSAC=River Tweed Special Area of Conservation Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected] 07 March 2008 Page 15 of 19 Site Name Ref Type Possible Link Likely Action Notes Sig. Effect zRO7March Street/ 89 RO There was a general risk to species and habitats that was neutral Appropriate George Street moderate. Specific species comment: Also likely to be Assessment not Salmon & Lamprey populations. Specific habitat comment: required the Eddleston Water (TSAC) forms the boundary of the site. Note - Otter within 100m. TP200Violet Bank 382 H No risk assessment for this site but site STP26 was assessed neutral Appropriate and covers part of site TP200. Similar comments are likely Assessment not to apply to site TP200. There was a general risk to habitats required and connectivity that was moderate on site STP26. Specific habitat comment on site SPT26: the Eddleston Water (TSAC) forms the Eastern boundary. Specific connectivity comments on site SPT26: contiguous habitats of river, habitat corridor - riverine on west bank of Eddleston Water and contiguous populations of riverine species such as Otter and fish. Note - Samon, Lamprey & Otter from 100 to 500m away. zSS4Violet Land 248 SS No risk assessment for this site but site STP26 was assessed neutral Appropriate and covers part of site zSS4 & other land to the north of it. Assessment not Similar comments are likely to apply to site zSS4. There required was a general risk to habitats and connectivity that was moderate on site STP26. Specific habitat comment on site SPT26: the Eddleston Water (TSAC) forms the Eastern boundary. Specific connectivity comments on site SPT26: contiguous habitats of river, habitat corridor - riverine on west bank of Eddleston Water and contiguous populations of riverine species such as Otter and fish. Note - Samon, Lamprey & Otter from 100 to 500m away.

Settlement: Selkirk Policy: ALL ALLSelkirk 340 ALL Settlement adjacent to TSAC. neutral Appropriate Assessment not required Policy: H3

Settlement: Sprouston Policy: H3 RSP4DDean Road 384 H Site is within 100 to 500metres of the Tweed (TSAC). neutral Appropriate Assessment not required

Settlement: St Abbs Policy: ALL ALLSt Abbs 356 ALL The settlement is adjacent to the Berwickshire and North neutral Appropriate Northumberland Coast SAC and St Abbs Head to Fast Assessment not Castle SAC/SPA is 100 to 500m away. required

Settlement: Tweedbank Policy: ALL

Settlement: Walkerburn Policy: H3 TW1BCaberston Farmland 85 H General risk to species is moderate. Note - Salmon within neutral Appropriate 100m, Otter and Tweed (TSAC) 100 - 500m. Assessment not required

Settlement: Waverley Policy: INF1 WaverleyWaverley Line 360 TS The indicative route of the railway line from Edinburgh to neutral Appropriate A full Appropriate Tweedbank crosses and lies adjacent to the Gala Water and Assessment not Assessment, in Tweed (TSAC). required accordance with EC directives, was approved by the Scottish Parliament for the Waverley Railway Project from Edinburgh to Tweedbank. The Waverley Railway (Scotland) Act 2006 gives the Council powers to construct this section of the railway. A copy of this assessment is available on request.

Settlement: Yarrowford Policy: H3 EY5BMinchmoor Road 22 H Site is within 100 metres of the Yarrow Water (TSAC). neutral Appropriate East Assessment not required EY4BMinchmoor Road 313 H Site is within 100 metres of the Yarrow Water (TSAC). neutral Appropriate West Assessment not required

Settlement: Yetholm Policy: H3 RY4BMorebattle Road 385 H Site is within 100 to 500metres of the Bowmont Water neutral Appropriate (TSAC). Assessment not required

Site Name Settlement: Ancrum Policy: H3 RA1B South Myrescroft

Settlement: Ayton Policy: H3 AY1A Beanburn

Settlement: Burnmouth Policy: H3 BBU3B Lyall Terrace

Settlement: Cardrona Policy: H3 TCO7B CALA site Adjacent to B7062 TCO5B Cardrona Mains

Settlement: Chesters Policy: H3 RC2B Roundabout Farm

Settlement: Chirnside Policy: H3 BCH6B Cheviot Avenue BCH7B Erskine Road zEL1 Southfield

Settlement: Clovenfords Policy: H3 EC8B Adjacent to Woodburnside House zSS200 Clovenfords School Site EC13B Meigle Site

Settlement: Cockburnspath Policy: H3

Abbrevations: H3= Policy H3, Land Use Allocations; BE11=Policy BE11, H1A Land Safeguarding Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected]

07 March 2008 Page 1 of 8 Site Name BC010B Burnwood BCO4B Dunglass Park

Settlement: Coldingham Policy: H3 BCL2B Bogangreen BCL12B The Firs

Settlement: Coldstream Policy: H3 zRO17 Duns Road BCS3A Guards Road zRO18 Lees Farm Mill zRO19 Trafalgar House BCS5B West Paddock

Settlement: Darnick Policy: H3 EM9B Chiefswood Rd

Settlement: Denholm Policy: H3 RD4B Denholm Hall Farm RD3B Jedward Terrace

Settlement: Duns Policy: H3 BD5A Berrywell BD12B Berrywell East zRO15 Berwickshire High School BD20B Bridgend II BD200 Hardens Road zSS6 High School Site at Langtongate zEL8 Peelrig Farm BD4B Todlaw Road

Settlement: Earlston Policy: H3 EEA12B Earlston Glebe EEA15A Thistle Cottage

Settlement: Eccles

07 March 2008 Page 2 of 8 Site Name Policy: H3 BEC4B Cherryburn

Settlement: Eckford Policy: H3 REC2B Hillview

Settlement: Eddleston Policy: H3 TE6B Burnside

Settlement: Ednam Policy: H3 RE1B West Mill

Settlement: Eyemouth Policy: H3 BEY2B Acredale Farm Cottages BEY15B Gunsgreenhill zEL6 Hawks' Ness

Settlement: Galashiels Policy: H3 EGL43 Balmoral Avenue EGL39 Balnakeil Phase 2 EGL17B Buckholm Corner EGL13B Crotchetknowe EGL42 Forest Hill zRS2 Galashiels Railway Station EGL20B Grange zRO24 Heriot-Watt halls of residence zCR4 Huddersfield St/Paton St zRO25 Low Buckholmside EGL40 Manse Street EGL19B Mossilee EGL16B South Crotchetknowe

Settlement: Gattonside Policy: H3 EGT10B Orchard

Settlement: Gavinton

07 March 2008 Page 3 of 8 Site Name Policy: H3 BGA1 West Gavinton

Settlement: Gordon Policy: H3 BGO9D Large Glebe

Settlement: Greenlaw Policy: H3 zEL23 Extension to Duns Road Industrial Estate BG200 Marchmont Road

Settlement: Hawick Policy: BE11 RHA27C Gala Law Policy: H3 RHA24A Crumhaughill zEL60 Gala Law Employment Land Proposal RHA27B Gala Law/Guthrie Road HL Use Proposal RHA10A Galabrae RHA2A Heronhill RHA21B Leaburn 2 zMU1 Mixed use at Galalaw RHA25B Stirches 2 RHA12B Summerfield 1 RHA13B Summerfield 2

Settlement: Heiton Policy: H3 RHE2B Heiton Mains RHE3B Ladyrig

Settlement: Hutton Policy: H3 BHU2B Rose Bank

Settlement: Innerleithen Policy: H3 TI9B Clough Mills zRO9 High Street Gap Site TI6B Kirklands/ Willowbank TI23B Linton Bank 1

07 March 2008 Page 4 of 8 Site Name TI24B Linton Bank 2 TI3B Peebles Road zEL16 Traquair Road East

Settlement: Jedburgh Policy: H3 RJ7B Annefield RJ30B Howden Drive RJ2B Lochend RJ14B Oxnam Road zRO2 Queen Mary Bldg RJ20B Sharplaw Road zEL7 Wildcat Wood

Settlement: Kelso Policy: BE11 RKE1C Broomlands North RKE8C Wallacenick 3 Policy: H3 RKE1B Broomlands East RKE11B Broomlands West zRO11 Henderson's Bldg RKE17B Queens House RKE12B Rosebank 2 zRO3 Roxburgh Street, Bus Station zIR2 Spylaw Roundabout RKE15B Wallacenick 1 RKE15BF Wallacenick 2

Settlement: Lauder Policy: H3 ELA11B Allanbank zSS3 Allanbank School Site ELA12B Wyndhead II

Settlement: Leitholm Policy: H3 BLE2B Main Street

Settlement: Lilliesleaf Policy: H3 ELI6B Muselie Drive ELI2B St Dunstan's Abbrevations: H3= Policy H3, Land Use Allocations; BE11=Policy BE11, H1A Land Safeguarding Produced by Information Systems Team, Planning and Economic Development, Scottish Borders Council. Tel: 01835 825060 Ext 5420/5421 Email: [email protected]

07 March 2008 Page 5 of 8 Site Name

Settlement: Melrose Policy: H3 EM32B Dingleton Hospital zRP1 Dingleton Road EM4B The Croft

Settlement: Morebattle Policy: H3 RMO6B Renwick Gardens

Settlement: Nenthorn Policy: H3 RN1B Nenthorn Primary School

Settlement: Newcastleton Policy: H3 RNE2B South of Holmeshead RNE1B W. of N Hermitage Sq

Settlement: Newtown St Boswells Policy: H3 ENT14B Hawkslee ENT4B Melrose Road ENT15B Sergeants Park II

Settlement: Nisbet Policy: H3 RNI4B West Nisbet Farm

Settlement: Paxton Policy: H3 BPA4B The Orchard

Settlement: Peebles Policy: H3 zRO10 Bus Station, Innerleithen Road TP13B Glen Crescent zSS202 Neidpath School Site zEL204 South Park TP7B Whitehaugh

07 March 2008 Page 6 of 8 Site Name Settlement: Preston Policy: H3 zRO16 Preston Farm

Settlement: Reston Policy: H3 zRO13 Auction Mart BR6 Rear of Primary School zRS3 Reston BR5 West Reston

Settlement: Selkirk Policy: H3 ESE13B Comelybank ESE6B Goslawdales ESE2 Kerr’s Land ESE10B Linglie Road ESE26B Linglie Road II ESE200 Linglie Road/ Bridge Street zEL10 Riverside 1 zEL11 Riverside 2 zEL12 Riverside 3 zEL14 Riverside 5

Settlement: Sprouston Policy: H3 RSP2B Church Field RSP3B Teasel Bank

Settlement: St Boswells Policy: H3 EL19 Extension to Charlesfield

Settlement: Stichill Policy: H3 RST4B Bogle Foot

Settlement: Stow Policy: H3 ESO10B Stagehall

07 March 2008 Page 7 of 8 Site Name Settlement: Swinton Policy: H3 BSW2B Well Field

Settlement: Tweedbank Policy: H3 ETW2B Cotgreen Road ETW7 Killie Holes ETW1B Tweedbank IV

Settlement: Walkerburn Policy: H3 zRO5 Caberston Farm, Tweedvale & Tweedholm Mills

Settlement: West Linton Policy: H3 TWL200 Deanfoot Road zSS9 Deanfoot Road/Robinsland TWL9B Eildon Site TWL8B Robinsland TWL15B School Brae

Settlement: Westruther Policy: H3 BWE3 Kirkpark

Settlement: Yetholm Policy: H3 RY1B Deanfield Court

07 March 2008 Page 8 of 8

Annex 7 – Additional Information Provided to SEPA on the Cumulative Impact of the Scottish Borders Finalised Local Plan on the River Tweed SAC.

The sites of interest are Policy H3 Land Use Allocations for Redevelopment Opportunities & Housing in the Finalised Local Plan 2005 (FLP). The Geographical Information System was used to identify those FLP sites/ part of sites which are within 500m of the Tweed SAC.

However, a number of sites are already within an adopted Local Plan. The table below shows in rows 5 and 6 the area and capacity of new sites within the FLP that lie within 500m of the River Tweed SAC.

The results: Total area of sites with all 210ha or part of the site within 500m of the Tweed SAC Total capacity of sites 2790 units with all or part of the site within 500m of the Tweed SAC Area of these sites within 190ha 500m of the Tweed SAC Capacity of these sites 2410 units within 500m of the Tweed SAC Total area of new sites 150ha within 500m of the Tweed SAC Total capacity of new 1950 units sites within 500m of the Tweed SAC

In summary there is a total of 150ha of new land use allocations in the FLP that include a housing component that fall within 500m of the Tweed. The total indicative capacity on these allocations is 1950 units.

Policy BE10 Newtown St Boswells Expansion Safeguarding & Policy BE11 H1A Land Safeguarding In addition to this the FLP includes areas of policy safeguarding for housing where all or part of the site falls within 500m of the Tweed SAC. Of the Policy BE11 sites an indicative capacity of 50 units on 4ha are within 500m of the River Tweed SAC. 900 units are safeguarded under Policy BE10 and part of this area falls within 500m of the River Tweed SAC. None of these safeguarding areas were allocated in a previous Local Plan.