Wiltshire Core Strategy – Assessment of the Core Strategy Options under the Habitat Regulations

Wiltshire Council

October 2009

WSP Document Reference Footer Title

QM

Issue/revision Issue 1 Revision 1 Revision 2 Revision 3 Remarks

Date October 2009

Prepared by Sean Nicholson

Helen Davis

Julian Hatherall

Liat Wicks

Signature

Checked by Helen Davis

Signature

Authorised by Sean Nicholson

Signature

Project number 12260843

File reference HRA

WSP Environmental UK Mountbatten House Basing View Basingstoke Hampshire RG21 4HJ

Tel: +44 (0)1256 318800 Fax: +44 (0)1256 318700 http://www.wspgroup.com

Contents

1 Introduction 3

2 Preliminary 8

3 Screening The Spatial Options 16

4 Conclusions and Recommendations 28

1 Introduction

1.1 PURPOSE OF THIS REPORT 1.1.1 Wiltshire Council is in the process of developing its Core Strategy and is currently consulting on options for growth. As part of the work, consideration must be given to potential effects on sites of European importance for nature conservation. The assessment focuses on the possible effects of the plan on designated sites of international nature conservation importance within and close to Wiltshire. It is important to stress that this report represents the start of a process that will consider possible effects on such sites as the Core Strategy progresses. WSP Environmental Ltd. has been appointed by the Council to identify relevant issues and prepare this report.

1.2 BACKGROUND 1.2.1 Natura 2000 is the European Union-wide network of protected areas, recognised as ‘sites of Community importance’ under the EC Habitats Directive (Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora). These sites, which are also referred to as European sites, consist of Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and Offshore Marine Site (OMS). 1.2.2 In addition to the above, sites designated under the Ramsar Convention (known as Ramsar sites) also receive the same degree of protection under Planning Policy Statement 9 (PPS9) (ODPM, 2005) as a matter of planning policy. SPAs and SACs are known as European sites and are part of the Natura 2000 network and all three types of site are also referred to as International sites. 1.2.3 The purpose of Appropriate Assessment (AA) of land use plans is to ensure that protection of the integrity of European sites is a part of the planning process at a regional and local level. 1.2.4 AA of plans and projects is required by Articles 6(3) and 6(4) of the European Habitats Directive: “6(3) Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public” “6(4) If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. Where the site concerned hosts a priority natural habitat type and/or a priority species the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest”. 1.2.5 In the UK, the Habitats Directive is implemented through the Conservation (Natural Habitats &c) Regulations 1994 (the “Habitats Regulations”). 1.2.6 On 20 October 2005, the European Court of Justice (ECJ) 1 ruled that the UK had failed to fully transpose the provisions of Article 6(3) and (4) into the Habitats Regulations because the regulations did

„

1 Para. 51-56 in Case C-6/04, Commission of the European Communities v. United Kingdom of Great Britain and Northern Ireland, http://curia.eu.int/jurisp/cgi- Assessment of the Core Strategy Options 12260843 3 under the Habitats Regulations

not clearly require land use plans to be subject to AA. Land use plans in this respect are Regional Spatial Strategies (RSSs), Development Plan Documents (DPDs) and Supplementary Planning Documents (SPDs) 2 . DPDS and SPDS are collectively referred to as Local Development Documents (LDDs). 1.2.7 A major amendment to the Habitats Regulations was made in 2007 (Statutory Instrument 2007 No. 1843) in response to the judgment. The 2007 amendment to the Regulations now specifically apply the provisions of the Habitats Regulations to land use plans such as the Wiltshire Core Strategy, and the relevant provisions are made in the main by Regulations 85A to 85E. The essential requirement is for the plan making authority to assess the potential effects of the LDD on European Sites in Great Britain. The site affected could be in or outside England. 1.2.8 The whole process of assessing the effects of a LDD on European sites is referred to in this report as the ‘Habitats Regulations Assessment’ (HRA), to clearly distinguish the whole process from the step within it commonly referred to as the ‘Appropriate Assessment’ (AA). The AA is a specific part of the entire assessment process and to use this term generally just adds confusion to the assessment. An AA is undertaken when it cannot be stated that a plan or project (alone or in combination will not have a significant effect on a European site, and where avoidance measures cannot easily be put in place to remove that likelihood. In such instances, the next step in the process is to undertake an Appropriate Assessment of the plan or project, to determine in far greater detail the type and magnitude of impacts and to try to find suitable mitigation measures that may reduce the impact to a level at which it will no longer be significant. 1.2.9 This report has been prepared by WSP Environmental Ltd on behalf of Wiltshire Council to inform the preparation of their Core Strategy.

1.3 HABITATS REGULATIONS ASSESSMENT AND THE WILTSHIRE CORE STRATEGY 1.3.1 In April 2009, Wiltshire Council was formed from the former districts of Salisbury, Kennet, West Wiltshire and North Wiltshire, and Wiltshire County Council. The Salisbury District Core Strategy is being continued as the South Wiltshire Core Strategy; it is more advanced than the Wiltshire Core Strategy and will be incorporated into the rest of the Wiltshire Core Strategy in due course. A HRA Report has already been prepared for the South Wiltshire Core Strategy3. 1.3.2 The Core Strategy is a new plan which will provide a clear strategy for what will happen spatially throughout Wiltshire up to 2026. 1.3.3 The Wiltshire Core Strategy will be a strategic document. It will set out the broad strategy for accommodating the appropriate level of housing and employment related development across Wiltshire. It will also include policies that set out key principles for the control of development and other forms of land- use. The Plan forms part of a Local Development Framework (LDF) that will include other DPDs. These lower tier plans provide the opportunity to further explore potential effects on European Sites and to put forward additional avoidance and mitigation measures. 1.3.4 The majority of development associated with the LDF will also require planning permission and project level AAs will also need to be undertaken where relevant. HRA is also required for other related processes such as licensing arrangements for the abstraction of water (for which the Environment Agency has responsibility). The position of the Core Strategy within the hierarchy of plans in the District is therefore important because it has a bearing on the level of risk associated with any potential effects that are

„ bin/form.pl?lang=en&Submit=Submit&alldocs=alldocs&docj=docj&docop=docop&docor=docor&docjo=docjo&numaff=C- 6%2F04&datefs=&datefe=&nomusuel=&domaine=&mots=&resmax=100

2 Letter from Lisette Simcock (ODPM) to chief planning officers (28 February 2006) “The Application of Appropriate Assessment under Article 6(3) and (4) of the Habitats Directive 92/43/EEC to Development Plans in the Transitional period between now and when the Amending Regulations come into force.” 3 South Wiltshire Core Strategy, Proposed Submission Draft, July 2009, HRA Report, Nicholas Pearson Associates, July 2001 Assessment of the Core Strategy Options 12260843 4 under the Habitats Regulations

identified. The Commission of the European Communities communication on the precautionary principle4 recognises risk as a key factor in implementing the precautionary principle. 1.3.5 Notwithstanding the safeguards that exist at the project level, it will be important to demonstrate that th e Core Strategy provides sufficient safeguards/measures to avoid potential issues down the line. This is considered essential to demonstrate that the Core Strategy is sound.

1.4 METHODOLOGY 1.4.1 The HRA has commenced whilst the Core Strategy is at a formative stage. This will enable the HRA to truly influence the content of the Core Strategy. The HRA process is an iterative one and this report will need to be reviewed and amended as the Core Strategy develops. 1.4.2 In devising the methodology for this work regard has been had to relevant guidance and recent practice: 5 „ Assessment of Plans and Projects Significantly Affecting Natura 2000 sites (European Union November 2001);

„ Unpublished Draft Guidance from Natural England on AA of Regional Spatial Strategies and Local Development Frameworks6; and 7 „ Guidance from the Department for Communities and Local Government (DCLG) on Appropriate Assessment of RSSs and LDDs. 1.4.3 A HRA has been undertaken of the draft RSS for the South West. Regard has been had to that work. 1.4.4 The methodology for the work has been discussed with a Steering Group comprising of repr esentatives from Natural England, the Environment Agency and Wiltshire Council. 1.4.5 Central to the guidance from Natural England is the concept of screening out those elements of the plan where it can be concluded with reasonable certainty that no significant impact on a European site will occur. In line with relevant guidance, the following tasks have been undertaken: 1. Brief description of the plan that is being considered; 2. Characteristics of the sites that might be affected; 3. Identification of spatial options that can be screened out. This included:

„ Identification of all European sites within 15km of the local authority boundary;

„ Screening out Settlements and / or European sites using a set of criteria;

„ A more detailed consideration of selected spatial options to highlight potential effects and any opportunities for avoidance measures to be incorporated in policies within the Core Strategy, lower level plans and projects.

„ 4 Communication from the Commission on the Precautionary Principle (2000), Commission of the European Communities 5 Assessment of Plans and Projects Significantly Affecting Natura 2000 sites, Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC European Union, November 2001 http://ec.europa.eu/environment/nature/nature_conservation/eu_nature_legislation/specific_articles/art6/pdf/natura_2000_assess_e n.pdf 6 Draft Guidance, The Assessment of Regional Spatial Strategies and Sub-Regional Strategies under the Provisions of the Habitats Regulations, David Tyldesley and Associates for English Nature, March 2007. 7 Planning for the Protection of European Sites: Appropriate Assessment Guidance For Regional Spatial Strategies and Local Development Documents, DCLG, August 2006 http://www.communities.gov.uk/pub/353/PlanningfortheProtectionofEuropeanSitesAppropriateAssessmentGuidanceForRegionals_i d1502353.pdf

Assessment of the Core Strategy Options 12260843 5 under the Habitats Regulations

1.4.6 The detailed consideration of selected spatial options comprised of the following tasks:

„ Identification of potential effects and the ‘pathways’ that might give rise to these effects on a settlement by settlement basis;

„ An assessment of the significance of potential effects with respect to the features (either or both primary habitats and species) for which a European site has been designated;

„ Consideration of opportunities for avoidance/mitigation measures, e.g. in the Core Strategy’s thematic policies or lower tier documents;

„ The assessment of potential effects also took account of the likelihood of such effects occurring. This is consistent with the precautionary approach;

„ Consideration of the potential for in-combination effects; and

„ Recommendations for the development of the Core Strategy. 1.4.7 Diagram 1 at the end of this section summarises the overall methodology and in particular the iterative nature of the process. 1.4.8 The purpose of this Report is to:

„ Set out the overall methodology used;

„ Provide the basis for assessing spatial options;

„ Contribute to an audit trail for HRA related work.

1.5 STRUCTURE OF THIS REPORT 1.5.1 The remainder of this report is structured as follows:

„ Section 2 reviews the context at the regional level, in terms of the assessment of effects and relevant policies in the RSS. It then outlines the scope and content of the Core Strategy and presents information on relevant European Sites;

„ Section 3 considers the approach to the assessment of the spatial options and initial findings;

„ Conclusions and recommendations follow in Section 4.

Assessment of the Core Strategy Options 12260843 6 under the Habitats Regulations

Consider 1. Site analysis and screening for Description of Agree sites to potential likely significant effects plan be considered significant with Natural effects of England and policies. identify characteristics of sites.

Place policy in screening If policy will table against not give rise appropriate to significant criterion. effects. If potential significant If potential effects identified or effects on uncertainty over potential effects European sites identified - 2 Consideration of potential Examine Identify record in effects policy in measures to matrix and greater detail. avoid proceed to significant ‘Box 2 effect consideration occurring. of potential effects’.

If there is still doubt or potential significant effects still exist

3. Appropriate assessment

4. Put forward alternatives and mitigation measures where significant effects are identified

If potential significant effects cannot be mitigated or compensated

5. Apply the ‘imperative reasons of overriding public interest (IROPI)’ test. (This stage is included here to show the whole process. it is not a standard part of the process and should be carried out only in exceptional circumstances. An assessment to consider whether compensatory measures will or will not effectively offset the damage to a site will be necessary before the plan can proceed.

Assessment of the Core Strategy Options 12260843 7 under the Habitats Regulations

2 Preliminary

2.1 INTRODUCTION 2.1.1 This section provides an overview of the key issues identified at the regional level through the HRA of the RSS for the South West. It also identifies relevant policies in the RSS. A brief description of the main elements of the Core Strategy and key information for relevant European sites is then provided.

2.2 IDENTIFYING SITES FOR ASSESSMENT 2.2.1 An initial search area of 15km from the boundary of the local authority was established, within which Natura 2000 and Ramsar sites were identified. The initial search area is shown on Figure 1 at Appendix A. This essentially forms the long list of sites that need to be considered. The work has focussed on settlements out with the South Wiltshire Core Strategy area and the Swindon area but takes into account the potential effects associated with development in these areas because these could contribute to in- combination effects. The Wiltshire Core Strategy also includes proposals for development on the edge of Swindon. Figure 1 also shows the boundary of the South Wiltshire Core Strategy. 2.2.2 The preliminary list of sites is as follows: SPA entirely or partly in Wiltshire SPA within 15km of Wiltshire

„ Porton Down SPA; and „ New Forest SPA;

„ Salisbury Plain SPA. „ Dorset Heathlands SPA;

„ Solent & Southampton Water SPA; and

„ Avon Valley SPA. SAC entirely or partly in Wiltshire SAC within 15km of Wiltshire

„ Bath & Bradford on Avon Bats „ Avon Valley SAC SAC; „ Costswolds Beechwood SAC „ Chilmark Quarries SAC; „ Dorset Heathlands SAC; „ Great Yews SAC; „ Emor Bog SAC „ Kennet & Lambourn Floodplain „ Fontmell and Melbury Downs SAC; SAC; „ New Forest SAC; „ Hackpen Hill SAC; „ North Meadow and Clattinger „ Kennet Valley Alderwoods SAC; Farm SAC; „ Mells Valley SAC; „ Pewsey Downs SAC; „ Mendip Woodlands SAC; „ Prescombe Down SAC; „ Mottisfont Bats SAC; „ River Avon SAC; and „ River Lambourn SAC; „ Salisbury Plain SAC. „ Rodborough Common and

„ Solent Maritime SAC.

Assessment of the Core Strategy Options 12260843 8 under the Habitats Regulations

2.2.3 Not all of these sites will need to be looked at in detail because potential effects are only likely to occur closer than 15km in some cases. Appendix B sets out the results of an exercise that considered the potential for development associated with the optioneering exercise to harm the sites. A range of factors were considered and in undertaking the exercise regard was had to the assessment work undertaken at the regional level (discussed below), other HRA work undertaken in Wiltshire and preliminary work undertaken by WSP.

2.3 KEY ISSUES IDENTIFIED IN THE HRA OF THE REGIONAL SPATIAL STRATEGY RELATING TO THE IDENTIFIED SITES 2.3.1 This section summarises the key issues relating to the long list of sites which are identified in the HRA of the RSS. These are summarised in the tables below. Note that this provides a guide to the issues that need to be covered and the sites they relate to but it does not automatically mean that development in Wiltshire will contribute to these issues, e.g. a site may be vulnerable to increased recreational pressure within the region but be considered too far from the settlemen ts identified for potential growth in Wiltshire for them to contribute to that problem. Table 2.1: Physical Damage due to H ousing Provisi on and Recreation

Site In or Partly In Impact Impact Impact Wiltshire? Likely? Uncerta in? Unlikely? Bath & Bradford on Avon Bats SAC Yes 9 Dorset Heaths SAC, Dorset Heathlan ds No 9 SPA & Ramsar Site Fontmell & Melbury Downs SAC No 9 Great Yews SAC Yes 9 Mells Valley SAC No 9 Mendip Woodlands SAC No 9 Pewsey Downs SAC Yes 9 Solent Maritime SAC, Solent & No Southampton Water SPA & Ramsar 9 Site

Table 2.2 Physical Damage d ue to Transport In frastructure Develop ment and Recreation

Site In or Partly I n Impact Impact Impact Wiltshire? Likely? Uncertain? Unlikely?

Avon Valley SPA & Ramsar No 9 Site Chilmark Quarries SAC Yes 9

Fontmell & Melbury Downs No 9 SAC Hackpen Hill SAC No 9 Kennet and Lambourn Yes 9

Assessment of the Core Strategy Options 12260843 9 under the Habitats Regulations

Floodplain SAC

Kennet Valley Alderwoods No 9 SAC Mells Valley SAC No 9 Mottisfont Bats SAC No 9

North Meadow and Clattinger Yes 9 Farm SAC Porton Down SPA Yes 9 Prescombe Down SAC Yes 9 River Avon SAC Yes 9 River Lambourn SAC No 9 Salisbury Plain SAC & SPA Yes 9

The New Forest SAC, SPA Yes - SAC 9 and Ramsar No – SPA/ Ramsar

Table 2.3: Water Abstraction

Site In or Partly In Impact Impact Impact Wiltshire? Likely? Uncertain? Unlikely? Avon Valley SPA & Ramsar Site No 9

Dorset Heaths SAC, Dorset No 9 Heathlands SPA & Ramsar Site

Kennet and Lambourn Floodplain Yes 9 SAC

North Meadow and Clattinger Farm Yes 9 SAC River Avon SAC Yes 9 Salisbury Plain SAC & SPA Yes 9 The New Forest SAC, SPA and Yes - SAC Ramsar No – SPA/ 9 Ramsar

Table 2.4: Water Pollution

Site In or Partly In Impact Impact Impact Wiltshire? Likely? Uncertain? Unlikely? Avon Valley SPA & Ramsar Site No 9

Dorset Heaths SAC, Dorset Heathlands No 9 SPA & Ramsar Site

Assessment of the Core Strategy Options 12260843 10 under the Habitats Regulations

River Avon SAC Yes 9 Solent Maritime SAC, Solent & No Southampton Water SPA & Ramsar 9 Site

Table 2.5: Air Pollution

Site In or Partly In Impact Impact Impact Wiltshire? Likely? Uncertain? Unlikely?

Avon Valley SPA & Ramsar No 9 Site

Bath & Bradford on Avon Yes 9 Bats SAC Dorset Heaths SAC, Dorset No Heathlands SPA & Ramsar 9 Site

Fontmell & Melbury Downs No 9 SAC

North Meadow and Yes 9 Clattinger Farm SAC Porton Down SPA Yes River Avon SAC Yes 9 River Lambourn SAC No 9 Salisbury Plain SAC & SPA Ye s 9 Solent Maritime S A C, Solent No & Southampton Water SPA 9 & Ramsar Site The New Forest SAC, SPA Yes - SAC and Ramsar No – SPA/ 9 Ramsar No – SPA/ Ramsar

Table 2.6: Disturbance from Plane Flightpaths

Site In or Partly In Impact Impact Impact Wiltshire? Likely? Uncertain? Unlikely?

Avon Valley SPA & No 9 Ramsar Site

Assessment of the Core Strategy Options 12260843 11 under the Habitats Regulations

IMPLICATIONS OF THE WORK UNDERTAKEN AT THE REGIONAL LEVEL 2.3.2 Based on the work undertaken at the regional level and other local assessments we know that the key issues relate to:

„ Potential for increased recreational pressure;

„ Potential physical damage due to housing provision/transport infrastructure development

„ Hydrogeology/hydrology - Potential changes to the hydrological regime of catchment areas; - Potential for pollution of surface or ground water; - Potential for nutrient enrichment of aquatic systems; - Issues around increased water abstraction;

„ Potential for effects on European sites associated with air pollution

„ Potential for in-combination effects associated with developments and potential mineral extraction

2.4 SHORTLISTED SITES AND KEY ISSUES BY SETTLEMENT 2.4.1 A key purpose of this initial HRA work is to help inform the scale and location of development on a settlement by settlement basis and to help identify avoidance and mitigation measures that can be built into the Core Strategy. 2.4.2 The work undertaken at the Regional level was used to help inform the next stage of the work. This involved considering each of the European sites, potential effects and the extent to which development at each settlement might contribute to each effect. Specific criteria were developed and used to assist with the work, for example it is accepted that 5km is the maximum distance that people will travel for recreational purposes associated with most green spaces. Larger site like Salisbury Plain have a larger catchment and there is evidence that people will travel up to 15km. So two questions were posed in relation to each of the settlements identified for growth; firstly is the site within 5km of a European site and secondly is it within 15km. Similar questions were asked for other issues. Appendix B indicates the questions that were used for other issues and those sites that were shortlisted because, using the criteria identified, there was considered to be potential for significant effects on a European site that needed further consideration. The issues and sites they relate to are considered in more detail in Section 3 of this report. 2.4.3 Section 3 of this report looks at these issues in more detail but the report first looks at the wider policy context because this also helps shape the approach to the assessment of issues.

2.5 THE REGIONAL POLICY CONTEXT 2.5.1 The draft Regional Spatial Strategy (RSS) was subject to independent testing at an Examination in Public (EiP) between 17 April 2007 and 6 July 2007. The Panel's report was published on 10 January 2008. 2.5.2 The Secretary of State's proposed changes to the draft RSS were published in July 2008. 2.5.3 The Draft RSS contains a number of policies that are relevant to the assessment of potential effects on the Natura 2000 Network. These are relevant in two respects:

„ They provide guidance on how authorities should approach the consideration of potential effects;

„ They provide guidance on the direction that policies in Core Strategies should take to issues that may be relevant to the consideration of potential effects. 2.5.4 Key policies are summarised below (note these are taken from the Secretary of State’s proposed changes and will need to be updated as this HRA progresses.

Assessment of the Core Strategy Options 12260843 12 under the Habitats Regulations

2.5.5 The supporting text to the revised RSS (Section 4) notes the need to protect the ecological integrity of sites, stating: “The integrity of Natura 2000 and Ramsar sites (collectively referred to as N2K sites) should be protected. New development in the region will be facilitated by policy measures that secure effective avoidance, minimisation and mitigation of the potential adverse effects on the ecological integrity of such designated sites. Policy ENV1 identifies three locations that are considered to be particularly vulnerable – the Dorset Heaths, the River Avon (Hampshire) and the Severn Estuary. The Habitat Regulations Assessment also identifies the following sites as being vulnerable where further protection measures may be necessary depending on the impacts of new development proposed through LDDs or planning applications:“

„ River Avon SAC and Avon Valley SPA and Ramsar (South East Dorset and Salisbury).

„ Chesil & The Fleet SAC, Chesil Beach & The Fleet SPA, Ramsar (South East Dorset, Dorchester and Weymouth).

„ Somerset Levels & Moors SPA and Ramsar (Taunton and Yeovil).

„ Hestercombe House SAC (Taunton).

„ Mendip Limestone Grassland SAC (Weston-super-Mare).

„ North Somerset & Mendip Bats SAC (Bristol).

„ Bath & Bradford-on-Avon SAC (Bath).

„ South Hams SAC (Newton Abbott and Torbay).

„ Wye Valley & Forest of Dean Bat Sites SAC and Wye Valley Woodlands SAC (Forest of Dean Towns). “ 2.5.6 Policy ENV 1 ‘Protecting and Enhancing the Region’s Natural and Historic Environment’ is a key policy, it states: “The quality, character, diversity and local distinctiveness of the natural and historic environment in the South West will be protected and enhanced, and developments which support their positive management will be encouraged. Where development and changes in land use are planned which would affect these assets, Local Authorities will first seek to avoid loss of or damage to the assets, then mitigate any unavoidable damage, and compensate for loss or damage through offsetting actions. Priority will be given to preserving and enhancing sites of international or national landscape, nature conservation, geological, archaeological or historic importance. Tools such as characterisation and surveys will be used to enhance local sites, features and distinctiveness through development, including the setting of settlements and buildings within the landscape and contributing to the regeneration and restoration of the area. Any development that could have any negative effect on the integrity and conservation objectives of a N2K site would not be in accordance with the development plan. Further assessment of the implications for N2K sites is required at subsequent levels including LDDs, and any development that would be likely to have a significant effect on a N2K site, either alone or in combination, will be subject to assessment at the project application stage. Three locations are considered to be particularly vulnerable and require special protection - Dorset Heath, River Avon (Hampshire) and Severn Estuary. Paragraph 4.1.16 identifies a number of other sites where further protection may be necessary depending on the impacts of new development proposed through LDDs or planning applications.” 2.5.7 Policy EN4 ‘Nature Conservation’, although not restricted to European sites is also relevant, it states: “The distinctive habitats and species of the South West will be maintained and enhanced in line with national targets and the South West Regional Biodiversity Action Plan. Local Authorities should use the Nature Map to help map local opportunities for biodiversity enhancement in LDDs, taking into account the local distribution of habitats and species, and protecting these sites and features from harmful development. Priority will be given to meeting targets for maintenance, restoration and recreation of Assessment of the Core Strategy Options 12260843 13 under the Habitats Regulations

priority habitats and species set out in Appendix 1, focusing on the Nature Map areas identified in Map 7.3. Proposals which provide opportunities for the beneficial management of these areas and habitats and species generally, should be supported, including linking habitats to create more functional units which are more resilient to climate change”. 2.6 THE WILTSHIRE CORE STRATEGY 2.6.1 The main elements of the emerging Core Strategy are outlined below, including the following matters:

„ Role of the Core Strategy;

„ Emerging Spatial Strategy and Principal locations for growth; and

„ Housing and Employment land provision.

ROLE OF THE CORE STRATEGY 2.6.2 The Core Strategy is an overarching spatial document which will indicate key sites and strategic locations for new development, along with criteria to guide new development to the most appropriate locations. 2.6.3 The Core Strategy is part of the Local Development Framework for Wiltshire, which will guide and enable development, secure regeneration, reduce deprivation and help improve Wiltshire’s environmen t and community facilities over the next 20 years. This document sets out a spatial vision and strategy and looks at the issues and options in the district as well as some preferred options to help achieve the spatial strategy. 2.6.4 The Core Strategy will help deliver the Wiltshire Community Strategy (and emerging Sustainable Community Strategy) and aims to reflect the views of the local community. 2.6.5 In addition to this HRA, the Core Strategy will be informed by a Sustainability Appraisal, evidence from various planning studies, Government planning policy statements, and the RSS.

PRINCIPAL LOCATIONS FOR GROWTH 2.6.6 The principal locations for growth that are currently being examined are the Strategically Significant Towns of Chippenham and Trowbridge and the following market towns:

„ Bradford on Avon „ Calne

„ Corsham „ Devizes

„ Ludgershall „ Malmesbury

„ Marlborough „ Melksham

„ Tidworth „ Warminster

„ Westbury „ Wootton Bassett

„ Swindon West

HOUSING AND EMPLOYMENT LAND PROVISION 2.6.7 The table over the page summarises the scale and location of growth that is being consulted on. It takes into account completions between 2006-2009 and seeks to allocate housing to meet RSS requirements once outstanding planning permissions and allocations have been considered.

Assessment of the Core Strategy Options 12260843 14 under the Habitats Regulations

Settlements Permitted (inc. S106) Outstanding Growth for inclusion in and expected to be allocations expected to Core Strategy complete be complete East Devizes 559 62 700 Tidworth/Ludgershall 43 280 1,200 Marlborough 237 0 250 Elsewhere * 164 60 500 North Chippenham 439 316 3,650 West of Swindon 0 0 2,800 Calne 189 28 500 Corsham 307 40 100 Malmesbury 215 0 200 Wootton Bassett 549 99 150 Elsewhere * 357 26 250 West Trowbridge 1,964 159 2,650 Melk sham 1,174 0 400 Warminster 392 120 900 Westbury 229 346 300 Bradford on Avon 247 0 150 Elsewhere * 204 0 150 *: This relates to all commitments outside the Strategically Significant and Market Towns within the Community Areas which approximate to the former district areas.

2.7 KEY POLICIES RELATING TO THE NATURAL ENVIRONMENT 2.7.1 It is anticipated that the draft Core Strategy will contain policies relating to:

„ Nature conservation and biodiversity, relating to the protection and enhancement of designated sites;

„ Flood Issues – adopting a risk based approach to the allocation of land for development;

„ Water environment – acknowledging issues around the treatment, use and acquisition of water; and

„ Recreation, Leisure, Green Links and Open Space - concerned with the protection and creation of new green links;

„ Transport – infrastructure provision, reducing the need to travel and encouraging modal shift;

„ Climate change – looking at the role of development in reducing the contribution to climate change and adapting to the change that will inevitably occur. 2.7.2 Such policies will help to protect and enhance European sites and are relevant to the assessment of potential effects. Clearly, any conclusions of this report that rely on such policies are contingent on the policies being incorporated in the Core Strategy.

Assessment of the Core Strategy Options 12260843 15 under the Habitats Regulations

3 Screening The Spatial Options

3.1 INTRODUCTION 3.1.1 In line with emerging advice, the spatial options have been screened against the issues identified in the RSS in order to identify whether or not options will have a potentially significant effect on a European site, either individually or in combination.

3.2 APPROACH 3.2.1 Potential effects are considered on an issue basis, essentially we have sought to identify an impact pathway between spatial options and relevant European sites. 3.2.2 As noted in Section 2 of this report the following issues were considered and reflect the issues identified in the RSS. They are considered to be issues that additional housing, employment and supporting infrastructure could, in principle, contribute to:

„ Potential for increased recreational pressure;

„ Hydrogeology/hydrology - Potential changes to the hydrological regime of catchment areas; - Potential for pollution of surface or ground water; - Potential for nutrient enrichment of aquatic systems; - Issues around increased water abstraction;

„ Potential for effects on European sites associated with air pollution

„ Potential physical damage due to housing provision/transport infrastructure development

„ Potential for in-combination effects associated with developments and potential mineral extraction 3.2.3 Examining each of these factors on a settlement basis was considered the best way of identifying issues because decisions are being made about the location of development on a settlement basis. 3.2.4 The concept of risk is also seen as central to the assessment given the strategic nature of the Core Strategy and the fact that it will not itself lead to development, as well as other factors, such as the opportunity to introduce avoidance measures in other parts of the LDF and through the planning for and granting of planning permission for developments. 3.2.5 The results of the work are summarised in Appendix B and are discussed below. Each of the issues identified above is considered in turn with a common format adopted:

„ What is the issue?

„ Which settlements does it relate to?

„ What are the implications for the Core Strategy

„ What are the implications for the HRA

3.3 RECREATIONAL PRESSURE

RECREATIONAL PRESSURE - WHAT IS THE ISSUE? 3.3.1 The housing element of the Core Strategy will introduce new residents to the area. A proportion of the total number of new residents will pursue recreational activity on nearby areas of green open space. These areas could possibly include designated areas such as Natura 2000 or Ramsar sites, which may contain habitats or species that may be sensitive to disturbance from increases in recreational pressure, e.g. populations of breeding birds.

Assessment of the Core Strategy Options 12260843 16 under the Habitats Regulations

3.3.2 The distance that people are prepared to travel for recreational purposes is a key consideration. 3.3.3 Research undertaken on behalf of Natural England (Liley et al, 2005)8 in respect of the Thames Basin Heaths has indicated that most recreational users, and in particular those who are most likely to visit the site most often, will live within 5km of the site. This distance also encompassed most dog walkers, who are considered more likely to have an impact upon receptors such as populations of breeding birds compared to other recreational users (Natural England, 2006)9. 3.3.4 For the purposes of this work it is therefore considered that 5km is likely to represent an appropriate distance to use for estimating likely increases in recreational pressure on most sites as a result of residents of new residential development seeking to pursue recreational activity. 3.3.5 Salisbury Plain is an exception to this. Specific research undertaken at the site to determine where visitors originated from indicated that over 80% of visitors travelled up to 15km to reach the site10. This is consistent with research elsewhere in England that showed that where larger sites with a high visitor appeal are concerned, people will travel up to 20km to reach a site. 3.3.6 Potential for increased recreational pressure is of particular relevance to Salisbury Plain SPA. It is designated for its breeding population of Stone Curlew as well as its over-wintering population of Hen Harrier. Studies have highlighted a clear link between breeding success and disturbance by people and dogs, to this species. 3.3.7 The HRA for the South Wiltshire Core Strategy highlights that public access to the SPA/SAC is currently only a potential concern in the eastern part of the SPA/SAC (to the north of Bulford, west of Tidworth and east of Netheravon)11. There is normally no public access to the majority of the western part of Salisbury Plain SPA/SAC which comprises the Imber Live Firing Range (and no Stone Curlew nesting sites have been identified by the RSPB’s monitoring programme in the area with public access east of the Tilshead-Chitterne road), or to the Porton Down part of the SAC, and very little public access (along two routes only outside live firing) to the central part of the SAC through the Larkhill / Westdown Artillery Ranges. In the eastern part, access is limited to Bulford Ranges Danger Area during live firing, but outside this is unrestricted on foot. 3.3.8 The means of managing public access to the eastern part of the SPA/SAC will be reviewed within the next 5 years as part of the MOD Byelaw Review of public access at Salisbury Plain in relation to the operational requirements of the Salisbury Plain Training Area, but such means have not yet been defined and cannot be relied upon. 3.3.9 In terms of mitigation, the main type of measure recommended by Natural England and reflected in the HRAs of the current draft South West RSS and the adopted South East RSS, is the provision of Suitable Alternative Natural Greenspace for residential developments and/or improvements to existing sites to increase their visitor capacity and manage/avoid potential negative effects. 3.3.10 Policy R2 of the emerging South Wiltshire Core Strategy requires new residential development to make provision for recreational open space (facilities for communal outdoor sport and children’s play) in accordance with a standard of 2.43 hectares per 1000 population, and additional open space (including landscaped areas, public gardens and roadside verges) will be sought as appropriate. Draft policy 26 now includes a clear requirement for developers to provide for any suitable alternative natural greenspace

„ 8 Liley D, Jackson D, and Underhill-Day J (2005) Visitor Access Patterns on the Thames Basin Heaths. English Nature Research Report 682, Peterborough.

9 Natural England (2006) Thames Basin Heaths (TBH) Special Protection Area (SPA) position on sheltered accommodation. A letter from Natural England to local planning authorities setting out their position in relation to different use classes for planning applications.

10 10 Liley, D. et. al. (2007). Access patterns on Salisbury Plain. Unpublished report for Enviros Ltd. Footprint Ecology, Wareham, Dorset.

11 South Wiltshire Core Strategy Proposed Submission Draft, Final HRA Report, Appendix 11, Nicholas Pearson Associates, July 2009. Assessment of the Core Strategy Options 12260843 17 under the Habitats Regulations

provision, access or quality improvements as well as providing linkages between greenspaces in order to offset increased public use of the New Forest and Salisbury Plain European sites, where appropriate.

RECREATIONAL PRESSURE - WHICH SETTLEMENTS DOES IT RELATE TO? 3.3.11 A 5km radius was drawn around each of the settlements included in the options work. Those instances where a European site was within 5km were recorded. A 15 km radius was used to indicate the distance to Salisbury Plain. The results are shown in Appendix B. 3.3.12 The settlements that could create additional recreational pressure on Salisbury Plain are as follows

„ Trowbridge „ Calne

„ Corsham „ Devizes

„ Tidworth/Ludgershall „ Marlborough

„ Melksham „ Warminster

„ Westbury

3.3.13 In its response to the HRA for the Swindon Core Strategy and Development Management Policies, Natural England indicated that the current level of recreational activity is at or above capacity on the North Meadow, Crickdale SSSI, which is a component of the North Meadow and Clattinger Farm SAC. Current information on the SAC (JNCC) and the component SSSI14 identify that site level management is the most important factor in maintaining a favourable condition status. The HRA concluded the management of recreational activity will need to continue to be dealt with at the site level through, for example, maintenance of the public footpaths and the restriction of access to areas of the site that are being adversely affected. In addition, Bradford on Avon is within 5km of Bradford on Avon SAC.

RECREATIONAL PRESSURE - IMPLICATIONS FOR THE CORE STRATEGY 3.3.14 Wiltshire Council is seeking to establish a green grid of open spaces through the protection of existing spaces and creation of new ones. 3.3.15 Natural England promotes the following level of open space provision nationally:

„ Local communities should have access to an appropriate mix of green-spaces providing for a range of recreational needs, of at least 2 hectares of accessible natural green-space per 1,000 population. This can b e broken down by the following system: - No person should live more than 300 metres from their nearest area of natural green-space; - At least 1 hectare of Local Nature Reserve should be provided per 1,000 population; - There should be at least one accessible 20 hectare site within 2 kilometres; - There should be one accessible 100 hectares site within 5 kilometres; and - There should be one accessible 500 hectares site within 10 kilometres. 3.3.16 It is suggested that the proposed Green Grid network is assessed against Natural England’s recommended standards. 3.3.17 Natural England also provide guidance towards the characteristics that Suitable Alternative Natural Green Space (SANGS) should have (it relates to the Thames Basin Heaths and we understand there may be more than one version of the guidance). The Guidance provides some important pointers on the location of SANGS, the facilities that are needed and the type of visitor that should be catered for.

Assessment of the Core Strategy Options 12260843 18 under the Habitats Regulations

3.3.18 Key considerations include;

„ ensure provision of adequate car parking and signpost it;

„ Where large populations are close to a European site, the provision of SANGS should be attractive to visitors on foot;

„ Sites should be capable of providing routes of 2.5 to 5 kilometres, people may require longer routes;

„ Where long routes cannot be accommodated within individual SANGS it may be possible to provide them through a network of sites, provided the connecting areas are rural in nature;

„ Paths do not have to be of any particular width, and both vehicular-sized tracks and narrow Public Rights of Way (PRoW) type paths are acceptable to visitors.

„ Safety is one of the primary concerns of female visitors. Paths should be routed so that they are perceived as safe by the users, with some routes being through relatively open (visible) terrain (with no trees or scrub, or well spaced mature trees, or wide rides with vegetation back from the path), especially those routes which are 1-3 km long.

„ The routing of tracks along hill tops and ridges where there are views is valued by the majority of visitors.

„ A substantial number of visitors like to have surfaced but not tarmac paths, particularly where these blend in well with the landscape. This is not necessary for all paths but there should be some more visitor-friendly routes built into the structure of a SANGS, particularly those routes which are 1-3 km long.

„ People value the naturalness of sites and artificial infrastructure should be avoided where possible;

„ However, SANGS would be expected to have adequate car parking with good information about the site and the routes available. Some subtle waymarking would also be expected for those visitors not acquainted with the layout of the site.

„ Other infrastructure would not be expected and should generally be restricted to the vicinity of car parking areas where good information and signs of welcome should be the norm, though discretely placed benches or information boards along some routes would be acceptable.

„ Hills do not put people off visiting a site, particularly where these are associated with good views, but steep hills are not appreciated. An undulating landscape is preferred to a flat one.

„ Water features, particularly ponds and lakes, act as a focus for visitors for their visit, but are not essential. 3.3.19 It is imperative that SANGS allows for pet owners to let dogs run freely over a significant part of the walk. Access on SANGS should be largely unrestricted, with both people and their pets being able to freely roam along the majority of routes. This means that sites where freely roaming dogs will cause a nuisance or where they might be in danger (from traffic or such like) should not be considered for SANGS. 3.3.20 The guidance also provides comments on the enhancement of existing sites, including ensuring that candidate sites do not have any competing uses that would make them unsuitable as SANGS. 3.3.21 The HRA for the South Wiltshire Core Strategy concludes that more detailed documents, e.g. the Small Sites Allocations DPD could identify specific needs but there could also be a role for the Wiltshire Core Strategy to identify broad areas of search, particularly in relation to an ‘interceptor site’ for Salisbury Plain . 3.3.22 Such mitigation measures could include:

„ high specific standards of greenspace provision for all developments;

„ identification of one or more specific greenspace sites to be provided;

Assessment of the Core Strategy Options 12260843 19 under the Habitats Regulations

„ contributions to specific site habitat improvement projects or visitor access management within N2K sites as mitigation, for example: - Stone Curlew plot creation within Salisbury Plain and other suitable locations in collaboration with Defence Estates/RSPB; - habitat enhancement for Nightjar, Woodlark or Dartford Warbler within the New Forest, - or recreational access management project, through a future joint working arrangement with the NFNPA to be provided through greenspace provision and access or quality improvements; and; - Encouraging/helping Defence Estates to bring forward the review of Bye Laws relating to public access on Salisbury Plain. 3.3.23 The Green Flag Award is the national standard for parks and green spaces in England and Wales. The award scheme began in 1996 as a means of recognising and rewarding the best green spaces in the country. It was also seen as a way of encouraging others to achieve the same high environmental standards, creating a benchmark of excellence in recreational green areas. The Green Flag Award could be another way of ensuring that high quality sites are provided (see http://www.greenflagaward.org.uk/award/). 3.3.24 The Wiltshire Core Strategy needs to provide the policy hook(s) on which such provisions can be made. It will be important to define what SANGS is required and where so that developers are clear on what is required and that the HRA can point to such provisions.

RECREATIONAL PRESSURE - IMPLICATIONS FOR THE HRA 3.3.25 So should the potential for increased recreational pressure influence which settlements development is directed too? On the basis of the above analysis it is concluded that:

„ At this stage, it cannot be shown for all options that there will be no significant adverse effect on European sites due to increased recreational pressure.

„ The provision of SANGS and management measures are recognised in principle by key stakeholders as a means to avoiding such effects and a commitment to securing these will need to be incorporated in the Core Strategy;

„ The Core Strategy has a role in: - Setting the policy context for the provision of SANGS, including securing developer contributions to help deliver sites and provisions for long-term management; - Securing management measures, e.g. encouraging the review of bye-laws on Salisbury Plain to be brought forward. - Securing other mitigation/enhancement measures, e.g. to increase sites that are suitable for ground nesting birds. 3.3.26 With such measures ‘in place’ it is concluded that the options identified for development need not be discounted at this stage because of issues around recreational pressure on European sites. The issue will need to be re-considered as the evidence base for the Core Strategy and the Core Strategy itself are developed.

3.4 HYDROGEOLOGY/HYDROLOGY

HYDROGEOLOGY/HYDROLOGY- WHAT ARE THE ISSUES? 3.4.1 The potential issues are considered in turn as follows:

„ Potential changes to the hydrological regime of catchment areas;

„ Potential for pollution of surface or ground water;

„ Potential for nutrient enrichment of aquatic systems; and

„ Issues around increased water abstraction; Assessment of the Core Strategy Options 12260843 20 under the Habitats Regulations

Potential Changes to the Hydrological Regime of Catchment Areas 3.4.2 Theoretically, development has the potential to change the hydrological regime of the catchment local to individual development sites through changes in groundwater recharge and surface water runoff. The local scale of this change in the regime means that it is considered that no identified designated European site would be impacted by developments within the area either in isolation or in combination. Potential for pollution of surface or ground water 3.4.3 In common with other areas, water pollution in Wiltshire results from, amongst other things, runoff from a number of diffuse and point sources. Whilst agriculture and aquaculture are two of the main sources of diffuse pollution, run off from roads, industrial activities (although this can be a source of point- source pollution too), forestry, use of pesticides in parks and gardens and discharges from contaminated land all contribute to diffuse pollution from non-agricultural sources. The impact of diffuse pollution will vary widely with the geology, hydrology and the hydrogeology of the catchment. This will impact the water quality and ecology to varying degrees. 3.4.4 In terms of point source pollution perhaps the most critical source is discharge from Sewage Treatment Works although other sources include authorised discharges from industrial and aquaculture processes. Discussion of the impact of discharge from Warminster STW is outlined below at 3.4.9 onwards. 3.4.5 The geology of Wiltshire is such that many of the proposed development allocations are located in the west of the area. Many of these overlie the relatively impermeable Oxford Clay strata whilst many of the important Natura 2000 sites which are of interest in this current study are situated on the Major Aquifers of the Chalk and the Greensand. Groundwater and surface water in these areas interacts and it is the water in these aquifers that are vulnerable to both pollution and sensitive to changes in water level. 3.4.6 The options for growth in the north and west of the Core Strategy area (Westbury, Trowbridge, Melksham, Devizes, Calne, Chippenham, Marlborough and Malmesbury), are outside the River Avon SAC catchment and diffuse discharges resulting from development of those areas are not considered to pose a significant threat to water quality of any of the water interest Natura 2000 sites identified as part of this assessment. Warminster is however located in the headwaters of the River Avon SAC and potentially poses a higher level of risk to water quality. A policy to mitigate this risk is therefore considered to be appropriate. 3.4.7 None of the options for growth use either the Salisbury or Pewsey STW works: issues around additional point source pollution from these particular STWs can therefore be discounted. 3.4.8 There is impetus from a number of parties, including regulators and local authorities, to develop a catchment wide nutrient and flow plan to mitigate some of the impact identified as a result of both point and diffuse pollution. For some time the issues related to this pollution have been studied by a working group (currently the Environment Agency, NE and Wiltshire Council with Wessex Water to join in Sept/Oct 2009) set up to address the issue of P and other nutrients in the River Avon SAC catchment. Developments within the catchment are therefore likely to be identified as requiring developer contributions together with assistance from industry to assist with implementation of actions to reduce the impact of nutrient pollution. Potential nutrient enrichment of aquatic systems 3.4.9 Nutrients originating within the Wiltshire area, associated with new development, have the potential to change the loading in aquatic systems. The original brief for this study identified Warminster Sewage Treatment Works (STWs) and Pewsey STW as potential issues. The initial work for this report confirms that reliance on Warminster STWs is an issue. Pewsey STWs is less of an issue because the settlements identified for growth would not use it. Warminster STWs is discussed below. Discussions have been held with Natural England (NE) and the Environment Agency regarding the current issues with the Warminster STWs. 3.4.10 The EA has been going through the Review of Consents process for the Hampshire Avon SAC. This process is due to be completed by the end of March 2010. The EA have considered all of the water company sewage treatment works in the catchment. The review has identified 17 STWs in the Wiltshire area which may be contributing to water quality degradation in the River Avon SAC catchment. Of these, there were three STWs which were identified as contributing to pollution within the catchment, these being Assessment of the Core Strategy Options 12260843 21 under the Habitats Regulations

Warminster, Pewsey and to some degree Salisbury (Environment Agency, Natural England and Wessex Water pers comms., 2009). Warminster however remains the main STW of concern because of the levels of Phosphate (P) being discharged and the apparent inability of the River Avon to assimilate this for some distance downstream of the site. 3.4.11 The Water Industry and Environment Agency have identified the discharge of a 1mg/l limit P from STWs as Best Available Technology (BAT). However, targets to support the Habitats Regulations do not necessarily agree with this as the outcome of the Review of Consents process sets a target of 60µg/l P (including an allowance for instantaneous mixing), understood to have been agreed nationally between the Environment Agency and NE. It should be noted that this target is more stringent than that set by the Water Framework Directive. 3.4.12 Modelling using the 1mg/l limit has indicated that at full license uptake, discharge from Warminster STW leads to a downstream concentration of 91µg/l of P, exceeding the limit for the identified stretch of the River Avon SAC. Modelling has shown that the impact of the discharge is not assimilated fully until approximately 7 km downstream. It is also understood that this evaluation assumes that there are no P inputs upstream, a situation which is known not to be true since there are a number of potential sources of P in agriculture and water cress farming activities upstream. Furthermore it is understood that there is a fish farm and an MOD Crown exempt discharge downstream which will further contribute to the pollution. When the impacts of these activities are considered upstream and downstream the overall the impact on the P target will therefore be even greater. 3.4.13 The current discharge from the Warminster STW was recently estimated by the Environment Agency and Wessex Water to be approximately 4400m3/day, which was modelled to produce an estimated downstream P concentration of 72µg/l, which exceeds the current P target. At present both Wessex Water and the Environment Agency argue that the effect of Warminster STW does not constitute an adverse effect on SAC integrity over an estimated 4% of the total length and that the impact in the SAC as a whole is offset by the vast improvements in P levels made throughout AMP4 across other parts of the catchment. However, this has been challenged by NE. 3.4.14 Further discussion is taking place on the rational for the seemingly conflicting limits and NE is currently awaiting formal, written rationale from the Environment Agency on the rational for the 1mg/l limit whilst the Environment Agency are in turn awaiting a reply form NE on the ecological impacts of the Warminster STW at the 60µg/l P limit set in the Review of Consents. 3.4.15 As things stand NE have serious concerns about the capacity of the STW to reach the 60µg/l P limit downstream of the Warminster STW even with the current discharge, even though this is current BAT under an upgrade from AMP4. As such Wessex Water and the Environment Agency considered there to be headspace for up to 1350 dwellings under the 1mg/l BAT limit with the current licensed capacity of the works. It is understood that there is no provision for further upgrade during AMP5 (2010-2015). If necessary potential provision could be included in the management plans during AMP6 or subsequent phases (from 2015 onwards) but likely to require industry wide adoption of new BAT, something that Wessex Water does not consider to be an option at this stage. 3.4.16 The EA is of the opinion that development within the current flow headroom of the discharge consent for Warminster STW is not an issue although careful consideration should be given to development which would necessitate an increase above that which is currently consented. NE have indicated that they would not support any additional development in Warminster, even within the flow levels of the current discharge consent. 3.4.17 The difference of opinion regarding the conclusions of the Review of Consents for the Hampshire Avon, in particular for Warminster STW, is to be discussed further by the EA and NE 3.4.18 Wiltshire Council, the Environment Agency, Natural England and Wessex Water are setting up a working group to discuss these issues further. This may have a bearing on the different stances been taken with regard to future development at Warminster. 3.4.19 With regard to the potential for future development, it is the discharge specifically from Warminster STW, and not a whole catchment solution, that needs to be addressed in order to conclude that an allocation at Warminster will definitely not have an impact on the River Avon SAC. The phasing of Assessment of the Core Strategy Options 12260843 22 under the Habitats Regulations

development at Warminster towards the end of the plan period, with the allocation being contingent is unlikely to be acceptable to NE as this assumes some future, as yet unspecified technological solution. Much like the recognised objection that NE has made, in the context of other Core Strategy HRAs, to pushing the responsibility for increased water supply through increased abstraction licensing back to the Environment Agency licensing regime stage, waste water treatment without recognised solutions would breach Habitats Regs and NE would object to the Core Strategy on this basis. Issues around Water Abstraction 3.4.20 Consideration of the development in terms of available water resources is relevant to this assessment since water would need to be supplied to new properties either through a utilities provider or through a private water supplier. 3.4.21 Wiltshire Council falls within a number of Water Resource Zones and water is predominantly provided by two water companies (Wessex Water and Thames Water. The situation is summarised below for each settlement: Settlement Water Company and Water Resource Zone (WRZ) Chippenham Wessex Water North WRZ Trowbridge Wessex Water North WRZ Bradford on Avon Wessex Water North WRZ Calne Wessex Water North WRZ Corsham Wessex Water North WRZ Devizes Wessex Water North WRZ Tidworth/Ludgershall Part Thames Water Swindon and Oxford (SWOX) WRZ (Ludgershall) and Veolia Water Projects has taken over an inset appointment from Thames Water at Tidworth Malmesbury Wessex Water North WRZ Marlborough Thames Water Swindon and Oxford WRZ Melksham Wessex Water North WRZ Warminster Wessex Water North WRZ Westbury Wessex Water North WRZ Wooton Bassett Thames Water Swindon and Oxford WRZ Swindon West Thames Water Swindon and Oxford WRZ

3.4.22 Thames SWOX Zone does not appear to include all of the proposed development outlined in the Consultation document as the draft WRMP was produced before publication of the revised Draft RSS. Reference is made by Thames Water to the update of those housing allocations in the final Water Resource Management Plan (WRMP) but this is not yet available until later in the year. However the preferred option is the use of currently licensed water sources in other parts of Thames Water to meet increased demand and no additional sources are proposed at this point hence no impacts on Natura 2000 sites are anticipated.

Assessment of the Core Strategy Options 12260843 23 under the Habitats Regulations

3.4.23 With regards to the Wessex Water North WRZ; A Habitats Directive Review of Abstraction Consents has identified that abstractions will be reduced. A new 'Water Grid' is proposed to move water from areas of surplus to areas of deficit. No additional abstraction and hence Natura 2000 sites impact is anticipated. Revised draft RSS figures were used for evaluation purposes in the review of consents. The 'Water Grid' is subject to OFWAT approval as part of Wessex Water’s (WW) Management Plan for AMP 5 and 6 and as part of WRMP and subject to final approval anticipated in autumn 2009. The Grid due for completion 2017-18 and currently over abstracting supplies will not be revoked before that time, meaning that current resources remain available. The Grid is unlikely to be phased to development since it requires specific ugrades at specific locations to create the links. The Project is expected to be funded by WW finances only. Any AA for the grid would be completed by WW following approval by DEFRA on a project basis rather than at strategy level. 3.4.24 Potential issues relating to water abstraction can therefore be discounted.

HYDROGEOLOGY/HYDROLOGY – WHICH SETTLEMENTS DO THE ISSUES RELATE TO? 3.4.25 It is understood that the STW at Warminster only serves Warminster and therefore only impacts on the potential for development at that settlement. 3.4.26 Issues relating to water quality and the use of SUDS apply to all of the settlements identified for growth.

HYDROGEOLOGY/HYDROLOGY - WHAT ARE THE IMPLICATIONS FOR THE CORE STRATEGY? 3.4.27 Issues around diffuse pollution can be dealt with through policy and development control. It is suggested that a policy in line with South Wilts Core Strategy is likely to be acceptable to NE for drainage, surface water and catchment water quality along the lines of the following: The potential impacts of development on the environmental quality of all surface waters and groundwater, particularly the River Avon and the Kennet and Lambourne Floodplains SACs must be considered and mitigated to avoid adverse environmental effects. In order to mitigate the potential environmental effects of surface water drainage discharge from new development on water quality of the River Avon and the Kennet and Lambourne Floodplains SACs, all new development will be expected to include Sustainable Drainage Systems (SUDS) to manage the storage and release of surface water runoff, as suitable to the site and ground conditions, and suitable pollution control measures, wherever possible. Appropriate schemes of mitigation, including consideration of suitable buffer zones along watercourses, habitat enhancements and river access management measures, will also be required to mitigate potential disturbance effects. 3.4.28 If the emerging Core Strategy adopts this approach it will enable the HRA to conclude that development near the River Avon SAC will not harm the SAC through diffuse pollution. 3.4.29 The issues relating to Warminster STW appear to be more intractable and, as things stand, impact on the suitability of the settlement of Warminster for additional development. No other settlements are affected. 3.4.30 The Core Strategy is the appropriate vehicle to try and resolve these issues. The significance of the issues is such that the Core Strategy would not be sound if the allocation at Warminster was retained without the issue being resolved. This assertion is consistent with the concept of spatial planning and the Council should continue to discuss the issues with Natural England, the Environment Agency and Wessex Water. 3.4.31 Off-line solutions may be appropriate but would bring a host of issues relating to site identification, long-term management and other potential environmental effects. The potential for use of the MOD’s infrastructure may also be worth exploring.

Assessment of the Core Strategy Options 12260843 24 under the Habitats Regulations

HYDROGEOLOGY/HYDROLOGY - WHAT ARE THE IMPLICATIONS FOR THE HRA? 3.4.32 On the basis of discussions to date the issues relating to Warminster STW cannot be screened out if Warminster is identified as a location for growth. As things stand there is uncertainty regarding the potential for a significant effect on the River Avon SAC associated with discharge of phosphate.

3.5 POTENTIAL FOR EFFECTS ON EUROPEAN SITES ASSOCIATED WITH AIR POLLUTION

AIR POLLUTION -WHAT IS THE ISSUE? 3.5.1 The HRA for the SW RSS states; “where N2K and Ramsar sites are vulnerable to air pollution, and are located within 200m of road or in close proximity to proposed airport development the potential for adverse effects from air pollution due to increased road and air transport associated with the increase in housing provision and airport expansion in policies within the Proposed Changes to the RSS is more certain. 3.5.2 The Design Manual for Roads and Bridges (DMRB), identifies 200m as the distance beyond which the contribution of traffic emissions to local pollutant concentrations is considered to be negligible (see Figure 3.1 below). Natural England has also confirmed that assessments of Development Plans should focus on sites within 200m of a road. Figure 3.1: Traffic Contribution to Pollutant Concentration

3.5.3 Five of the 14 Natura 2000 and Ramsar sites considered were identified as being potentially sensitive to an increase in air pollution. The location of the five sites were considered in terms of their proximity to main roads which are predicted to experience a change in traffic flow and composition, based on the 200m threshold referred to above. 3.5.4 Natura 2000 or Ramsar sites that were identified as being within 200m of main roads are:

„ Cotswolds Beechwood SAC;

„ Rodborough Common SAC;

„ Salisbury Plain SAC and SPA; and

„ River Avon SAC.

Assessment of the Core Strategy Options 12260843 25 under the Habitats Regulations

3.5.5 According to the SW RSS HRA North Meadow and Clatttinger Farm SAC is a site where Nitrogen deposition is currently exceeding critical loads but this is over 200m from a major road and agricultural activity may be the source of the problem.

AIR POLLUTION - WHICH SETTLEMENTS DOES IT RELATE TO? 3.5.6 At this stage in the Core Strategy process it is difficult to attribute air pollution to specific settlements or understand the contribution that new development will make to the problem, in comparison to general traffic growth in the County and the role of through traffic. 3.5.7 Air pollution is perhaps best seen as a local authority wide issue requiring a local authority wide solution, with specific solutions/interventions for recognised ‘hot-spots.’

AIR POLLUTION WHAT ARE THE IMPLICATIONS FOR THE CORE STRATEGY? 3.5.8 The SW RSS HRA recommends that Policy RE9 in the Proposed Changes to the South West RSS references the need to avoid and where necessary reduce the impacts of air quality problems arising from development on biodiversity, and in particular on N2K and Ramsar sites. In the supporting text, LDDs and local transport plans should be required to take into account through HRA the potential effects on air quality arising from housing, airport and port development proposals, including from traffic generated by them, and in particular transport-related schemes, which could adversely affect N2K and Ramsar sites. 3.5.9 It is recommended that the traffic modelling, undertaken as part of the Core Strategy process to inform infrastructure requirements, should also model emissions to air. This will help provide an evidence base for the HRA and Core Strategy. 3.5.10 The Core Strategy needs to include policies that ensure potential effects on European sites associated with air pollution are taken into account at the development stage. This comment relates to all potential sources of pollution, including point sources.

AIR POLLUTION WHAT ARE THE IMPLICATIONS FOR THE HRA? 3.5.11 The HRA process is predicated on the basis that the Core Strategy should not make an existing situation worse. As things stand it is considered premature to screen out air quality as an issue. It would be premature to identify specific settlements as being problematic. As noted under the implications for the Core Strategy more detailed modelling work is needed to help determine whether or not development associated with a particular settlement will exacerbate the existing situation. 3.5.12 The HRA can also take account of safeguards put in place by the Core Strategy, relating to modal shift and the need for developments to be assessed.

3.6 POTENTIAL PHYSICAL DAMAGE DUE TO HOUSING PROVISION/TRANSPORT INFRASTRUCTURE DEVELOPMENT

WHAT IS THE ISSUE? 3.6.1 In many instances where bats are the qualifying features, N2K sites will have been designated for bat breeding and roosting sites. However, bats often rely on foraging habitat some distance away from the designated sites, and on habitat features linking foraging locations with breeding and roosting sites. As a result, in order to maintain the integrity of the N2K sites, and in particular to ensure that there are no adverse effects on bats as qualifying features, the foraging habitat and flight paths also need to be considered, and direct effects such as physical loss from development, or from indirect effects such as disturbance from people, traffic or artificial lighting need to be avoided.

Assessment of the Core Strategy Options 12260843 26 under the Habitats Regulations

WHICH SETTLEMENTS DOES IT RELATE TO? 3.6.2 The issue is relevant to Bath and Bradford on Avon SAC. Bradford on Avon and Corsham are the nearest settlements to this site.

WHAT ARE THE IMPLICATIONS FOR THE CORE STRATEGY? 3.6.3 The issues associated with such sites are capable of being assessed and resolved through the provision and implementation of design guidance. Guidance is being prepared jointly by Natural England and Wiltshire Council. AA is already taking place at the project level for development near Corsham. 3.6.4 Key issues for the design guidance to cover and examples of how effects can be avoided through design include:

„ Mapping flight lines;

„ Location and design of lighting;

„ Provision of road crossings on key flight lines

„ Identification and protection of habitats used in the summer, e.g. veteran trees/old buildings;

„ Retention/enhancement of linkages/corridors; and

„ Provision of new foraging sites for use in the winter. 3.6.5 With these measures in place, potential issues around in-combination effects with mineral activity can be discounted.

WHAT ARE THE IMPLICATIONS FOR THE HRA? 3.6.6 These issues can be dealt with through the provision and adoption of design advice. They need not therefore influence which settlements development is accommodated in.

Assessment of the Core Strategy Options 12260843 27 under the Habitats Regulations

4 Conclusions and Recommendations

4.1 CONCLUSIONS 4.1.1 A process has been followed which follows advice provided by Natural England. This process has been termed a ‘screening exercise under the Habitats Regulations’ (or a ‘Habitats Regulations Assessment’). It is the first iteration of a process that will need to continue as the Core Strategy develops. 4.1.2 The process has examined the options work undertaken for the Core Strategy to identify whether there is a potential for significant effects on European sites and, if so, how these might be avoided or mitigated. 4.1.3 A range of potential effects have been considered and the work concludes that it should be possible to avoid/mitigate the majority of these. The main area of uncertainty relates to Warminster STW and the impact that additional development might have on water quality. There are also issues relating to potential for recreational pressure, potential impacts relating to poor air quality and potential issues associated with development in proximity of Bath and Bradford on Avon SAC because of its importance to bats. Of these issues, based on the information available to date, only the issues associated with Warminster STW should influence the distribution of development at the settlement level. The other issues should be capable of being avoided or mitigated and the Core Strategy has a role in providing the policy hooks that will help ensure that measures are put in place. 4.1.4 On basis of the work set out above there is uncertainty as to whether or not the Core Strategy will have an (or any) adverse effect on the integrity of European sites.

4.2 RECOMMENDATIONS 4.2.1 It is suggested that:

„ The Green Grid network for Wiltshire should include a range of spaces, including larger informal spaces that meet Natural England’s specifications for natural green space;

„ The options for Warminster STW need to be urgently explored;

„ The Core Strategy should include a general policy relating to the protection of water quality, measures to reduce the demand for, and consumption of, water and the role of SUDS;

„ Consideration is given to how road traffic to and from the area can be reduced, particularly along roads that are close to European sites.

„ The link between air quality and the future pattern of development needs to be better understood. 4.2.2 The HRA will need to be kept under review as the Core Strategy and the response to the issues identified in this report evolve. 4.2.3 One of the comments made by the Steering Group was that this report should factor in the potential implications of climate change and how it might interact with the issues identified and biodiversity. The next iteration of this report will attempt to take climate change into account using available information.

Assessment of the Core Strategy Options 12260843 28 under the Habitats Regulations

Appendix A Figure One

Assessment of the Core Strategy Options 12260843Footer Title under the Habitats Regulations

Environmental Constraints Plan - Overview Scale @ A3 :1:400,000 Figure 1

Key

Wiltshire Council Boundary 15km Study Area Swindon West Preferred Option

Development Options

National Parks

River Wye Walmore Common RAMSAR Sites Special Protection Areas (SPA)

Special Areas of Conservation (SAC) Costwold Beechwoods Roads in Close Proximity to Ecological Sites

  Wye Valley & Forest   Wessex Water North Resource Zone of Dean Bat Sites Thames Water: Swindon & Oxfordshire Water Resource Zone

Wessex Water Resource Zone

Areas Outside Core Strategy Area

Rodborough Common

Severn Estuary North Meadow & Clattinger Farm

Hackpen Hill

River Lambourn SAC

Bath & Bradford Kennet & Lambourn Floodplain on Avon Bats Kennet Valley Alderwoods Pewsey Downs

Bath & Bradford on Avon Bats River Avon

Salisbury Plain Mells Valley Salisbury Plain Salisbury Plain

River Avon

Mendip Woodlands

Salisbury Plain Porton Down

Chilmark Quarries River Avon

Mottisfont Bats

Prescombe Down Great Yews

Emer Bog River Itchen

Fontmell & Melbury Downs

Dorset Heathlands Rooksmoor

Holnest Solent & Southampton Water Avon Valley New Forest SAC/SPA

Dorset Heathlands Solent & Southampton Water Avon Valley Cerne & Sydling Downs

Dorset Heathlands Solent & Southampton Water Dorset Heathlands Dorset Heathlands

PROJECT: Drawn: GH Wiltshire Council HRA Checked: SN PROJECT No: 12260834-001 Approved: SN Client: Revision: A Wiltshire Council Date: October 2009

Appendix B Summary of Issues by European Site and Settlement

Assessment of the Core Strategy Options 12260843 under the Habitats Regulations

KEY TO TABLE Recreation R1 Site screened in - the settlement is within 5km of the site R2 Site screened in - the settlement is within 15km of Salisbury Plain R3 Site screened out - none of the above issues apply Hydrology/Hydrogeology H1 Site and settlement within the Wessex Water Northern Resource Zone H2 Site and settlement within the Thames Water Swindon and Oxfordshire Water Resource Zone H3 Site screened in - STW serving the settlement could impact on conservation objectives for the site H4 Site screened out - none of the above issues apply Nitrogen Deposition N1 Site is within 200m of a road N2 Nitrogen deposition exceeding critical loads N3 Site screened out - none of the above issues apply Physical damage to supporting habitats for batP1 Development at this settlement could give rise to this issue for the site indicated and/or interruption of flight lines etc. P2 Site screened out - the above issue does apply

North Ba Ke th n S ne M Fo ol and B t e ent and ado nt Ke S mell a n Cot lisbu & radf La w an net Rodb S and swo Dorse ou Chi m Dorse V M ry o bo d P al e oro t rd Clatt P re Mel ley n M River S ld Pl h lm urn scombe di on ol P a o e p s ugh ai t mpton n a w t b Ha A ent B orton Ne H Av r Great Ne s River H M Wo ti n Av k F ing ey eat ury Downckpen ld e sf Lam ee E eat o loo w l C m S w n o Qu e erwo ls odl o Mari chw o DownP Fo h n Fo r FarmD h nt m or B A l Wat V arries Y dpl o D A l V bo a a all B e wns o a al an Bat time m res n ats S ai res wn von n Hil o l urn oo n ds er ey w ds d ey ds S on og d t s n t s l s s d S S S S S SPA S S S S S S S SAC S SAC S S SAC SAC SA S S SAC SA P A P PA P AC A AC AC A A A A A AC AC AC AC A A C A A C C C C C C C C C Settlement Chippenham Recreation R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Swindon West Recreation R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R1 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H4 H4 H4 H4 H4 H4 H4 H4 H2 H4 H2 H4 H4 H4 H4 H4 H2 H2 H4 H4 H4 H2 H4 H2 H2 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Infrastructure P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Trowbridge Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Bradford on Avon Recreation R3 R2 R3 R3 R3 R3 R1 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P1 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Calne Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Corsham Recreation R3 R2 R3 R3 R3 R3 R1 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P1 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Devizes Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R1 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Tidworth/ Ludgershall Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H4 H4 H4 H4 H4 H4 H4 H4 H2 H4 H2 H4 H4 H4 H4 H4 H2 H2 H4 H4 H4 H2 H4 H2 H2 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Malmesbury Recreation R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R1 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Marlborough Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H4 H4 H4 H4 H4 H4 H4 H4 H2 H4 H2 H4 H4 H4 H4 H4 H2 H2 H4 H4 H4 H2 H4 H2 H2 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Melksham Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Warminster Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1/3 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Westbury Recreation R3 R2 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H1 H4 H4 H4 H4 H1 H4 H4 H4 H4 H1 H1 H4 H1 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 Wootton Bassett Recreation R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 R3 Hydrology/Hydrogeology H4 H4 H4 H4 H4 H4 H4 H4 H4 H2 H4 H2 H4 H4 H4 H4 H4 H2 H2 H4 H4 H4 H2 H4 H2 H2 H4 Nitrogen deposition N1 N1 N3 N3 N1 N3 N3 N3 N3 N3 N3 N2 N3 N3 N1 N3 N3 N3 N3 N3 N3 N3 N3 N3 N1 N1 N3 Physical damage/interruption of sight lines etc. P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2 P2

Assessment of the Core Strategy Options 12260843 under the Habitats Regulations