Habitats Regulations Assessment

North Devon and Torridge Local Plan

Publication Draft

Habitat Regulations Assessment

June 2014

If you have any queries or questions relating to this document please get in touch using the details shown below:

Torridge District Council North Devon Council Riverbank House Civic Centre Bideford Barnstaple EX39 2QG EX31 1EA

01237 428748 01271 388392 Contents 1.0 Introduction ...... 1 1.1 The Habitats Regulation Assessment Process...... 2 1.2 Requirement for Habitats Regulations Assessment ...... 3 1.3 Assessment Approach ...... 3 1.4 Consultation ...... 3 1.5 Purposes and Structure of Screening Report ...... 4 2.0 Methodology ...... 5 3.0 Evidence ...... 5 3.1 State of the SACs ...... 6 3.2 Potential Impacts ...... 6 4.0 Scope of the Assessment ...... 7 4.1 Braunton Burrows ...... 8 4.1.1 Braunton Burrows SAC Condition ...... 8 4.1.2 Vulnerability...... 8 4.1.3 Potential Impacts from Development ...... 9 4.2 Culm Grasslands ...... 9 4.2.1 Culm Grassland SAC Condition ...... 10 4.2.2 Vulnerability...... 10 4.2.3 Potential Impacts from Development ...... 10 4.3 Exmoor and Quantock Oakwoods ...... 10 4.3.1 Vulnerability...... 11 4.3.2 Potential Impacts from Development ...... 11 4.4 Exmoor Heaths ...... 11 4.4.1 Vulnerability...... 12 4.4.2 Potential Impacts from Development ...... 12 4.5 Tintagel–Marsland–Clovelly Coast ...... 13 4.5.1 Vulnerability...... 13 4.5.2 Potential Impacts from Development ...... 13 4.6 Lundy Marine ...... 14 4.6.1 Vulnerability...... 14 4.6.2 Potential Impacts from Development ...... 14 4.7 Other European Sites ...... 14 5.0 Screening ...... 15 5.1 Potential Vulnerabilities ...... 15 5.2 Plan Categorisation ...... 16 6.0 Relevant Plans and Projects ...... 22 7.0 Screening Conclusions ...... 23 7.1 Next Stages ...... 29 8.0 Appropriate Assessment ...... 29 8.1 Culm Grassland SAC Traffic Volume Impacts ...... 29 8.1.1 Issues Arising from the Plan ...... 31 8.1.2 How the SAC maybe Affected ...... 32 8.1.3 The Current Situation ...... 33 8.1.4 The Potential for Adverse Effects on the Integrity of the Site ...... 34 8.1.5 Avoidance, Mitigation and Compensation Measures ...... 40 8.1.6 Summary and Conclusions ...... 41 8.2 Braunton Burrows SAC Increase in Recreational Pressure ...... 42 8.2.1 Issues Arising from the Plan ...... 43 8.2.2 How the SAC maybe Affected ...... 43 8.2.3 The Current Situation ...... 44 8.2.4 The Potential for Adverse Effects on the Integrity of the Site ...... 46 8.2.5 Avoidance, Mitigation and Compensation Measures ...... 46 8.2.6 Summary and Conclusions ...... 48 Appendix 1: UK Traffic Data – Rose Ash on the A361 between B3227 and A396 ...... 50 Appendix 2 Automatic Traffic Counter, A361, Beaples Moor ...... 51 Appendix 3: DWT Knowstone, Haresdown and Rackenford Moors SAC Mitigation Proposal ...... 52 Appendix 4: Full Biosphere Reserve visitor survey data...... 56 Appendix 5: Sandy Lane Car Park Tickets ...... 58 Appendix 6 Summary of Green Infrastructure Strategy Requirements ...... 59

1.0 Introduction

North Devon and Torridge District Councils are currently developing their joint Local Plan, which is at the regulation 19 stage. The Authorities are undertaking this Habitats Regulation Assessment (HRA) in line with the requirements set out by the Conservation (Natural Habitats &c) (Amendment) Regulations 2007.

This HRA/AA Report seeks to establish whether there is the potential for any adverse effect on identified European Sites (N2k sites) as a result of implementing the policies in the joint Local Plan. Stage One of the HRA assessment has sought to determine the likely significant effects (LSE) of the Local Plan through the Screening of each policy. The HRA Screening process has concluded that due to the locations of northern Devon’s SACs in relation to the spatial distribution of proposed development there are no individual Local Plan led developments or site allocations which will lead to a LSE on any European Site. Furthermore, the impacts of individual developments are carefully regulated through development management policies and on-site measures, which include the requirement for project level HRA.

The Screening assessment was unable to conclude that there would not be a LSE as a result of the overall quantum of development and the subsequent rise in population totals across northern Devon over the entire Plan period to 2031. The overall level of Local Plan led residential and commercial development has the potential to lead to secondary and in-direct effects which can not be attributed to any individual site or its proximity to a SAC. These potential LSEs would occur as a result of the Plan alone and are not considered to be significantly affected by any in-combination effects with other plans or programmes. Therefore the Screening assessment has concluded that the HRA should progress to Stage Two of the HRA process. An Appropriate Assessment (AA) is required to assess whether the identified LSEs would lead to a significant adverse effect on the integrity of any identified SAC.

Stage Two of the HRA considers the potential for significant adverse effects on the integrity of Braunton Burrows SAC through increased visitor disturbance, and on the Culm Grassland SAC through increased traffic on the A361 and subsequent changes in air quality. Stage One concluded that an LSE would only occur as a result of the growth in population of northern Devon over the Plan period as dictated by Policy ST07: Scale and Distribution of New Development in Northern Devon. Policy ST07 guides the overall quantum of housing and associated employment, community and infrastructure provision and will potentially lead to a rise in population, long-term traffic growth and an increase in recreational pressures.

Culm Grassland SAC

The AA has concluded that there would be no significant adverse effect on the integrity of the Culm Grassland SAC as a result of Local Plan led development and growth in vehicle related emissions on the A361. Existing atmospheric pollutants are significantly below the habitats Critical Levels and are expected to decrease further by 2031 even under a worst-case scenario of traffic growth through the SAC. However, evidence suggests that the habitat has already exceeded its minimum Critical Load for nitrogen deposition as a result of all sources of nitrogen deposition, with agricultural being the principal input.

Given the location and strategic importance of the A361 no alternatives to the overall level of Local Plan led development are available to the LPA which would significantly restrict the projected increase in vehicle movements on the A361 over the Plan period. Future reductions in atmospheric pollutants combined with improved on-site management should lead to a long-term decline in nitrogen deposition and any associated habitat degradation. To increase the resilience of the Culm SAC the AA recommends that the Local Plan continues to support further measures to lower nitrogen deposition levels and reduce the current level of habitat fragmentation. Recommendations included:

 Continued support for the Devon Wildlife Trust Working Wetlands project  General policy support for improvements in public transport  Policy support for the take up of low emission vehicles

The Local Plan should be seen in conjunction with the need for wider measures such as effective SAC management and coordinated regional approaches to air quality. The recommendations have been subject to ongoing consultation and advice from Natural England, Devon Wildlife Trust, the Biosphere Reserve Partnership and wider stakeholders 1

Braunton Burrows SAC

The AA has concluded that there would be no significant adverse effect on the integrity of the Braunton Burrows SAC as a result of Local Plan led development and any increase in visitor pressure. The numerous SSSI units within the SAC are generally in a favourable or recovering condition and existing on-site management measures are in place to limit habitat degradation associated with recreational pressure.

Analysis of current visitor numbers and behavioural patterns suggest that visitors to Sandy Lane car park are likely to have the greatest potential impact on the sites interest features. Dog walkers, trekkers and people taking regular exercise in and around the heart of the SAC are found at this location with the majority of visitor trips originating in the local area. Local Plan led development will likely result in marginal growth of approximately 10% (on average 5 cars per day) in regular visitors to the SAC by 2031. Despite the relatively low numbers there is clearly potential for a degree of additional recreational pressure, particularly in the area around Sandy Lane car park.

The AA recommends that the Local Plan supports the development of the existing evidence base to increase the understanding of existing and projected visitor pressures and habitat condition in Braunton Burrows SAC. A management strategy will be developed to address the identified levels of impacts and appropriate measures implemented and monitored for effectiveness. The evidence base and emerging management strategy will be developed in partnership with Natural England, Christie Estates, the Biosphere Reserve Partnership and wider stakeholders.

1.1 The Habitats Regulation Assessment Process

The HRA process is generally divided into three stages and it is often referred to as ‘Appropriate Assessment’ (AA). However, appropriate assessment forms only one stage of the HRA, and it is first determined by an initial ‘screening stage’ whether or not AA is needed.

Stage Task Outcome Stage 1:  Description of the plan Where effects are unlikely, prepare a Screening  Identification of potential ‘finding of no significant effect report’. effects on Natura 2000 sites  Assessing the effects on Where effects judged likely, or lack of Natura 2000 sites information to prove otherwise, proceed to Stage 2. Stage 2:  Gather information (plan and Appropriate Assessment report describing Appropriate Natura 2000 sites) the plan, Natura 2000 site baseline Assessment  Impact prediction conditions, the adverse effect of the plan on  Evaluation of impacts in the Natura 2000 site, how these effects will view of conservation be avoided through, firstly, avoidance, and objectives secondly mitigation including the  Where impacts considered mechanisms and timescales for these to affect qualifying features, mitigation measures. identify alternative options.  If no alternatives exist, If effects remain after all alternatives and define and evaluate mitigation measures have been considered mitigation measures where proceed to Stage 3. necessary. Stage 3:  Identify ‘imperative reasons This stage should be avoided if at all Assessment where for overriding public interest’ possible. The rest of IROPI and the no alternatives (IROPI) requirements for compensation are exist and adverse  Identify potential extremely onerous. impacts remain compensatory measures. taking into account mitigation Table 1: Stages in HRA 1

1 Appropriate Assessment of Plans. LUC and Levett-Therivell 2006. http://www.levett-therivel.co.uk/AA.pdf 2

1.2 Requirement for Habitats Regulations Assessment

Habitats and species of European nature conservation importance are protected by the European Directive (92/43/EEC) on the Conservation of Natural Habitats and Wild Flora and Fauna (the Habitats Directive). The Habitats Directive establishes a network of internationally important sites that are designated for their ecological status. These sites are often referred to as Natura 2000 (N2K) sites or European sites, and they comprise Special Areas of Conservation (SACs) and Special Protection Areas (SPAs). SPAs are classified under the Council Directive 2009/147/EEC on the conservation of wild birds.

Articles 6 (3) and 6 (4) of the Habitats Directive require AA to be undertaken on proposed plans or projects which are likely to have a significant effect on one or more European sites, either individually or in combination with other plans and projects2. This requirement was transposed into UK law in Part IVA of the Habitats Regulations (The Conservation (Natural Habitats &c.) (Amendment) (England and Wales) Regulations 2007) in 2007, and these regulations require the application of HRA to all land use plans. These regulations have been consolidated through The Conservation of Habitats and Species Regulations 2010 and amended further by The Conservation of Habitats and Species (Amendment) Regulations 2012.

The purpose of HRA/AA is to assess the impacts of a land-use plan, alone or in combination with the effects of other plans and projects, against the conservation objectives of a European site and to determine whether it would adversely affect the site’s integrity3. Where significant negative effects are identified, avoidance, mitigation measures or alternative options need to be examined in order to avoid any potentially damaging effects. The scope of the HRA will depend on the location, size and significance of the proposed plan or project and the sensitivities and nature of the interest features of the European sites under consideration.

1.3 Assessment Approach

The methods and approach used for this screening are based on currently available and emerging practice, including ‘Appropriate Assessment of Plans’ (Levett-Therivel, Treweek Environmental Consultants, Land Use Consultants, 2006) and ‘The Appropriate Assessment of Spatial Plans in England’ (Dodd A. M., Cleary B. E., Dawkins J.S., Byron H.J., Palframan L.J., and Williams G.M. (2007)). Current practice recommends that HRA be approached in three main stages as outlined in table 1 and this report outlines the method and findings for Stage 1 and 2 of the HRA process.

Further guidance ‘Habitats Regulations Appraisal of Plans - Guidance for Plan-Making Bodies in Scotland’ (David Tyldesley And Associates for Scottish Natural Heritage, August 2012) has been recently issued and has informed the revised version of the HRA/AA and its supporting evidence base.

1.4 Consultation

It is a requirement of the Habitat Regulations to consult the appropriate nature conservation statutory body (Natural England). Consultation on the approach to HRA/AA has been undertaken throughout the development of the original and revised versions of the HRA/AA. Consultation with other bodies and the public is at the discretion of the plan making authority and following good practice guidance the HRA information will be made available to the public at each formal development plan consultation stage.

Version 1 of the Screening Report was made available for wider public consultation alongside the joint Local Plan and the draft Sustainability Appraisal during February and March 2013. Formal comments have been received from the Environment Agency and Natural England and have informed the revised assessment.

2 Determining whether or not an effect is ‘significant’ is undertaken in relation to the designated interest features and conservation objectives of the Natura 2000 sites. If an impact on any conservation objective is assessed as being adverse then it should be treated as significant. Where information is limited the precautionary principles applies and significant effects should be assumed until evidence exists to the contrary. 3 Integrity is describe as the sites’ coherence, ecological structure and function across the whole area that enables it to sustain the habitat, complex of habitats and/or levels of populations of species for which it was classified 3

There have been a number of changes made to the Local Plan since the publication of the draft in January 2013. These amendments have arisen as a result of consultation responses and changes to national planning policy and mainly relate to the clarification or strengthening of policy wording. The changes do not significantly affect the findings of the HRA Screening Report (Jan 2013) which accompanied the draft plan on consultation.

1.5 Purposes and Structure of Screening Report

This report documents the screening process and its findings for the joint Local Plan for North Devon and Torridge. Following on from the introduction the report contains the following main sections:

 Section 2, 3 and 4 – outlines the method used for the screening process and includes reference to the information sources used  Section 5 and 6 – outlines the most relevant plans and programmes, and the process and summary findings of the screening process and assessment  Section 7 – outlines the conclusions and recommendations for the screening exercise and the next steps in the HRA process.  Section 8 – Appropriate Assessment of the evidence base and proposed course of action for each Likely Significant Effect (LSE) identified at the Screening Stage.

Copies of the documents are available for public inspection free of charge from the addresses below. They can also be accessed on the Council’s website: www.torridge.gov.uk or www.northdevon.gov.uk

Comments on the screening report should be sent in writing to

Mark Saunders Sustainability Officer North Devon Council Civic Centre North Walk Barnstaple, EX31 1EA Or via e-mail to [email protected]

2.0 Methodology

The Habitats Directive and Regulations do not specify how assessment should be undertaken and the screening stage has therefore been conducted in accordance with DCLG guidance ‘Planning for the Protection of European Sites: Appropriate Assessment’ (2006) and the European Commission document ‘Assessment of plans and projects significantly affecting Natura 2000 sites’ (2001). It is also guided by the approach of the South West Regional Spatial Strategy (RSS), which was never adopted and is now formally rescinded. However, the HRA of the RSS forms part of a detailed regional evidence base which is still considered relevant.

The DCLG guidance sets out three main tasks:

 Screening Likely Significant Effects (LSE): it is considered important that the precautionary principle is used in assessing whether effects may be significant, meaning that where there is uncertainty in the possible effects it should be assessed in more detail.  Detailed Appropriate Assessment and ascertaining the effect on site integrity: where significant effects are present (or possible, having applied the precautionary principle) more detailed evidence in necessary to determine the impact of effects. The appropriate assessment must at this stage consider whether the plan has an adverse effect on the integrity of the European site.  Mitigation measures and alternative solutions: where a plan option has been found to have adverse effects on the integrity of a European site such effects should be mitigated. Mitigation should aim to fully cancel out any negative effects, where this is not possible the option should not be pursued other than for imperative reasons of overriding public interest.

However, HRA should be an iterative process and counter-acting measures identified through Screening should be introduced at the earliest possible stage of plan development. The efficacy of the proposed measures will dictate the scope and/or necessity for subsequent detailed AA. If the Screening recommendations and amendments have been unable to exclude the risk of a significant effect(s) then a technical AA will be required as above. This document sets out the following tasks:

 Identifying the sites, reasons for designation, the condition of the SAC and the SACs vulnerabilities (Section 4)  Identifying other plans and programmes that may have an impact on sites (Section 5)  Identifying possible effects of the plans aims on the SACs (Section 6)  Assessing whether possible effects could arise as a result of specific plan policies (coarse screening) (Section 6)  Screening conclusions, recommendations and identification of further work. (Section 7)  Appropriate Assessment assessing the significance of effects of plan policies against the conservation objectives of the SACs (Section 8)

3.0 Evidence

It is inevitable that this kind of assessment relies on a degree of balanced judgement and it is important that wherever possible judgement is based on sound evidence. The evidence that is of value for this assessment will consider two key areas, namely the state of the SACs and the range and scale of potential impacts.

The North Devon and Torridge area comprises about 1,903 square kilometres and has a population of around 157,000 people living in a network of historic market towns, rural settlements and coastal resorts. The population is estimated to grow by approximately 2,200 people (1.4%) per year4. About half the population live around the Taw and Torridge estuaries, in Barnstaple, Bideford, Braunton, Fremington and Northam. The North Devon Link Road and the Atlantic Highway run east-west, connecting the area to the M5 and to north Cornwall. The only rail link is the Tarka Line running between Barnstaple and Exeter. Other north-south links are of poorer quality and many rural communities are relatively isolated.

4 North Devon and Torridge Local Plan Consultation Draft. North Devon Council 2013. 5

From the northern Devon housing target of approximately 16,500, 87% will be located in the districts’ towns. The growth focus will be at Barnstaple and Bideford, which will accommodate 48% of the overall housing requirement, supported by significant employment allocations, which account for about 50% of the employment land supply. The Main Towns will accommodate about 38% of the overall housing target and 53% of the employment requirement. Development opportunities in the rural area will account for about 13% of the housing supply 2011-2031.

Development will be focused at the Sub-regional, Strategic and Main Centres to increase self- containment through sustainable growth that provides balanced housing markets within environmental limits and increases access to jobs, health, education, leisure, culture and community facilities. New development will be focused within Barnstaple (3,900) and Bideford (4,100) These areas will accommodate the bulk of the requirement for new dwellings and associated economic and community development during the plan period. More locally focussed development will occur in the Main Centres and Local Centres reflecting the needs and requirements of those communities and to ensure that they offer a range of services and facilities and sustainable opportunities for change, consistent with their scale and function.

Figure 1: Local Plan Key Diagram

3.1 State of the SACs

An essential element in assessing potential impacts is the evidence that relates to species and habitats and the key reasons for the designation of the SACs, and any particular vulnerabilities of the site, are set out in Natural England’s assessments. The monitoring of the sites is conducted over wide intervals (normally around five years), because it can be resource intensive but also allows the consideration of long-term trends as opposed to annual fluctuations (for example species population).

Natural England holds the existing evidence relating to the state of SACs and this includes data that relates to projects and improvements in specific areas, species population and habitat quality as well as initial baseline studies. Natural England undertake a ‘Site of Special Scientific Interest (SSSI) Condition Survey every six years.

3.2 Potential Impacts

Because the evidence relating to potential impacts can be wide ranging, the scale of the existing issues and the potential for such an impact to increase as a result of Local Plan policies must be

6 considered. It is also important to consider any cumulative and synergistic effects as well as the duration, frequency and reversibility of any impacts.

The evidence base relating to potential impacts stems mainly from within the Authority and partner organisations and includes data and monitoring relating to population, visitor numbers, new development, land-use and agricultural changes, pollution incidents, water resources and traffic and transport. Section 8 provides the Appropriate Assessment methodology and evidence base relevant to each specific LSE.

Additional date on water resources is available from the Environment Agency and on air quality from Defra Local Air Quality Management (LAQM) and the Air Pollution Information System (APIS).

4.0 Scope of the Assessment

Guidance states that the scope of the assessment must consider an appropriate level of information. It states that it would be best practice to collect information in relation to:

 European sites within and outside the plan that are potentially affected  The characteristics of these European sites  Their conservation objectives  Other relevant plans and projects.

There are six European sites within the areas covered by the joint Local Plan as outlined in Table 2 below:

European Sites Designation Braunton Burrows (North Devon) SAC Culm Grasslands (North Devon &Torridge) SAC Exmoor Heaths (North Devon) SAC Exmoor and Quantock Oakwoods (North Devon) SAC Lundy (Torridge) SAC Tintagel-Marsland-Clovelly Coast (Torridge) SAC Table 2 European Sites within the Plan/Proposal Boundary

These sites represent a number of diverse SAC habitats/site types, varying in extent and reasons for designation. There are no SPA or Ramsar sites in North Devon and Torridge.

KEY

County Boundary

District Boundary

Special Areas of Conservation

Motorway

Primary Road

Railway Line

Source: Natural England, Ordnance Survey. 2007

Figure 2: Designated Sites within North Devon and Torridge

The following sections summarises each SAC5, their designated species and habitats, and their vulnerability to development. The identified risks from development are derived from Appendix 36 of the RSS Proposed Changes HRA Final Report. This sets out the AA conclusions regarding potential adverse effects on each site from the proposals in the Proposed Changes to the South West RSS. More detailed information on the affected sites including relevant threats; vulnerabilities and key issues can be found in Section 8.

4.1 Braunton Burrows

SAC Name Braunton Burrows SAC Code UK0012570 Area (ha) 1346.64 Grid Reference SS451348 District North Devon General Site Character Coastal sand dunes. Sand beaches. Machair (85%) Shingle. Sea cliffs. Islets (1%) Inland water bodies (standing water, running water) (1%) Heath. Scrub. Maquis and garrigue. Phygrana (3%) Improved grassland (5%) Broad-leaved deciduous woodland (5%) Annex I habitats that are a Shifting dunes along the shoreline with Ammophila arenaria primary reason for selection Fixed dunes with herbaceous vegetation * Priority feature of this site Dunes with Salix repens ssp. argentea Humid dune slacks Annex I habitats present as Mudflats and sandflats not covered by seawater at low tide a qualifying feature, but not a primary reason for selection of this site Annex II species that are a Petalwort Petalophyllum ralfsii primary reason for selection of this site

4.1.1 Braunton Burrows SAC Condition

Figure 3: Condition of Braunton Burrows SAC

4.1.2 Vulnerability

This large site contains a substantial area of mobile and fixed dune vegetation. The virtually intact and active fixed dune site is made up of herbaceous vegetation and species-rich calcareous grassland. The short turf areas are extremely rich in herbs and lichens, including a number of nationally rare species. Early and mature successional stages of dune slack vegetation are scattered across the site and form part of a complex mosaic of vegetation. An exceptionally large area of Humid dune slacks containing both water and scrub dominated vegetation represents a significant proportion of the national resource.

In recent decades, coarse, rank vegetation and willow scrub have spread on the Burrows due to a lack of grazing, and land drainage and/or abstraction and has caused water tables to fall. In conjunction with the Environment Agency and land owners Natural England are, through the preparation of a Water Level Management Plan, exploring ways of raising the water level such as the installation of

5http://www.jncc.gov.uk/ProtectedSites/SACselection/SAC_list.asp?Country=E 6 http://gosw.limehouse.co.uk/portal/regional_strategies/drss?tab=files 8 sluices in the perimeter ditch. An agreement is also being sought with the landowner and Ministry of Defence to introduce grazing to the majority of the Burrows.

4.1.3 Potential Impacts from Development

Water abstraction to serve future development around Barnstaple and Bideford is considered a potential threat to the integrity of Braunton Burrows SAC. Through the HRA of the RSS the Environment Agency has confirmed that currently abstraction is not having a significant effect on the integrity of the SAC. The EA have since confirmed that there is no pressure on water supply from housing or industrial development in the Roadford water resources zone in which Barnstaple and Bideford are located. This is based on the current South West Water Resource Management Plan which advises that in spite of climate change and the effect of sustainability reductions in the water available for use, levels in the Roadford Water Resource Zone7 remain comfortably above demand plus target headroom throughout the planning period. Given this forecast the subsequent risk of impacts on Braunton Burrows as a result of future water abstraction is currently assumed to be well within manageable limits.

The proposed level of housing development in northern Devon is likely to lead to increased recreational pressure on certain parts of the SAC. This may result in the need to manage the risk of future physical damage and erosion. General policies should restrict waterside development and guard against any water pollution implications. The HRA of the RSS does not identify Braunton Burrows SAC as being at risk from tourism pressures.

4.2 Culm Grasslands

SAC Name Culm Grasslands SAC Code UK0012679 Area (ha) 768.69 Grid Reference SS843214 District North Devon, Torridge and West Devon General Site Character Inland water bodies (standing water, running water) (1%) Bogs. Marshes. Water fringed vegetation. Fens (3.5%) Heath. Scrub. Maquis and garrigue. Phygrana (25%) Dry grassland. Steppes (2.5%) Humid grassland. Mesophile grassland (60%) Improved grassland (1%) Broad-leaved deciduous woodland (7%) Local Sites Hares Down, Knowstone and Rackenford Moors (768.89ha) – NDC Bradworthy Common, Bradworthy. (24.1ha) Bursdon Moor, Hartland. (144.2ha) Dunsdon Farm, Pancrasweek (39.2ha) Kismeldon Meadows, Woolfardisworthy (32.4ha) Membury and Stowford Moors, East Putford (39.5ha) Thorne and Doves Moors, Buckland Brewer (78.4ha) Hollow Moor and Odham Moor (183.68ha) – WDBC Annex I habitats that are a Molinia meadows on calcareous, peaty or clayey-silt-laden soils primary reason for selection of this site Annex I habitats present as Northern Atlantic wet heaths with Erica tetralix a qualifying feature, but not a primary reason for selection of this site Annex II species that are a Marsh Fritillary butterfly Euphydryas aurinia primary reason for selection of this site

7 Water Resources Management Plan. South West Water. March 2013. http://www.southwestwater.co.uk/media/pdf/4/7/South_West_Water_Draft_Water_Resources_Management_Plan_March_2013. pdf 9

4.2.1 Culm Grassland SAC Condition

Figure 4: Condition of Culm Grassland SAC

4.2.2 Vulnerability

Culm Grasslands represents Molinia meadows on calcareous, peaty or clayey-silt-laden soils. Contains extremely diverse examples of the heathy type of fen-meadow, ranging from short, grazed swards through to stands that are transitional to scrub. It is judged to be the most important location for the Marsh Fritillary butterfly in its major south-west stronghold.

Culm Grassland is the local name given to the unimproved pastures, which support a distinctive array of wildlife on the Culm Measures of northern Devon and north-east Cornwall. The grassland is a result of human activity, and to survive it must continue to be managed. The traditional methods upon which these meadows depend are rough summer grazing, selective burning and topping, and no application of fertilisers. Such management may no longer be economic; therefore Environmental Stewardship Schemes are being used to promote the continuation of traditional management. The scheme has achieved a 95% uptake rate with owner-occupiers.

4.2.3 Potential Impacts from Development

The promotion of North Devon as a popular tourist destination would potentially result in increased visitor pressure and potential habitat damage. The HRA of the RSS does not identify the Culm Grasslands SAC as being at risk from tourism pressures.

The Hares Down, Knowstone and Rackenford Moors Culm Grassland site contains the strategic A361 entering northern Devon and may experience an increase in traffic volumes. Bursdon Moor Culm SAC also has the A39 running through it. The RSS states that existing acid deposition caused by diffuse pollution from traffic at the site is 2.3 times the critical load for calcareous grassland. The Two Moors Way also crosses the site and could potentially experience an increase in user numbers. Physical damage due to recreation and increased air pollution relating to traffic should be managed by relevant planning documents. The RSS has identified Culm Grasslands SAC as already exceeding critical loads of nitrogen deposition. The Highways Agency suggests that beyond 200m from a roadside (A361) the increase in local pollution levels from vehicles is not significant.

4.3 Exmoor and Quantock Oakwoods

SAC Name Exmoor and Quantock Oakwoods SAC Code UK0030148 Area (ha) 1895.17 Grid Reference SS894440 District North Devon and West Somerset General Site Character Inland water bodies (standing water, running water) (0.5%) Bogs. Marshes. Water fringed vegetation. Fens (0.5%) Heath. Scrub. Maquis and garrigue. Phygrana (6%) Dry grassland. Steppes (3%) Humid grassland. Mesophile grassland (0.5%) Broad-leaved deciduous woodland (87%) Coniferous woodland (1%) Mixed woodland (1%) Other land (including towns, villages, roads, waste places, mines, industrial 10

sites) (0.5%) Annex I habitats that are a Old sessile oak woods with Ilex and Blechnum in the British Isles primary reason for selection of this site Annex I habitats present as Alluvial forests with Alnus glutinosa and Fraxinus excelsior * Priority a qualifying feature, but not feature a primary reason for selection of this site Annex II species that are a Barbastella barbastellus bats primary reason for selection of this site Annex II species present as Bechstein`s bat Myotis bechsteinii a qualifying feature, but not Otter Lutra lutra a primary reason for site selection

4.3.1 Vulnerability

This site supports extensive tracts of old sessile oak woods in conjunction with heath. They are rich in bryophytes, ferns and epiphytic lichens, the latter often associated with old pollards, since parts are former wood-pasture rather than the oak coppice that is more common with this type. In the Barle Valley the woods also occur in mosaic with glades and small fields and the combination results in good populations of fritillary butterflies and bats. The loss of habitat diversity may also be exasperated by impacts on flights lines outside of the SAC itself.

Some grazing/browsing is essential to maintain conditions suitable for lower plant assemblages, which are a key feature of the woodlands. However, sheep and/or red deer graze many woods and this can prevent regeneration and change the ground flora. Cases of overgrazing may require action using environmental conditions of livestock subsidy schemes. Invasive non-native species are a problem in some woods, particularly Rhododendron and Japanese Knotweed. Conservation bodies or management agreements are eliminating these species. Beech is also a problem, as it is replacing oak in places and does not support such diverse or specialist wildlife.

Dense monocultures of coppiced oak occur, of little structural or species diversity. Although minimum intervention is mostly desirable, opportunities are being taken to diversify age and species composition to restore near-natural conditions where possible.

4.3.2 Potential Impacts from Development

Water abstraction to serve future development around Barnstaple and Bideford is considered a potential threat to the Exmoor and Quantock Oakwoods SAC. The EA has confirmed that currently abstraction is not having a significant effect on the integrity of the SAC. However the EA has confirmed that water deficits are still likely to occur in relation to planned housing even if water efficiency standards associated with Code for Sustainable Homes Level 3 and other methods are adhered to. The Roadford Resource Zone, in which Barnstaple and Bideford are located, is likely to experience rising deficits throughout the plan period. The subsequent impact on the SAC is currently difficult to ascertain.

4.4 Exmoor Heaths

SAC Name Exmoor Heaths SAC Code UK0030040 Area (ha) 10705.87 Grid Reference SS864419 District North Devon and West Somerset General Site Character Shingle. Sea cliffs. Islets (1%) Bogs. Marshes. Water fringed vegetation. Fens (3%) 11

Heath. Scrub. Maquis and garrigue. Phygrana (83%) Dry grassland. Steppes (7.5%) Humid grassland. Mesophile grassland (3.5%) Broad-leaved deciduous woodland (1%) Inland rocks. Screes. Sands. Permanent snow and ice (0.5%) Other land (including towns, villages, roads, waste places, mines, industrial sites) (0.5%) Annex I habitats that are a Northern Atlantic wet heaths with Erica tetralix primary reason for selection European dry heaths of this site Annex I habitats present as Vegetated sea cliffs of the Atlantic and Baltic coasts a qualifying feature, but not Blanket bogs * Priority feature a primary reason for Alkaline fens selection of this site Old sessile oak woods with Ilex and Blechnum in the British Isles

4.4.1 Vulnerability

Exmoor is representative of upland wet heath predominating on gently sloping and level ground. It is extremely variable in nature and has in places been modified by management, particularly burning. Typically, heather dominates, with scattered plants of purple moor-grass, cross-leaved heath and deergrass. The valley mires support the oceanic species pale butterwort and ivy-leaved bellflower. The Exmoor heaths are also important as the largest stronghold for the heath fritillary butterfly

These heathlands retain significant areas of mature heather stands. This habitat is dependent upon low intensity, traditional agricultural management by grazing and controlled burning. Such management is becoming less economic, except with agri-environment funds. An Environmentally Sensitive Area (ESA) scheme has been useful in promoting traditional grazing management, as have other management agreements and conservation body ownership. Illegal and uncontrolled burning is adversely affecting heathland structure in some areas, and localised winter feeding of cattle and overgrazing has caused some losses to grassland. These problems are particularly apparent on common land. Grazing issues are being tackled by action using the environmental conditions attached to livestock subsidy schemes, as well as the ESA scheme. Incentive payments are currently seen as the only effective means of influencing burning practices. Rhododendron has spread in some areas. Natural England and Exmoor National Park Authority management agreements are being used to eliminate infestations from affected heathland.

4.4.2 Potential Impacts from Development

Water abstraction to serve future development around Barnstaple and Bideford is considered a potential threat to the Exmoor Heaths SAC. The EA has confirmed that currently abstraction is not having a significant effect on the integrity of the SAC. However the EA has confirmed that water deficits are still likely to occur in relation to planned housing even if water efficiency standards associated with Code for Sustainable Homes Level 3 and other methods are adhered to. The Roadford Resource Zone, in which Barnstaple and Bideford relocated, is likely to experience rising deficits throughout the plan period. The subsequent impact on the SAC is currently difficult to ascertain.

The promotion of North Devon as a popular tourist destination would potentially result in increased visitor pressure and potential habitat damage. Physical damage due to recreation should be managed by relevant planning documents. The site is not within close proximity to the strategic road network, however existing acid deposition at the site is 6 times the critical load for upland heathland. It is uncertain what the sources of acid deposition are but any increase in traffic due to tourism may have an adverse effect. The HRA of the RSS does not identify Exmoor Heaths SAC as being at risk from tourism pressures.

This site is vulnerable to invasion by woody species as a result of natural succession. Adopted policy should allow the removal and management of trees and woodland where there is a need to meet conservation objectives for open habitats, such as heathland and grassland.

4.5 Tintagel–Marsland–Clovelly Coast

SAC Name Tintagel–Marsland–Clovelly Coast SAC Code UK0013047 Area (ha) 2429.84 Grid Reference SS225234 District Torridge and North Cornwall General Site Character Coastal sand dunes. Sand beaches. Machair (5%) Shingle. Sea cliffs. Islets (60%) Inland water bodies (standing water, running water) (2%) Heath. Scrub. Maquis and garrigue. Phygrana (10%) Dry grassland. Steppes (10%) Broad-leaved deciduous woodland (10%) Mixed woodland (3%) Local Sites Hobby to Peppercombe, Alwington / Clovelly / Parkham / Woolfardisworthy (224.0ha) Marsland to Clovelly Coast, Clovelly / Hartland / Welcombe (949.8) Annex I habitats that are a Vegetated sea cliffs of the Atlantic and Baltic coasts primary reason for selection Old sessile oak woods with Ilex and Blechnum in the British Isles of this site Annex I habitats present as European dry heaths a qualifying feature, but not a primary reason for selection of this site

4.5.1 Vulnerability

This site represents an extensive length of largely hard coastal cliff with a range of maritime influences and vegetation. The greater part of this site is west facing and strongly maritime in character. The section east of Hartland Point faces north and north-east and is relatively sheltered. Inland of the crevice and grassland communities, maritime heath and short coastal grassland with wild thyme and spring squill are particularly significant, and locally these show transitions to scrub and woodland in the adjacent valleys.

Stretches of old sessile oak wood occur at various points along this section of coast. The trees are frequently wind-pruned, sometimes to the point where they are barely taller than the heather. The oak communities include small patches of richer ash and alder woodland. The bryophyte and lichen assemblages are particularly rich, and the Atlantic influence is also shown in the abundance of hay- scented buckler-fern.

The sea cliffs support a variety of maritime vegetation that is dependent upon natural processes and climatic influence. The sea cliffs require limited management, and are fairly inaccessible in many areas. Maintenance and enhancement of the coastal strip is being pursued in collaboration with the National Trust and other land managers, through the provision of advice and promotion of positive land management Environmental Stewardship Schemes.

4.5.2 Potential Impacts from Development

The promotion of North Devon as a popular tourist destination would potentially result in increased visitor pressure and potential habitat damage. Physical damage due to recreation should be managed by relevant planning documents. The South West Coast Path passes through this SAC and may experience increases in trampling and noise leading to loss of habitats. The HRA of the RSS does not identify Tintagel–Marsland–Clovelly Coast SAC as being at risk from tourism pressures.

Waterside employment and development of new maritime industries in towns along the coast could potentially lead to loss of habitats. It is not considered that the qualifying features of this site, such as vegetated sea cliffs would be affected.

4.6 Lundy Marine

SAC Name Lundy Marine SAC Code UK0013114 Area (ha) 3064.53 Grid Reference SS136465 General Site Character Marine areas. Sea inlets (95%) Coastal sand dunes. Sand beaches. Machair (1%) Shingle. Sea cliffs. Islets (4%) Local Site Lundy, Lundy Island (346.4ha) Annex I habitats that are a Reefs primary reason for selection of this site Annex I habitats present as Sandbanks which are slightly covered by sea water all the time a qualifying feature, but not Submerged or partially submerged sea caves a primary reason for selection of this site Annex II species present as Grey seal Halichoerus grypus a qualifying feature, but not a primary reason for site selection

4.6.1 Vulnerability

Lundy is a granite and slate reef system and is selected for its outstanding representation of reef habitats. It is exposed to a wide range of physical conditions as a result of differing degrees of wave action and tidal stream strength on sheltered and exposed coasts and headlands. This range of physical conditions, combined with the site’s topographical variation, has resulted in the presence of a unusually diverse complex of marine habitats and associated communities within a small area.

Lundy is managed as a Marine Nature Reserve. Many of its marine communities are stable, long-lived and slow growing, and would be vulnerable to disturbance by potting or collection and to increased suspended sediment load. A Management Plan implemented through management and advisory groups and involving various measures, is helping to achieve protection of the site. Building on this work, the vulnerability of the marine site will be further identified through Natural England’s work to develop and promote the necessary conservation measures for UK marine SACs.

4.6.2 Potential Impacts from Development

Lundy Marine SAC is not anticipated to experience any significant adverse effects from onshore development in North Devon and Torridge. Water quality may potentially be affected in the short term in near shore waters although this is extremely unlikely to impact the marine nature reserve surrounding Lundy Island. The nature of anticipated development in northern Devon and the distance of Lundy SAC from the coast is likely to preclude any future impact. Major offshore development such as wind farms could have significant effects on the integrity of the site.

4.7 Other European Sites

Natural England has made the following recommendations in terms of defining the sites which should be considered as part of the Screening process.

a) Sites within the plan area; b) Sites downstream of the plan area in the case of river or estuary sites; c) Peatland and other wetland sites with significant hydrological links to land within the plan area, irrespective of distance from the plan area; d) Sites which have significant ecological links with land in the plan area, for example, land used by bats or migratory birds, which also use a SAC or SPA respectively, at different times of the year; e) Sites within 5km of the plan area boundaries that may be affected by local recreational or other visitor pressure from within the plan area; f) Sites within about 20km of the plan area that comprise major (regional or national) visitor attractions such as promoted National Nature Reserves, coastal sites and sites in major tourist or visitor destinations such as AONBs and National Parks; 14

g) Sites that are used for, or could be affected by, water abstraction irrespective of distance from the plan area; h) Sites used for, or could be affected by, discharge of effluent from waste water treatment works or other waste management streams serving land in the plan area, irrespective of distance from the plan area.

Numerous European Sites have been identified outside of the North Devon and Torridge boundary using Natural England’s Nature on the Map application.

 Dartmoor SAC  Holme Moor and Clean Moor SAC (Somerset)  Quants SAC (Somerset)  Hestercombe House SAC (Somerset)

The additional identified sites are considered to be of a sufficient distance from any Local Plan led development to be at no risk of a LSE. No significant development is likely to occur within close proximity to any of these sites with South Molton approximately 40km west of Quants SAC and Great Torrington approximately 30km north of Dartmoor SAC. Dartmoor SAC is within approximately 10- 20km from the Torridge boundary in some areas. However the south-eastern area of Torridge is particularly rural with a sparse settlement pattern. Holsworthy is the nearest Main Centre settlement in this area and is over 25km from the nearest boundary with the Darmoor SAC. Furthermore, none of the identified SACs are considered to have significant hydrological or ecological links to the Local Plan area.

5.0 Screening

Screening is being completed as a two-stage process:

 Coarse Screening – considers the vulnerabilities of each site, and what potential impacts may be damaging to the site. This then ‘screens out’ policies that clearly have no possible negative impacts. Counter-acting measures should be identified in order to amend the plan and mitigate against the most significant negative impacts of the remaining policies. Polices which have not been screened out feed into the final screening.  Final Screening - assesses the possible impacts of each policy on the specific conservation objectives of the site, the significance of such an impact and the risk of it occurring. It will have regard for the plan as a whole, including any counter-acting amendments made during coarse screening. It will also regard any remaining impact in combination with other plans. Policies not ‘screened out’ by this stage require detailed ‘Appropriate Assessment’.

5.1 Potential Vulnerabilities

The RSS HRA Screening process set out a checklist of potential site vulnerabilities, as a mechanism for assessing potential impacts on site integrity. A similar approach will be used for this assessment.

Broad categories of Examples of operations/impacts potential impacts on SACs Physical loss  Direct loss through house building, coastal and flood defence and other development and fragmentation  Recreational pressure (erosion, trampling) Physical damage  Through habitat severance and fragmentation  Erosion, severance, prevention of natural erosion (flood defence)  Increased pressure for wind farms  Erosion due to:  waterside and port development  transport infrastructure development; and  recreation Non-physical  Human presence and pets disturbance  Noise/visual presence Toxic contamination  Air, soil and water pollution, tipping. Non-toxic  Eutrophication due to sewage treatment works discharge contamination  Dust 15

Biological  Natural succession disturbance  Introduction of non-native species Water table  Changes in water levels due to abstraction, drainage, development on floodplain etc.  Changes in turbidity (flood defence) Water resource  Water pollution  agricultural run-off  domestic  industrial  Water availability Air quality  Air pollution  traffic and transport  industrial Table 3: Checklist of potential site vulnerabilities

5.2 Plan Categorisation

The likely impact of each of the proposed policies has been established using the categories shown in the table below. For each proposal that is likely to have an effect, the spatial extent of its potential impacts will be used to determine specific N2k sites that may be affected. Indirect and combined effects have also been identified at this stage, along with avoidance, cancellation, and protection and mitigation measures to be applied.

Category Key to Sub-Categories Used in Screening and Likely Effects Category A – No A1 Policy will not lead to development, e.g. because it relates to design or other negative effect qualitative criteria, or it is not a land-use planning policy at all A2 Policy intended to conserve or enhance the natural, built or historic environment, where enhancement measures will not be likely to have any negative effect on a European Site.

A3 Policy would have no effect because no development could occur through the policy itself, the development being implemented through later policies in the same plan, which are more specific and therefore more appropriate to assess for their effects on European Sites and associated sensitive areas.

Category B – No N/A No significant effect either alone or in combination with other plans or significant effect projects, because effects are trivial or minimal.

Category C – C2 Policy could indirectly affect a European Site, because it provides for, or Likely significant steers, a quantity or type of development that may be very close to it, or effect alone ecologically, hydrologically or physically connected to it, or it may increase disturbance as a result of increased recreational pressure.

Category D – D1 The policy alone would not be likely to have significant effects but its effects Likely significant are combined with the effects of other policies or proposals provided for or effects in coordinated by the LDD the cumulative effects would be likely to be combination significant.

Table 4: Plan Categorisation

Policy / Proposal Could the policy have an impact on Natura 2000 (N2k) sites in the location covered by the policy and/or on any N2k sites outside the Reference location covered but vulnerable to off-site impacts? This includes cumulative impacts from multiple policies. Yes / No Reason Likely operations Potential impacts on Site(s) Assessment to result as a N2K site(s) potentially Category consequence of affected policy

Local Plan Section 3 – Sustainable Development Policy ST01: Presumption No Policy seeks to ensure a positive approach to that in Favour of Sustainable A3 reflects the presumption in favour of sustainable N/A N/A N/A Development development in the NPPF Policy ST02: Principles of No Policy seeks to reduce the environmental impact of Sustainable Development A3 sustainably located development through the efficient N/A N/A N/A use of key resources, minimising greenhouse gas emissions, promoting renewables and reducing waste. Policy ST03: Adapting to No Policy seeks to capitalise on the Biosphere Reserves Climate Change A3 role through management of flood risk, efficient surface water management, conserving landscapes and habitats, N/A N/A N/A and integrating additional green infrastructure. Policy ST04: Improving the No Promoting high quality sustainable design which respects Quality of Development A1 the character of the area and achieves high standards of N/A N/A N/A efficiency, adaptability, ease of movement has no direct impacts on the environment Policy ST05: Sustainable No Promoting high quality sustainable design which respects Construction and Buildings A1 the character of the area and achieves high standards of N/A N/A N/A energy and water efficiency has no direct impacts on the environment Local Plan Section 4 – Spatial Strategy Policy ST06: Spatial No Policy seeks to provide a development hierarchy that Development Strategy for A3 meets the areas needs and aspirations. The hierarchy N/A N/A N/A Northern Devon provides the foundation for the distribution of development through ST07 Policy ST07: Scale and Yes Significant growth in northern Devon focusing on the Housing and mixed- Water table: changes Braunton Distribution of New C2 main towns of Barnstaple and Bideford. Sustainable use development In Roadford Water Burrows SAC, Development in Northern growth will not have a direct impact on any N2k sites but leading to Resource Zone due to Exmoor and Devon indirect impacts may develop in areas that include population growth, abstraction Quantock European Sites. infrastructure Oakwoods, provision and Exmoor Heaths increased traffic Contamination air, Braunton volumes. water and soil pollution, Burrows particularly traffic Culm Grassland volumes on the A361 (Rackenford & and A39 Bursdon Moors),

Non-toxic Braunton contamination: Burrows Eutrophication due to sewage treatment works discharge Physical loss: direct Braunton loss through house Burrows building, coastal and flood defence and other development and fragmentation Increase in recreational Braunton users resulting in Burrows physical damage, i.e. erosion, trampling Policy ST08: Rural Area Yes Focusing development in Rural Hubs to facilitate self- Strategy D1 containment and enhance the sustainability of rural communities. Indirect impacts associated with strategic N/A N/A N/A housing distribution identified under ST07. Assess in combination with ST07 Policy ST09: Coast and No Policy seeks to enhance the sustainability of coastal N/A N/A N/A Estuary Strategy A2 settlements and their unique character and tourism potential. The importance of the undeveloped coastal and estuarine environment is recognised along with the importance of coastal access routes. Commercial and leisure ports and docks will be protected and enhanced to meet community needs. Policy ST10: Transport Yes Maintaining the function of the Devon Road Network, Strategy D1 developing public transport, pedestrian and cycle networks, and enabling sustainable alternatives to the N/A N/A N/A car. Indirect impacts associated with strategic housing distribution identified under ST07. Assess in combination with ST07 Local Plan Section 5 – A World Class Environment Policy ST11: Enhancing No Protecting and enhancing the natural environment Environmental Assets A3 through managing a network of designated sites should N/A N/A N/A lead to direct benefits to the environment Policy ST12: Conserving No Protecting and conserving features of historic importance Heritage Assets A3 through managing a network of designated sites should N/A N/A N/A lead to direct benefits to the environment Policy ST13: Delivering No Increasing the generation of renewable energy and heat Renewable Energy and A1 at appropriately lactations and facilitating district heating N/A N/A N/A Heat schemes in order to combat climate change will have indirect benefits to the environment. Local Plan Section 6 – Enabling a Vibrant Economy 18

Policy ST14: Delivering No Diversifying the economy, regeneration and improving Employment land Employment and D1 the viability and vitality of the area through the strategic allocation may have Economic Development provision of a range of business and employment indirect impacts on N/A N/A opportunities. Allocations that facilitate sustainable traffic movements, communities and transport may produce indirect impacts and air and water at more detailed, later policies. quality. Policy ST15: Town, District No Qualitative and quantitative improvements to retail and Village Centres A1 centres to enhance viability and vitality of the area has N/A N/A N/A no direct impact on the environment. Policy ST16: Sustainable No Qualitative and quantitative improvements to the tourism Tourism A1 industry to support growth that has no direct impact on N/A N/A N/A the natural and historic environment. Local Plan Section 7 – Delivering a Balanced Housing Market Policy ST17: A Balanced Promotes meeting identified housing needs in order to Local Housing Market No achieve balanced and sustainable communities through N/A N/A N/A A1 a mix of dwelling sizes, types and tenures has no direct impact on the environment. Policy ST18: Delivering No Delivery of affordable housing targets has no direct N/A N/A N/A Affordable Housing A1 impact on the environment. Policy ST19: Providing Ensuring adequate provision for the travelling community Homes for the Traveling No without impact on the environment, character or amenity N/A N/A N/A Communities A1 of the local area will have no direct impact on the environment. Policy ST20: Managing the Promotes meeting identified housing needs in order to Delivery of Housing No achieve balanced and sustainable communities through N/A N/A N/A A1 a mix of dwelling sizes, types and tenures has no direct impact on the environment. Local Plan Section 8 – Strong and Inclusive Communities Policy ST21: Community Promotes the delivery of well-related and sustainable Services and Facilities No infrastructure and service facilities as identified through N/A N/A N/A D1 community initiatives may produce indirect impacts at more detailed, later policies. Policy ST22: Infrastructure Yes Ensuring timely physical, social and green infrastructure D1 provision through developer-funded contributions may have indirect impacts associated with strategic housing N/A N/A N/A distribution identified under ST07. Assess in combination with ST07 Policy ST23: No Policy seeks to ensure a positive approach to N/A N/A N/A Neighborhood Planning A1 neighbourhood planning in conformity with the Local Plan Local Plan Section 10 – Main Town Strategies

BAR: Barnstaple Spatial Provision of approximately 4,000 new homes and 45 Strategy hectares of employment land and associated physical, Partially responsible for Yes social and green infrastructure. Indirect cumulative potential increase in Braunton C2 impacts on N2k sites when combined with ST07 visitor numbers on Burrows SAC Braunton Burrows BID: Bideford Spatial Provision for about 3,790 dwellings at Bideford and, Strategy associated development and infrastructure and provision Yes of about 30 hectares of deliverable employment land N/A N/A D1 focused at locations around theClovelly Road and Caddsdown Industrial Estates. Indirect cumulative

impacts on N2k sites when combined with ST07.

BRA: Braunton and Provision of approximately 340 new homes and 10 Partially responsible for Wrafton Spatial Strategy hectares of employment supported by required physical, Yes Individual town potential increase in Braunton social and green infrastructure at Wrafton and Chivenor C2 policies will guide all visitor numbers on Burrows SAC Business Park. Indirect cumulative impacts on N2k sites significant growth in Braunton Burrows when combined with ST07. individual FRE: Fremington and Provision of approximately 370 new homes and 8 settlements away Yelland Spatial Strategy hectares of employment supported by required physical, Yes from N2k sites and social and green infrastructure at Fremington Army N/A N/A D1 guard against direct Camp and Yelland Quay. Indirect cumulative impacts on physical loss N2k sites when combined with ST07. through GTT: Great Torrington Provision for about 470 dwellings and employment land development and / Spatial Strategy provision of about 9 hectares at Hatchmoor Industrial Yes or fragmentation. Estate and associated physical, social and green N/A N/A D1 Effects of town infrastructure. Indirect cumulative impacts on N2k sites policies in when combined with ST07. combination (water HOL: Holsworthy Spatial Provision for about 650 dwellings and about 10 hectares resources, traffic Strategy of additional employment land, which includes an pollution, non-toxic Yes extension to the Dobles Lane Industrial Estate, and contamination), as a N/A N/A D1 associated physical, social and green infrastructure. component of total Indirect cumulative impacts on N2k sites when combined development with ST07. identified and ILF: Ilfracombe Spatial Yes Provision of approximately 1,550 new homes and 15 assessed under Strategy D1 hectares of non-retail employment land and associated ST07. physical, social and green infrastructure. Indirect N/A N/A cumulative impacts on N2k sites when combined with ST07 NOR: Northam Spatial Yes Provision of approximately 1,550 new homes and Strategy D1 improved tourism schemes in Westward Ho!, with associated physical, social and green infrastructure. N/A N/A Indirect cumulative impacts on N2k sites when combined with ST07

SM: South Molton Spatial Yes Provision of approximately 1,100 new homes and 30 Strategy D1 hectares of non-retail employment land including a new primary school, new medical centre, new sewage N/A N/A N/A treatment works, additional sports pitches, allotments and informal open space.. Indirect cumulative impacts on N2k sites when combined with ST07 Local Plan Section 12 – Development Management Policies DM01 – DM28 Development management policies do not directly lead to development but are structured to guide the provision No and design of development which meets the needs of N/A N/A N/A A1 / A2 residents and businesses while providing adequate protection of the natural and cultural environment. Local Plan Section 13 – Neighbourhood Plans Neighbourhood Plans for Neighbourhood Plans will define the scale and type of Local Centres and Villages development that individual rural communities will as defined in ST06 accommodate and help to ensure that the Local Plan takes account of community aspirations in accordance with ST23. Neighbourhood Plans for Witheridge, Yes Rackenford and other rural communities will not be of a N/A N/A N/A D1 significant scale or be in close enough proximity to any SAC to produce a likely significant effect in isolation. Potential indirect cumulative impacts on N2k sites when combined with the overall level of development planned for northern Devon under ST07 Table 5: Coarse Screening of Local Plan policies

6.0 Relevant Plans and Projects

HRA must consider the impact of cumulative and in-combination effects with other plans or proposals on sites being assessed at the screening stage. The HRA of the draft RSS has been completed and serves as a useful starting point for assessment at local authority level.

Area/ Plan or Implications Likely In-Combination Effects Authority Proposal SW Regional Draft Regional 10,700 dwellings over plan No LSE - strategy rescinded Planning Body Spatial Strategy period in Torridge (rescinded) 10,900 dwellings over plan period in North Devon Devon County Minerals Local Significant working includes The Devon Minerals Plan 2011 – 2031 is still Council Plan Petrockstowe Basin between under preparation. The current evidence Meeth and Peters Marland in base does not provide sufficient specific Torridge. information relating to minerals workings in northern Devon to allow a full consideration of in-combination effects. Existing sites are safeguarded but no proposals to expand on the current low level of workings. Plan will be monitored through on-going co-operation. Waste Local Deep Moor Landfill site in Possible LSE - Further considered required Plan (Pre- Great Torrington. as potential for LSE on the Culm Grassland Submission) Energy from waste proposal SAC resulting from traffic growth given Dec 2013) at Brynsworthy, Barnstaple further consideration below. . Devon Local Includes targets relating to No LSE – Impacts associated with long term Transport Plan 3 air quality, recreation, leisure growth in traffic assessed by individual Local 2011-2026 and tourism, towns, villages Authority Local Plans. and rural communities. Proposal for junction improvements on A39 and A361 West Devon Adopted Core New development will be No LSE – No identified in-combination Borough Strategy 2011 concentrated in Okehampton effects given spatial influence of Council and Tavistock development and separation from northern Devon SACs. Mid Devon Adopted Core Limited village development, Raised through Duty to Co-operate District Strategy 2007 town focused growth. regarding possible in-combination effects Council Numerous housing options on the Culm SAC as result of traffic growth. under review to ensure Currently the site is one of numerous options NPPF compliance and it remains to be seen if Mid Devon pursues the development. Progress of the Mid Devon Local Plan will be monitored through ongoing co-operation Environment Catchment Manages ongoing No LSE - All three water resources zones Agency Abstraction abstraction issues for for South West Water are in surplus and are Management Torridge and Hartland forecast to remain in surplus for the next 25 Strategies Streams, Tamar, Taw and years and there is no pressure on water (CAMS) North Devon Streams; supply from housing or industrial development in the Roadford water resources zone as defined by South West Water’s draft water resources management plan. Cornwall LDF Local Development Scheme No LSE - No identified in-combination County for Cornwall in preparation. effects given spatial influence of Council development and separation from northern Devon SACs. North Devon Draft Shoreline Provides a large-scale No LSE - Policy of ‘no active intervention’ or And Somerset Management assessment of the risks ‘managed realignment’ applies. Promote Coastal Plan for North associated with coastal favourable condition of Dune habitats and Advisory Devon and evolution their associated species. A ‘hold the line’ Group Somerset (2010) policy applies between Crow Point and Horsey Island in the short term, In the medium-term a policy of ‘managed realignment’ should promote natural processes. No significant effects on the interest features of the SAC are foreseen. Table 6: Relevant Plans and Projects 22

Table 6 screens out the potential for any further LSE from the North Devon and Torridge Local Plan in- combination with the specified adopted and emerging plans and strategies. Only the Devon County Council Pre-Submission Waste Local Plan contains a policy or proposal which has the potential for an in-combination adverse LSE. The current version of the Waste Local Plan contains a proposal (W6A) for an additional energy recovery facility at Brynsworthy Environment Centre to the south of Barnstaple. The proposal seeks to divert existing waste streams from Deepmoor Landfill in Torrington to a site which is strategically placed to serve the largest urban areas in the Districts.

The Sustainability Appraisal of the Submission Devon Waste Plan8 states that with reference to development in Barnstaple "the site will not change the number of road miles required to treat waste because waste miles accrued by the transport of waste to this site will be offset by a reduction in waste that is currently transported to landfill. The effect has therefore been graded as negligible". Given the strategic location within Barnstaple, the proposal is likely to result in a net decrease in waste miles particularly in the rural areas between Barnstaple and Torrington. Heavy duty traffic flows on the A361 through the Culm Grassland SAC is not anticipated to increase as a result of proposal W6A. It is therefore considered that in terms of traffic growth in the Districts and potential adverse effects on the integrity of the Culm Grassland SAC the proposal is unlikely to have a significant effect alone or in- combination.

The Habitat Regulations Assessment of the Submission Devon Waste Plan9 states that "In response to NE comments on potential traffic pollution impacts on Natura 2000 sites resulting from all waste being taken to one site, the maximum size of any one facility has been capped at approximately 80,000 tonnes. Based on proposals submitted within Devon, this is considered to represent a viable size for an energy recovery facility that avoids the potential scale of impacts, including traffic generation and associated emissions, of larger facilities". The requirement to limit capacity of all new facilities combined with the spatial separation between Barnstaple and other major urban areas outside of northern Devon should ensure that any impacts associated with cross-boundary waste movements is negligible. The Waste Local Plan spatial strategy seeks to further ensure that any waste generated outside of northern Devon is dealt with by facilities in the Exeter area or elsewhere on the M5 corridor.

Section 8.1.4 of the HRA/AA shows that Heavy Duty Vehicles historically make up between 6.1% and 11.4% of total vehicle flow on the A361 and the long term trend shows no evidence of significant increases. The relatively small proportion of heavy duty vehicles passing through the Culm SAC would further support the conclusion that any increase associated with proposal W6A at Brynsworthy would be negligible. It is therefore considered that Local Plan led development in-combination with Waste Local Plan proposal W6A will result in only a minor increase in heavy duty vehicles on the A361 when considered against the overall rate of traffic using the road. Section 8.1 provides a detailed Appropriate Assessment of the potential air quality impacts of overall traffic growth on the Culm Grassland.

7.0 Screening Conclusions

The coarse Screening assessment has identified a series of Local Plan policies, which may have a LSE alone, or in-combination with other Local Plan policies. The coarse Screening process confirmed that the majority of Local Plan policies would individually have a neutral or positive effect on the N2K sites in North Devon and Torridge. Furthermore, it has been concluded that no individual strategic policy, town strategy or development management policy is likely to result in a LSE. The Local Plan Is urban focused and will therefore guide growth towards the most sustainable settlements in the most sustainable pattern of distribution. Given the principally rural nature of northern Devon the areas SACs have been shown to be sufficiently separated ecologically, hydrologically or physically from any specific development that is likely to occur as a result of the adoption of the Local Plan. .

However, the Screening process has also confirmed that Local Plan led development across the Plan period may result in in-direct and secondary effects as a consequence of the overall level of

8 Sustainability Appraisal of Devon Waste Local Plan. Devon County Council. October 2013. http://www.devon.gov.uk/sd02_devon_waste_plan_sustainability_appraisal_report.pdf 9 Habitat Regulations Assessment of the Devon Waste Local Plan. Devon County Council. March 2014. http://www.devon.gov.uk/sd09_habitats_regulations_assessment_final_report-2.pdf 23 cumulative growth in the area’s population. A potential LSE may occur as a result of any one of the following:

 Long-term pressure for farm diversification or changing agricultural practices, changing grazing regimes or pressure to develop new ones;  Increased tourism and recreation, further pressure for recreation on European sites and increasing accessibility, a long-term problem, potentially seasonal in nature;  Housing development increasing long-term disturbance including traffic, demand for water resources and further recreational pressure, increasing pressure on existing infrastructure;  Employment land up-take increasing long-term disturbance including traffic, increasing resource demand, increasing pressure on existing infrastructure;  Long-term increases traffic levels, housing and industrial development and consequently air pollution and noise impact.

It has been demonstrated that the above effects are not a result of individual policies or developments but rather long-term changes in the demographics of northern Devon. It is not possible at this stage to unequivocally state that the cumulative effects of long term population growth as a result of Local Plan led development across the plan period will not lead to a range of LSEs.

The policies in Table 7 have been identified as potentially having a LSE on one or more of northern Devon’s SACs. Consideration therefore must be given to removing policies from the plan or amending them in such a way as to avoid, cancel or reduce the identified effects sufficiently to avoid the risk of further significant effects. The identified impacts and the potential effects of those impacts on the four European Sites are summarised below:

Potential Effects Potentially Identified Policies Can Counter-Acting Amendments be made at Screening to Avoid Sensitive Sites Likely Significant Effects of the Local Plan? Watertable changes in Roadford Water  Braunton ST07, ST08, ST10 and Yes - Avoidance Amendments introduced – Water efficiency measures Resource Zone. Increased demand due to Burrows ST14 cumulatively guide introduced throughout Local Plan to offset impact of new housing new development has the potential to lower  Exmoor and housing growth and development throughout the Roadford Resource Zone in addition to Code water levels either within designated Quantock associated employment and for Sustainable Homes requirements set out in Policy ST05. watercourses or rivers that have hydrological Oakwoods have potential to connectivity to Natura 2000 sites with water  Exmoor incrementally increase  ST02 (1f) – “Reducing water use and increasing its reuse through dependencies. Changes to sedimentation Heaths demand on water resources sustainable water management” levels in rivers and estuaries are possible. throughout the northern  p3.9 – “In addition to incorporating water efficient design principles, Devon. Short, medium and water usage will also be reduced through sustainable water long term impacts. management, such as reuse of rainwater”

 ST03 (1f) – “Adopting effective water management including Sustainable Urban Drainage Systems, water efficiency measures and the reuse of rainwater”  p3.22 – “new developments will need to be designed to increase water efficiency through the reuse of rainwater and other water reduction measures… All residential developments should be designed to use, on average, no more than 105 litres of water/person/day”

 ST05 (2) “New Homes will be expected to meet the Code for Sustainable Homes Level 4, and Level 6 from April 2016 (or successor)

 ST05 (5) – “All new development will be built to a standard, which minimises the consumption of resources during construction and thereafter…(a) demonstrating high standards of energy and water efficiency, including for existing buildings”

Contamination air, water and soil pollution,  Braunton ST07, ST08, ST10, ST14, No – Avoidance Amendments Introduced. Further Appropriate particularly related to traffic volumes on Burrows ST21 and ST22 Assessment Required –The A361 is likely to experience increased traffic A361.Vulnerability to a range of pollutants.  Culm cumulatively guide housing volumes between Tiverton and Barnstaple as a direct result of population Nitrogen oxides, sulphur dioxide and Grassland growth and associated growth across the Plan period as a result of new development in northern ammonia can all contribute to acidification, (Knowstone employment, community and Devon. The A361 bisects Knowstone Moor and will potentially impact on the with nitrogen deposition specifically implicated & Bursden infrastructure provision food-plant of the Marsh Fritillary butterfly with impacts extending up to a in eutrophication. Vehicle exhaust fumes Moors) dictating long-term traffic maximum extent of 200m either side of a busy road. The Local Plan will comprise up to 50% of measured nitrogen growth throughout the continue to support the Devon Wildlife Trust Working Wetlands Project oxide emissions. northern Devon. Localised impacts likely on strategic  P6.14 – “The Working Wetlands Project will facilitate the enhancement roads. Short, medium and of existing Culm Grasslands, reduce fragmentation of the existing long term impacts. habitat network whilst achieving wider environmental benefits by reducing flooding and improving water quality downstream.  Culm Grassland Improvement annotation added to Northern Devon Key Diagram of the Local Plan.

The Working Wetlands Project seeks to improve the integrity of the Culm Grassland SAC and reduce fragmentation of the habitat. Atmospheric pollutants from traffic make up a small proportion of the overall level of pollutants affecting the SAC. Potential increases in traffic may conflict with the aims of the project. Section 8 provides a detailed AA and a substantive analysis of impacts

Braunton Burrows is too far from the A361 and A39 to be affected by vehicle pollutants and will not require further action. The A39 south of Bideford, which passes through Bursden Moor, may experience minor increases in traffic volumes associated with tourist traffic, unrelated to development and will not require further action.

Increase in recreational pressure on land  Braunton ST07 and ST08 No – Avoidance Amendments Introduced. Further Appropriate (e.g. through trampling, the use of motorised Burrows cumulatively guide housing Assessment Required – Substantial new housing development in northern off-road vehicles) can result in soil growth and will contribute to Devon will potentially lead to increased recreational pressure on Braunton compaction and erosion and the disturbance incremental increases in Burrows SAC. Visitor numbers indicate that on average between 30 and 50 of species. visitor numbers and cars a day visit Sandy Lane car park with almost 60% of day trips originating recreational pressure. Short, in Braunton and the surrounding rural villages, with a further 30% originate medium and long term in Barnstaple. The Local Plan supports provision of new Green impacts Infrastructure to support new residential development

 BAR19 (3) – “Land between the Tarka Trail and the A361 north-west of Bradiford Water and land south of the Tarka Trail to the north of Bickington and Sticklepath, as shown on the Policies Map, is identified as strategic accessible natural green spaces where the green infrastructure network will be enhanced through habitat creation, provision of new outdoor recreation and leisure opportunities and improved pedestrian and cycle links to the Tarka Trail”.  P10.83 – “Accessible natural green space between the Tarka Trail and the existing development at Sticklepath and Bickington and to the north- west of Bradiford Water provide opportunities for enhancement of the green infrastructure network through habitat creation or restoration and new outdoor recreation and leisure opportunities…… with potential to become future Local Nature Reserves”

The provision of new Green Infrastructure as informed by the adopted North Devon and Torridge Green Infrastructure Strategy (2013) will help to reduce recreational pressure on existing facilities. Estuary and coastal areas are of special interest and provide a considerable draw to visitors. Provision of new Green Infrastructure may not be sufficient in isolation to prevent additional pressure on Braunton Burrows SAC. Section 8 provides a detailed AA and a substantive analysis of impacts. Non-toxic contamination: New developments  Braunton ST07, ST08 and ST14 No - Counter Acting measures not necessary – The Environment Agency such as housing and employment would Burrows cumulatively guide housing Review of Consents found that the Braunton Burrows SAC was not at risk result in sewage works effluent discharges and employment growth and from toxic or non-toxic contamination via point source discharge to surface that may contribute to increased will contribute to incremental or ground water. The South West Water Resource Management Plan eutrophication. Agricultural land-use increases in sewage concludes that in spite of climate change and the effect of sustainability contributes to effluent discharges. A growth discharges throughout the reductions in the water available for use, levels in the Roadford Water in commercial and recreational use of the northern Devon. Short, Resource Zone remain comfortably above demand plus target headroom water environment raises the likelihood of medium and long term throughout the planning period pollution incidents (e.g. fuel spillage, impacts. emissions). The draft RSS HRA concluded that the receiving waters for discharge are hydrologically separate from this site. Adverse effects on site integrity are not expected.

Physical loss: direct loss through house  Braunton ST07 and ST08 No - Counter Acting measures not necessary – No direct loss of building, coastal and flood defence and other Burrows cumulatively guide housing significant habitats or site integrity is anticipated as a result of the Local Plan development and fragmentation. growth and will contribute to due its the high level strategic nature. Subsequent site-specific allocations Disused/rural buildings can provide valuable incremental increases in and proposals, such as barn conversions or flood defences which present a habitats for protected species and in northern Devon wide perceived significant negative impact will be required to submit a HRA particular bats, which also use established development in both urban precisely identifying the nature, scale and location of the development. ST11 paths for foraging. Land use changes and and rural areas. Short, protects designated sites and guides development elsewhere so as to avoid new development can have significant medium and long term direct loss. negative effects in relation to feeding and impacts migration patterns. Table 7: Final Screening of Local Plan policies

7.1 Next Stages

The screening approach has identified a number of Local Plan policies where there is a possibility for significant adverse effects on the integrity of a number of N2k sites. Table 7 documents the policy amendments that are currently proposed within the Local Plan to avoid, cancel or mitigate for the possibility of a significant adverse effect on a European Site. Identified effects relate to the overall volume of development across northern Devon and the subsequent rise in population and will occur regardless of the spatial distribution or scale of individual developments within the Plan area

The LPA considers that it is not currently feasible to assess alternatives to the sub-regions housing targets in order to prevent potential effects of the total volume of Local Plan led residential and non- residential development over the Plan period. The Local Plan does not allocate any individual development sites which would potentially lead to a LSE on a SAC and therefore amending development scales and locations will have no net impact on the identified effects. Equally, a ‘do nothing’ approach is not a reasonable option given the requirements placed on the Local Plan to meet the projected housing need as required by the NPPF and the Localism Act through the joint Strategic Housing Market Assessment 2012.

The following Appropriate Assessment (AA) provides an appraisal of the current situation and the issues which may arise at each SAC during the Plan period. The AA establishes the current baseline condition of each SAC and estimates the likely level of impact resulting from Local Plan led development. A precautionary principle approach has been adopted for each conservation objective of all potentially affected SACs and a proportionate level of evidence is presented to support the assessments conclusions. The AA concludes that the Local Plan is considered acceptable in terms of its effect on northern Devon’s SACs and that the identified effects are unlikely to be significant.

The HRA/AA will now be submitted to Natural England for consultation and any comments received will be used to amend the Local Plan and HRA/AA prior to formal submission alongside the Local Plan.

8.0 Appropriate Assessment

This section addresses Stage 2 of the HRA process and considers if any of the likely significant effects on European Sites identified through the Screening Stage have the potential to adversely affect site integrity. Policy screening has identified two main areas of impacts that have potential to significantly affect the integrity of an identified European site.

8.1 Culm Grassland SAC Traffic Volume Impacts

Culm Grassland forms part of the UK Biodiversity Action Plan habitat purple moor-grass and rush pasture. In Devon and Cornwall only 8% of that present in 1900 remains, with 62% of sites and 48% of the total area being lost between 1984 and 1991. This habitat has suffered extensive loss and fragmentation resulting from changes in agricultural practice. The chief causes have been agricultural improvement of land by drainage, ploughing, reseeding and fertiliser application; afforestation; abandonment and neglect; management inappropriate for conservation purposes (e.g. overgrazing); and habitat fragmentation. Across the southwest of England only 4,000 hectares remain, or approximately 1.4% of land area.

Knowstone and Rackenford Moors, alongside Hares Down was designated as part of the wider Culm Grassland Special Area of Conservation (SAC) (hereafter to be referred to as Knowstone Moor) due to the internationally significant Culm Grassland communities it supports and also the presence of a Marsh Fritillary butterfly meta-population (a number of interacting populations).

Knowstone Moor is the largest area of diverse lowland-heathland remaining in North Devon. It supports both species-rich and species-poor heaths and some plant associations that are nationally rare. The rich flora and fauna include several uncommon and local species. The site represents a habitat that used to be widely distributed in England but is now very local and confined to the southwest. The heathland overlies the Culm Measures which give rise to nutrient-poor acidic, impermeable soils with local base-rich areas. Much of the vegetation consists of species-rich, wet, dwarf-shrub heath.

Figure 5: Knowstone Moor SAC

Culm Grassland requires positive management in order to retain its conservation interest. Management should maintain an open sward with a diverse vegetation structure that allows a range of different plants and animals to flourish. This is best achieved by light grazing in late spring, summer and early autumn. Cattle are the preferred stock because they have sufficient weight to break down leaf litter and purple moor-grass tussocks but do not graze too tightly. Heavy grazing prevents the establishment of the desired uneven sward structure. However, hill sheep can be used if necessary. An element of managed scrub, both within and fringing a field is of great importance to the characteristic birds and invertebrates of Culm Grassland. Where scrub has spread across a significant proportion of a field, however, it should be cut and removed.

Natural England states that most SSSI units covered by the Knowstone Moor SAC designation are meeting the PSA target and assessed as unfavourable recovering with appropriate management in place to bring about habitat recovery. Units failing to meet specified targets indicate that in some areas the habitat is not being grazed sufficiently and sward height is too high. In some areas the observed level of littler is also too high.

SSSI condition summary – 1st October 2013 % Area meeting PSA target 97.34% % Area favourable 16.17% % Area unfavourable recovering 81.17% % Area unfavourable no change 0.00% % Area unfavourable declining 2.66% % Area destroyed / part destroyed 0.00% Table 8: Knowstone and Rackenford Moors SSSI Condition Summary

Cultivation, new drainage, the application of pesticides including herbicides, lime or of any fertilizer, is damaging and must be avoided. Chemical run-off from surrounding land may also disturb the nutrient balance of the site and management should seek to avoid or minimise any such effect. The rare Marsh Fritillary Butterfly is found on the majority of Culm Grassland sites and the management described above is also beneficial to ensure their continued existence on this site.

8.1.1 Issues Arising from the Plan

Of the 2.2 million tonnes of NO2 emitted by the UK each year about one-half is from motor vehicles. Emissions from road transport currently make the largest contribution to the UK NOX total accounting 10 for some 33% in 2010 . Emissions of NOX are falling slowly in the UK as emission control strategies for stationary and mobile sources are offset by increasing the numbers of road vehicles.

Figure 6 Long Term Roadside NO2 Profile

Figure 6 illustrates there has been a clear decrease in NO2 concentrations between 1996 and 2002. 11 Thereafter NO2 concentrations have stabilised with little to no reduction between 2004 and 2010 . The subsequent consequence of the conclusions of Defra’s advice on long-term trends is that there is now a discernible gap between projected vehicle emission reductions and the overly pessimistic projections on the annual rate of improvements in ambient air quality. Therefore there is some potential that in certain areas ambient air quality may actually improve faster than projected.

There is potential for an impact on air quality and nutrient enrichment as a result of an increase in vehicle emissions associated with the cumulative housing and employment growth that will be delivered through the Plan period to 2031. The proposed level of housing development within the Pre- Submission Local Plan is likely to lead to an overall increase in the population of northern Devon. Any increase in the resident population will likely contribute towards the volume of traffic on northern Devon’s roads. The A361 is part of the strategic road network which connects northern Devon to the M5 at Junction 27 north of Exeter. The road will therefore potentially experience an increase in traffic volume passing through the Knowstone Moor SAC leading to a proportionate increase in vehicle emissions and reduction in air quality.

Although the majority of the Local Plan led development is at least 10km from the SAC it can be expected that some proportion of future traffic growth will be as a direct result of residential and commercial development in northern Devon. It is particularly difficult to estimate the proportion of future changes in overall traffic volumes as a direct result of new development alone.

The HRA/AA of the Devon County Council Local Transport Plan 3 (LTP3)12 states “that there are possible indirect or induced impacts of works proposed to the A39/A361 junction in- combination with Core Strategy policies but that these are being considered in the HRA for that document” and suggests that the “Hare’s Down, Knowstone and Rackenford Moors SSSI is in a 100% Favourable condition”. The HRA/AA does not fully consider general traffic growth on the A361 or the potential impacts on the Knowstone Moor SAC and the Marsh Fritillary butterfly. The HRA/AA recommends evidence collection including habitat assessment, surveys of landscape features, analysis of existing records and traffic modelling for other regional SACs but does not specify a course of action for the Knowstone Moor SAC.

10 Review of Transboundary Air Pollution. DEFRA 2012. http://www.rotap.ceh.ac.uk/sites/rotap.ceh.ac.uk/files/CEH%20RoTAP.pdf 11 Interim Advice Note 170/12 v3. Updated air quality advice on the assessment of future NOx and NO2 projections. DfT 2013. http://www.dft.gov.uk/ha/standards/ghost/ians/pdfs/ian170v3.pdf 12 Stage 2 Appropriate Assessment. Local Transport Plan 3. DCC 2011. 31

The LTP313 states that the A361 to North Devon generally operates adequately but some of the junctions are busy at peak times. In the long term, new housing development in northern Devon could increase congestion - especially at the northern end of the North Devon Link Road. The section of road that is most at risk of reaching capacity is located between the Barnstaple and South Molton areas. Assessments in support of LTP3 show that the road can accommodate modest levels of growth to the east of Barnstaple and in South Molton without significantly disrupting traffic on the A361. However, the road will need some junction improvements in the Barnstaple and South Molton areas. There are a series of junctions on the A361 between South Molton and Tiverton which have the potential to cause safety and congestion issues in the future if they are not carefully managed.

The LTP3 also proposes junction improvement works which are located in excess of 2km from any N2k sites and as such concludes no impacts are likely and that “at this stage it is difficult to assess the in-combination effects of the junction improvements with those of other transport infrastructure works proposed in the Core Strategy. These are being considered by Natural England and whilst in this assessment it is considered unlikely that in-combination effects will occur, this judgement should be revised in the light of any new findings by Natural England in the future”.

8.1.2 How the SAC maybe Affected

The Screening Report has identified the Knowstone Moor SAC as being at potential risk from an increase in vehicle emissions resulting from in-combination development in northern Devon. The effect of a road upon the environment is complex and includes disturbance during construction, and pollution from road material and from the traffic using an established road. There are no planned Highways proposals or individual construction projects in northern Devon which are considered to have the potential to impact on the SAC. The potential impacts can be summarised as follows:

 Increase in animal strikes  Increase in plant and animal disturbance  Atmospheric, terrestrial and aquatic pollution  Deleterious changes in vegetation community  Increase in habitat fragmentation  Sound and visual pollution / disturbance

Deposited nitrogen is acknowledged as contributing to the reduced diversity of plant species per unit area in a range of sensitive habitats of high conservation value over large areas of the UK. Nitrogen deposition on sensitive terrestrial habitats throughout the UK exceeds the critical load in 58% of their area, a value which has hardly changed since the mid-1980s. This figure is only expected to decrease to 48% by 202014.

Emissions from traffic on the A361 have the potential to significantly impact the Knowstone Moor SAC and its interest features. The road dissects the site for approximately 3.2km in total and approximately 2.5km of road is immediately adjacent to designated areas. The road is located on embankment, cutting and also a section of bridge.

Emissions associated with road traffic can increase plant nutrients entering the ecosystem from atmospheric NO3 and CO2 deposition which act as fertilizers, enhancing growth of plants. Culm Grassland relies on its nutrient impoverished status and adding nutrients unbalances the vegetation community; competitive plants grow with increased vigour, out-competing the characteristic Culm plants. The increase in abundance of competitive grasses can be observed at Knowstone Moor SAC as a strip (approximately 30-50m wide) of luxuriant green grass growth adjacent to the road15. If this strip were to extend to the 200m zone of impact the extent of habitat affected would be 84.4 hectares. This calculation takes into account the presence of SAC on both side of the highway in certain locations totalling almost 769 hectares.

The loss of habitat would have an impact on one interest feature, the Marsh Fritillary butterfly. This species requires abundant Devil’s-bit scabious, their caterpillars’ only food-plant. This plant is vulnerable to elevated nutrient levels and will not be found in sufficient abundance in such situations.

13 Local Transport Plan 3. Devon and Torbay Strategy 2011. http://www.devon.gov.uk/dtltp2011-2026strategydoc.pdf 14 Review of Transboundary Air Pollution. DEFRA 2012. http://www.rotap.ceh.ac.uk/sites/rotap.ceh.ac.uk/files/CEH%20RoTAP.pdf 15 Knowstone, Haresdown and Rackenford Moors Mitigation Proposal. Devon Wildlife Trust 2010 32

Extinction rates for the Marsh Fritillary butterfly are dependent on habitat patch connectivity, with increasing fragmentation leading to increased extinction rates. Marsh Fritillary requires 80 – 142 hectares of prime habitat to achieve 95% population persistence. As traffic flows increase a corresponding increase in habitat fragmentation may occur as the grassland habitat changes, jeopardising the status of the butterfly.

8.1.3 The Current Situation

The rescinded South West RSS included a robust evidence base which is still considered relevant as context. The South West RSS HRA16 states that it was not possible to conclude that no adverse effects on site integrity would occur without additional safeguards. The RSS HRA identifies the following existing trends and pressures.

 This site consists of a number of highly fragmented parcels.  Agri-environment schemes are being used to encourage the use or uptake of traditional management techniques which are vital to maintaining the integrity of these habitats.  Many of the site units have been classified as in favourable condition, with others recovering due to burning and the introduction of grazing.  Nutrient enrichment may cause a problem in some locations, either due to deposition or nearby agricultural activity.

The RSS HRA does not specifically identify the Knowstone Moor SAC as being at risk from tourism pressures.

Pollutant Estimated for SAC (2007) Nitrous oxides NOx 0.26 Ammonia NH3 0.21 Nitrogen N 0.98 Sulphur Dioxide SO2 0.08 Acid deposition 2.29 Table 9: Proportion of deposition of pollutants in relation to the Critical Levels/Loads17

Table 9 indicates that in 2007 acid deposition at the site was almost 2.3 times the critical load for calcareous grassland and that Nitrogen levels at the SAC were marginally below minimum critical load limits. The RSS goes on to state that acidifying deposition is generally agreed to have little effect on calcareous grasslands since the calcareous soil provides ample neutralising capacity.

A widely adopted international standard for setting acceptable levels of atmospheric pollutants and deposition rates is the use of critical levels and loads. The Air Pollution Information System (APIS) database provides predictive critical loads for acidity and nitrogen for each designated feature within every SAC and SPA in the UK. Critical levels identify acceptable levels of pollutants in the atmosphere while critical loads identify acceptable deposition levels on different habitats. The sensitivity of designated sites to atmospheric pollutants is dependent on the types of habitat present and the environmental conditions at each site. This means the sensitivity of each European site may vary even if they have the same qualifying features.

APIS identifies that the general level of nitrogen deposition at the Knowstone Moor SAC already exceeds the minimum critical load for acid grassland and minimum critical loads are being exceeded for the habitat Molinia caerulea meadows which supports Marsh Fritillary. It is assumed that the main source of traffic related atmospheric pollution at the site is from passing traffic on the A361 with only a fraction of the overall pollutants arising from visitors to the SAC itself. The site is relatively remote and is not thought to be influenced by any large, individual emission sources. Adopting a precautionary principle approach it is reasonable to assume that projected future increases in traffic volume would increase atmospheric pollutant levels and nitrogen deposition rates at the SAC.

16 Habitats Regulations Assessment of the Draft Regional Spatial Strategy for the South West. SWRA 2007. http://www.southwest- ra.gov.uk/media/SWRA/RSS%20Documents/Technical%20Documents/Technical%20Work/Habitat%20Regulations%20Assess ment/SW_RSS_Final_HRA_Report.pdf 17 Analysis Of Effects Of Air Quality On Natura 2000 And Ramsar Sites In The South West Of England. Appendix 5. SWRA 2007. http://www.southwest- ra.gov.uk/media/SWRA/RSS%20Documents/Technical%20Documents/Technical%20Work/Habitat%20Regulations%20Assess ment/Appendix_5_Air_quality_analysis.pdf 33

Pollutant Critical load / level Estimated for Knowstone Moor SAC (2007-2012) 3 3 Nitrous oxides NOX 30 µg NOx (as NO2) /m 5.3 µg NOx (as NO2) /m 3 3 Ammonia NH3 1-3ug/m 1.71 µg/m Nitrogen N 15 - 25 Kg N/ha/year 18.9 Kg N/ha/year Sulphur Dioxide 20 µg/m3 0.43 µg/m3 SO2 Acid deposition 0.45 – 1.03 keq/ha/yr 1.43 keq/ha/yr Table 10: Critical Loads / levels of pollutants at SS844215 for Acid Grassland.and Molinia caerulea meadows

APIS data was interrogated and Table 10 indicates that total nitrogen deposition exceeds the lower range critical load for Acid Grassland at the roadside within the SAC while overall acid deposition is currently thought to exceed the maximum critical load at this location. Current levels of atmospheric pollutants associated with vehicle emissions (NO2) are significantly below defined limits for this habitat.

Table 9 and 10 indicate that generally the levels of nitrogen and acid deposition at the site have increased slightly since the production of the RSS evidence base in 2007. Although deposition levels have increased, atmospheric concentrations have fallen at this location. Considering national trends in roadside NO2 concentrations, ongoing improvements in vehicle emissions standards and the exposed, rural nature of the site it is likely that the site’s relatively low atmospheric concentrations will continue to fall in line with national trends. The reducing trend in atmospheric NOX and future nitrogen deposition levels in line with national trends suggests that nitrogen deposition at the SAC is potentially a decreasing problem. Although nitrogen deposition levels are unlikely to significantly increase in open, rural areas, past deposition requires ongoing management measures to reduce existing levels of exceedance.

APIS forecasts suggest that Nitrogen deposition from UK road transport is predicted to fall from 50.9 kt/N/yr in 2005 to 19.7 kt/N/yr in 2020. As well as the total level of Nitrogen deposition decreasing by 2020 the sources from which the deposition will arise will also change. Agriculture will continue to be the highest source however deposition from road transport will reduce to less than 5% of the total, compared to a 2005 figure of 5.4%. Comparative sources and percentages of Nitrogen pollution for 2005 and 2020 are summarised in Table 11 as defined by APIS.

Predicted N Deposition 2020 Based on EUP30 Scenario Source N Deposition 2005 Source N Deposition 2020 Source of Pollution % Contribution Source of Pollution % Contribution Livestock production 44.4 Livestock production 62.1

Other sources (individually <5%) 15.8 Other sources 15.9 (Individually <5%) Imported emissions (e.g. from 22.7 Imported emissions (e.g. 14.9 Europe) from Europe) International shipping 6.8 International shipping 7.1 Ammonia from fertiliser use 5.1 Road transport (buses, cars, HGVs 5.4 etc) Table 11: N deposition sources for Hare's Down, Knowstone & Rackenford Moors SSSI - Lowland dry acid grassland

The change in sources of deposition at the SAC can be attributed to lower emissions from new cars and fuels and the gradual reduction of old vehicles on the roads. Difficulties remain in further quantifying how total deposition and locally contributing sources vary on an annual basis at the Knowstone Moor SAC. Despite the long term projections of traffic growth on the roads nationally and regionally Nitrogen deposition from road transport is expected to continue to fall. Positive site management in partnership with local farmers should also continue to improve the situation.

8.1.4 The Potential for Adverse Effects on the Integrity of the Site

The AA for Rother, Wealden, Hastings and Eastbourne Core Strategies18 in respect of the air quality at the Pevensey Levels Ramsar site identified the following methodology that has been adapted for undertaking this assessment with regard to air quality issues at the Knowstone Moor SAC. East

18 Appropriate Assessment and Air Quality Local to the Pevensey Levels Ramsar Site. Rother District Council, Hastings Borough Council, Wealden District Council and Eastbourne Borough Council 2009. http://www.eastbourne.gov.uk/EasysiteWeb/getresource.axd?AssetID=212260&type=full&servicetype=Attachment 34

Sussex County Council predicted a 49% increase in vehicles using the A259 and consequently there was the potential for a likely significant effect as a result of increases in atmospheric NOx concentrations. The study establishes a sound approach to estimating impacts on designated habitat features from Local Plan led growth and the subsequent effects on traffic volumes and air quality:

 Determine what proportion of the SAC is within 200m of the A361.

 Determine the current background NOX concentration using the UK Air Pollution Information System (APIS) and determine whether the current background is beyond the critical level for the key habitats for which the site was designated.  Estimate the relative increase in traffic generation along the A361 by the end of the plan period.  Use the percentage increase in traffic to determine the likely increase in nitrogen deposition.

The Highways Agency19 calculates that beyond 200m from a roadside any increase in local traffic generated atmospheric pollutants is unlikely to have a significant effect on deposition rates and nutrient enrichment.

Figure 6: Highways Agency traffic contribution to deposition rates

Natural England supports the use of this figure as the recommended distance from roadside for the consideration of ecological impacts as a result of vehicle derived atmospheric pollutants. The road dissects the site for approximately 3.2km in total and 2.5km of road is immediately adjacent to designated areas. Devon Wildlife Trust estimates that 84.4 hectares of the SAC habitat could be degraded if the effects of atmospheric pollution were to reach to the extents of the 200m zone.

Historical and current background pollutant levels have been set out in the previous section in relation to APIS derived critical loads and levels and sources of pollutants. Air pollution arising from traffic on the A361 and increases in Nitrogen deposition is a potential significant effect that could arise from the implementation of the Plan. Atmospheric pollutants at the Knowstone Moor SAC have been shown to be significantly below the minimum critical level, however soil deposition levels are currently higher than the minimum critical load. The level of historical deposition is thought to be negatively impacting upon the extremely diverse examples of the Molinia caerulea – Cirsium dissectum fen-meadow which is the habitat for the rare Marsh Fritillary butterfly. Currently JNCC does not consider the Knowstone Moor SAC to be significantly vulnerable to local air pollution20.

Historical traffic flows on the A361

The evidence base for the Devon Local Transport Plan 3 identities relatively small rates of change in the annual average daily traffic flow on the majority of the A361. The exception is area around Barnstaple which is significantly more urban and which is reflected by the +11% increase at Landkey a short distance to the east of northern Devon’s main town. The nearest estimates to historical traffic volumes on the A361 through the Knowstone Moor SAC is at Ash Mill approximately 5km to the west

19 Environmental Impact Appraisal. DfT Tag Unit 3. 2013. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/254128/webtag-tag-unit-a3-environmental- impact-appraisal.pdf 20 Culm SAC Natura 2000 Data Form. JNCC. http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0012679.pdf 35 of the SAC, a section of road which has experienced an average increase of 232 traffic movements daily between 2005 and 2009, reflected by a 2% increase.

Annual Average Daly Traffic A361 Locations 2005 2009 % Change East of Aller Cross 12904 13017 +1 Landkey 16494 18331 +11 Ash Mill 13070 13302 +2 Sampford Peverell 23791 24794 +4 Table 12 Change in traffic flow 2005-2009 on the A36121

It is possible to further quantify the existing volume of traffic on the A361 using estimates from manual, 12 hours, single day, traffic counts which are then repeated annually. The results are then factored to provide an estimate of traffic flow where no observational data is available. Appendix 1 gives a full breakdown of the constituent traffic components summarised below.

Average 2000 - Daily Flow 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2012 All motor vehicles 10038 10128 14635 10842 11438 13759 11940 11170 14328 14250 15754 11214 11195 % Annual Change 0.9 44.5 -25.9 5.5 20.3 -13.2 -6.4 28.3 -0.5 10.6 -28.8 -0.2 11.5

Average 2000- Daily Flow 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2012 Cars 7319 7161 11847 8480 8755 10603 8766 7711 11438 11403 12954 8045 7981 % Annual Change -2.2 65.4 -28.4 3.2 21.1 -17.3 -12.0 48.3 -0.3 13.6 -37.9 -0.8 9.0

Average 2000- Daily Flow 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2012 All HGVs 988 1088 1065 935 846 1200 1104 1071 786 743 871 1133 1113 % Annual Change 10.1 -2.1 -12.2 -9.5 41.8 -8.0 -3.0 -26.6 -5.5 17.2 30.1 -1.8 12.7 Table 13: Annual Average Daily Traffic Flow estimates at Rose Ash on the A361 between Tiverton and Newtown22

Table 13 exhibits substantial fluctuations from year to year for all types of vehicles with isolated years showing significant increases in traffic flow, possibly as a result of seasonal tourism related traffic. The long-term trend as derived from this estimated data indicate a year-on-year increase in total traffic volume over the last 12 years of approximately 1%. The annual change for cars is slightly lower, while the change in HGV movements is slightly higher.

Observed traffic rates can provide further evidence on monthly and annual variations in overall traffic volumes. Devon County Council operates a permanent Automatic Traffic Counter on the A361 at Beaple’s Moor a short distance to the west of the Knowstone Moor SAC. Table 14 provides the observed daily average two-way traffic flow data from 2009 to 2012. Appendix 2 provides the full set of month-by-month data and indicates that 2013 will exhibit a slight rise on previous years, resulting in a similar annual count to that of 2011 but still below that of 2009.

Year 2009 2010 2011 2012 Vehicles 13500 13115 12944 12660 Annual growth - -2.9% -1.3% -2.2% Growth from 2009 - −2.9% −4.1% −6.2% Table 14: Observed annual traffic counts – A361, Beaples Moor

The estimated and observed traffic data presented above clearly shows that there has been very little change in the year-on-year traffic rates experienced in northern Devon and in particular on the stretch of the A361 between Tiverton and Bish Miill. Long-term historical estimates indicate an average annual growth of 1% or as little as a hundred vehicles per annum, while observed data shows an

21 Evidence report - State of Devon and Torbay's Transport 2010. DCC 2011. http://www.devon.gov.uk/ltp3evidencereportfinal.pdf 22 A361 between B3227 and A396 Bolham Road. UK Traffic Data. http://www.uktrafficdata.info/cp/devon-a361-rose-ash-18566 36 average annual decrease of approximately 2% in recent years. The discrepancy between estimated and observed annual flows could be attributed to the recent recession where the number of interurban trips may reduce alongside a move to cheaper modes of travel.

Population and car ownership trends in northern Devon

The trends in traffic flow on the A361 must be set against the context of a population increase in North Devon and Torridge of 6,300 and 4,900 respectively between 2001 and 201123. The Strategic Housing Market Assessment for North Devon and Torridge24 specifies the average household size in North Devon and Torridge and allows an estimate of the number of homes in northern Devon and the approximate rate of change. Table 15 shows that over the past decade 4,841 new homes have been built across North Devon and Torridge which represents 7% of total housing stock.

Average Population increase Housing increase Household Size 2001-2011 2001-2011 North Devon 2.34 6300 2692 Torridge 2.28 4900 2149 Total 11200 4841 Table 15: Population and housing growth in North Devon and Torridge

The 2011 Census estimates that the total existing number of dwellings across northern Devon equates to 67,987. With the additional 16,500 homes proposed in the Local Plan a total of 84,500 homes across northern Devon are estimated for 2031. The Census also provides a ratio of vehicles per household with which to estimate the number of vehicles in the North Devon and Torridge area.

% Total 2011 Total 2031 (68,000) (84,500) Households with no car 19% 0 0 Households with one car 44% 29920 37180 Households with two or more cars 27% 36720 45630 Households with three or more cars 7% 14280 17745 Households with four or more cars 3% 8160 10140 Total vehicles in North Devon and Torridge 89080 110695 Table 16: Vehicles in North Devon and Torridge in 2011 and 2031

Applying the ratios in Table 16 results in a current estimate of approximately 89,080 cars across northern Devon in 2011. Using the above ratios against the additional total housing provision across the Plan period would add a further 21,615 vehicles to northern Devon’s roads by the end of the plan period, a potential increase of 24%. Given that Local Plan led development will follow existing patterns of spatial distribution it is assumed that the growth of traffic on the A361 will be proportionate to the overall rate of growth on northern Devon’s roads. Consequently a projected 24% growth in observed annual traffic counts on the A361 at Beaples Moor (table 14) would result in an increase of around 3,000 on 2012 figures and annual average daily traffic flows of approximately 15,700 by 2031. The estimates presented here assume a flat-line trend in the level of development and consequent growth in vehicle numbers across the Plan period.

Vehicle projections on the A361

Devon County Council have provided TEMPRO modeled data for projected traffic growth on the A361 using the historical annual average daily traffic flow at Rose Ash as shown in Table 13. The modeling assumes a rate of flat growth across the Plan period cumulating in a total provision of 7500 jobs and 16020 dwellings across the whole plan period. The model ignores any future demographic and technological changes and predicts an 18% increase in traffic flow between 2011 and 2031. This equates to a less than 1% annual rate of change and broadly supports the rate of change established by the evidence presented in the preceding paragraphs.

23 Mid Year Population Estimates 2001-2011. Devon County Council. http://www.devon.gov.uk/index/councildemocracy/improving_our_services/facts_figures_and_statistics/factsandfigures/thepeopl e/peopleestandproj/peoplepopestimates/peoplemyedevon2-2.htm 24 Strategic Housing Market Assessment. North Devon and Torridge Update 2012. http://www.northdevon.gov.uk/north_devon___torridge_shma_update_final_report.pdf . 37

A361 Annual Average Daily Traffic 16000

15000

14000

13000

AADT 12000

11000

10000

9000

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 Year

Observed Predicted Figure 7: Projected traffic growth on the A361

The modeled data in Figure 7 suggests that the long-term trend is unlikely to exceed the historical peaks in flow experienced during the past decade. The estimations of future growth in vehicles in northern Devon does not consider the projected national trends in the reduction of household sizes and would potentially result in a significant over estimate of the number of vehicles per household. Furthermore, there is no allowance in the projections for modal-change in vehicle use or economic factors influencing the general cost of motoring in the future. Therefore the total additional number of vehicles on northern Devon’s roads and the subsequent additional number of vehicles using the A361 is likely to be considerably less than the above worst-case projections. External factors beyond the control of the LPA such as annual fluctuations in seasonal visitors will also influence the future use of northern Devon’s roads and add to the annual variation in observed traffic flows.

The Design Manual for Roads & Bridges (DMRB)25 provides a set of criteria to determine whether there is any potential for significant impacts along highway routes. The Local Plan has been assessed against the following criteria:

 Daily traffic flows will change by 1,000 Annual Average Daily Traffic (AADT) or more; or  Heavy duty vehicle (HDV) flows will change by 200 AADT or more; or  Daily average speed will change by 10 km/hr or more; or  Peak hour speed will change by 20 km/hr or more

Both estimated and observed traffic datasets indicate that it is unlikely that any of the above criteria would be exceeded on the section of the A361 between Tiverton and Bish Mill in any year in the Plan period. The projected Local Plan led increase of annual average daily traffic by 2031 of 3,000 equates to a year-on-year increase in annual average daily traffic of 150 movements. Applying the same rate of growth to HGV movements would result in a year-on-year increase of around 14 movements per day. There is currently no indication that the average speed or peak hour speed on the A361 through the Knowstone Moor SAC is likely to be significantly different by 2031.

Despite the relatively modest annual increase of vehicles on northern Devon’s roads the total traffic growth over the entire Plan period leads to annual average daily traffic flow which exceed the DMRB criteria by 2031. Therefore it is considered necessary to carry out more detailed, site-specific assessment using the DMRB Screening Tool26. The screening tool produces an estimate of future atmospheric pollutant concentrations as a direct result of vehicle emissions at receptor locations close

25 Design Manual For Roads and Bridges. Volume 11. Section 4. DfT 2008. http://www.dft.gov.uk/ha/standards/dmrb/vol11/index.htm 26 Design Manual for Roads and Bridges Screening Tool. DfT 2008. http://www.dft.gov.uk/ha/standards/guidance/air-quality.htm 38 to roads. The model requires input data on current and predicted background pollutant concentrations, annual average daily traffic flows, annual average speeds, the proportion of different vehicle types, the type of road, and the distance from the centre of the road to the receptor.

Vehicle emissions and air quality projections on the A361

Site-specific data from Defra’s Local Air Quality Management (LAQM) 2010 background maps27 provide an estimate of future changes in background air quality pollutants at the Knowstone Moor SAC at SS844215. The LAQM data shows a decreasing level of background atmospheric pollutants over the Plan period with a significant decrease in pollutants related to vehicle emissions. Measured concentrations in 2010 at AURN background stations were higher in 2010 than in 2008 and this is reflected in the revised maps. As such the projected background concentrations for NOx/NO2 may actually be higher than expected.

2010 2012 2020 2030

Total NOX 8 7.43 4.98 4.33

Total NOX from A road 1.9 1.7 0.8 0.6

NO2 6.18 5.7 3.89 3.4 Table 17: Defra background maps at SS844215

The DMRB Tool has been run using 2012 Defra background NOX and NO2 levels, which represents the current scenario at the SAC. The relative split of light duty vehicles and heavy-duty vehicles has been calculated from Appendix 1 as 89% and 11% respectively. Annual average traffic speed has been derived from the local speed limit of 60mph, although for the single lane section of the A361 DCC acknowledge this may be significantly less. The existing level of traffic flow on the A361 is factored into the Defra background figures and is considered the baseline against which to assess any future changes in traffic flow and air quality.

The second run of the DMRB Tool has been run using Defra background figures for 2030 and the projected daily traffic flows for 2031 of 15,700. This represents the observed flow at Beaple’s Moor traffic counter for 2012 of 12660 plus the additional traffic flow of around 3,000 anticipated by 2031. The relative split of light duty and heavy duty vehicles is assumed to have remained static, as has the annual average speed. The DMRB Tool outputs when using these figures are presented in Table 18.

2012 2031 3 3 Total NOX 7.43 µg/m 7.8 µg/m 3 3 NO2 5.7 µg/m 4.8 µg/m Table 18: Projected atmospheric pollutant concentrations at SS844215

The APIS defined critical levels for NOX on Acid Grassland and Molinia caerulea meadows at 3 SS844215 is 30µg NOX (as NO2) /m . Table 18 clearly shows that NO2 levels fall from the current baseline and remain significantly below the critical level for atmospheric concentration when factoring in the projected growth in traffic on the A361. The DMRB Screening Tool indicates that there is a significant tolerance to atmospheric NOX as NO2 from vehicle emissions at the Knowstone Moor SAC. The DMRB Tool suggests that an increase in traffic volumes many hundred times the level of that resulting from Local Plan led development would be required to reach the critical level NO2 for the habitat supporting the interest feature Marsh Fritillary butterfly.

The Department for Transport states the rate of Nitrogen deposition from atmospheric concentrations of NOX as NO2 can be calculated using the conversion factor of 1 μg/m³ of NO2 = 0.1 kg N 28 hectare/year . It is therefore assumed that as atmospheric concentrations of NO2 are predicted to have decreased by 0.9 µg/m3 by 2031, then nitrogen deposition from vehicle emissions will have decreased by 0.09 kg Nitrogen/hectare.

The Nitrogen deposition levels for Acid Grassland and Molinia caerulea meadows at SS844215 is currently 18.9 Kg N/ha/year and currently exceeds the minimum critical load of 15 Kg N/ha/year. Local

27 2010 Based Background Maps. Defra LAQM. http://laqm.defra.gov.uk/maps/maps2010.html 28 Design Manual For Roads and Bridges. Volume 11. Section 3. DfT 2007. http://www.dft.gov.uk/ha/standards/dmrb/vol11/section3/ha20707.pdf 39

Plan led development and a subsequent worst case scenario increase in daily traffic flows of 3,000 by 2031 would lead to a marginal decrease in Nitrogen deposition associated with vehicle emissions. The projected decrease in nutrient enrichment at roadside locations within the SAC would be set against the continuing trend of national and regional improvements in emission standards and air quality and ongoing investment in Culm habitat management and restoration. Given the continuing improvements in national air quality standards and vehicle engine technology it is assumed that the concentration of vehicle generated atmospheric NOX and NO2 is likely to continue to decrease annually.

8.1.5 Avoidance, Mitigation and Compensation Measures

The HRA/AA has concluded that no individual Local Plan led development will have a significant impact on interest features of the Knowstone Moor SAC within 200m of the A361. There is not considered to be any merit in the drafting of hierarchical mitigation measures to be applied in a lower tier plan. It is probable that each strategic housing site in isolation will only marginally add to population growth and the overall volume of traffic on northern Devon’s roads. Given the difficulty in modeling and monitoring small changes in air quality from individual developments it has been considered more appropriate to assess the overall effects of all development in northern Devon.

It is not currently considered possible to completely avoid or mitigate against the projected increases in traffic flow on the A361 associated with the adoption of the Local Plan. Despite predicgted traffic growth concentrations of pollutants within the atmosphere and habitat at the Culm SAC are estimated to remain well within defined limits. Examples of avoidance and mitigation measures, which at this stage are deemed either inappropriate or ineffective in dealing with the in-combination effects of cumulative developments are as follows:

Avoidance/Mitigation Measures Justification Deletion of the policy or proposal that may Duty to meet the Local Plan’s areas’ objectively assessed cause the likely significant effect needs in accordance with NPPF p14 – presumption in favour of sustainable development means that strategic growth policies cannot be deleted Changing the nature or type of a potentially Local Plan seeks to provide most sustainable pattern of damaging proposal development across northern Devon while minimising the impact of individual proposals but cannot influence the in- combination effect of the overall level of development Reduction in the scale of the potentially No individual proposal is considered to potentially result damaging provision, whether it be an in a likely significant effect on a SAC. Reductions in the overall level of growth across all or part of proposed overall level of growth is likely to be considered the plan area, or a single proposal of a unsound and not deliver the socio-economic benefits specific scale or size; required. Relocation or alteration of the spatial The spatial context of growth in northern Devon will follow distribution of the potentially damaging existing patterns of development and relocation within provision; northern Devon will have no effect on changes in traffic patterns on the strategic road network Phasing or timing of a proposal so that its For the purpose of the AA a flat line of growth has been possible effects can be adequately assumed across the Plan period, resulting in a slight, but managed over time; steady increase in traffic flow. This provides ongoing opportunity to manage impacts through site specific projects such as Working Wetlands Programming a proposal so that it is Significant highway infrastructure proposals are not dependent on key infrastructure provision considered to be an appropriate or effective way of or upgrading, such as water supply or addressing air quality at Knowstone SAC and would waste water treatment, being in place potentially necessitate a complete rerouting of the A361 before it could proceed; Requiring buffer zones to be put in place. No development is proposed within the proximity of Knowstone SAC and therefore buffer zones would be an ineffective course of action. Table 19: Culm Grassland SAC Avoidance and Mitigation Options

Given the sub-regional importance of the A361 it is not possible to actively manage individual components of the overall traffic composition. The route experiences commuting, tourism and heavy goods traffic throughout the week and weekend. There is no immediate opportunity to review the regional road hierarchy, or to encourage a shift to the local road network, which would likely result in further adverse impacts on the local area and Knowstone Moor SAC.

Introducing traffic calming measures, speed restrictions and speed cameras on the A361 could potentially reduce speeds, and therefore emissions but would not reduce the overall volume of traffic on the road. The vast majority of traffic on the A361 passes through the SAC freely with the nearest frequently experienced congestion around Tiverton several kilometers to the east. The AA has set out projections in car ownership in northern Devon and subsequent trends in vehicle movements and emissions on the A361. It has been concluded that despite the projected growth in traffic flows, Local Plan led development will have a negligible impact on atmospheric air pollution and future deposition loads at the Knowstone Moor SAC.

8.1.6 Summary and Conclusions

JNCC site-specific information does not indicate that atmospheric pollution is currently having an adverse effect on the site’s qualifying features. It appears that the site receives the majority of nutrients from sources associated with farming and general land management. The Local Plan has been considered alongside other plans and programmes to establish the potential for any in- combination effect of trans-boundary development which may result in a potential increase in emission levels and background atmospheric pollutants at Knowstone Moor SAC. The AA has drawn together the existing evidence base relating to the condition of the Knowstone Moor SAC and anticipated future trends in traffic volumes, traffic related emissions and atmospheric deposition rates. The following provides a summary of the preceding sections and concludes that there is unlikely to be a significant adverse impact on the integrity of the SAC as a result of increases in the vehicle volumes on the A361 over the Plan period.

 APIS estimates at SS844215 for Acid Grassland and Molinia caerulea meadows 2007- 2012 for atmospheric (NOX) and deposition (N) – (p8.1.3) 3 3 o NOX (as NO2) Estimated 5.3 µg /m (Critical Level 30 µg /m ) o Nitrogen Estimated 18.9 Kg N/ha/year (Critical Load 15 - 25 Kg N/ha/year)  APIS estimates that by 2020 road transport will contribute less than 5% of N deposition at Hare's Down, Knowstone & Rackenford Moors SSSI for Lowland dry acid grassland, down from 5.4% in 2005.  Traffic flow on the A361 has been shown to be growing by approximately 1% per annum and is projected to continue to do so across the Plan period to 2031 (p8.1.4)  Population estimates and housing projections show that under a worst-case scenario there is likely to be a 24% growth in vehicle numbers across northern Devon as a result of Local Plan led development.  A 24% growth in observed traffic flows on the A361 would result in an increase in annual average daily traffic flow of approximately 3,000 vehicles. Therefore 2031 annual average daily traffic flow are estimated at 15,700 following Local Plan led development.

 DMRB Tool run using DEFRA LAQM 2010 background map projections for 2030 of NOX 3 3 (4.33 µg/m ) and NO2 (3.4 µg/m ) with additional average daily traffic flows of 3,000. The 3 3 projected 2030 levels are 7.8 µg/m for NOX and 4.8 µg/m for NO2.  This can be seen to be a significant decrease in NO2 over the background levels for 2012 of 5.7µg/m3. Any decrease in projected atmospheric pollution associated with the site would clearly result in no increase in deposition levels arising from traffic emissions at the SAC.  Numerous worst-case assumptions regarding growth in traffic rates, average speed and background emissions result in atmospheric projections of NOX as NO2 considerably below levels which would degrade the Culm SAC interest features.

The LPA therefore concludes that there is no adverse effect on the integrity of the Culm SAC as a direct result of the Local Plan alone or in-combination with other identified plans and programmes. However, the Local Plan will continue to support the Devon Wildlife Trust Knowstone, Haresdown and Rackenford Moors Special Area of Conservation (SAC) Mitigation Proposal (Appendix 3) independently of the findings of the HRA/AA report. The proposal is a fully evidenced and costed proposal for ongoing management and restoration aimed at reducing habitat fragmentation and increasing the resilience of the Marsh Fritillary butterfly. The predictions of future vehicle flows and emissions and the extent to which these are linked to development will enable greater confidence in improving the integrity of the SAC in the future.

Policies aimed at improving sustainable transport options and nationally adopted targets for reductions in emissions will continue to drive down overall emission levels associated with road transport. Nitrogen deposition from road sources are likely to continue to drop, both in terms of overall levels and 41 as a overall percentage of contributing factors. However, improvements in national and regional air quality are to some extent likely to be counteracted by projected long-term increases in overall traffic volumes and associated atmospheric pollutants. Therefore the management of general growth in traffic over the Plan period is a priority which will be addressed within numerous Plan policies. The LPA considers that the Local Plan can contribute towards the reduction of air pollution and general traffic related impacts regionally by:

 Requiring the construction of major development to be of the highest feasible standard  Strategically locating new development in order to reduce the overall necessity to travel and to support sustainable transport options  Supporting pedestrians and cyclists through the provision of appropriate recreational facilities and green space  Adopting a sustainable approach to parking standards, including the appropriate provision of park and ride facilities.  Encouraging and assist communities to provide electric vehicle charging points.  Continuing to work with Devon County Council as the highway authority to continue appropriate highway improvements across the County.

8.2 Braunton Burrows SAC Increase in Recreational Pressure

Braunton Burrows is one of the largest dune systems in Britain, about 5 km long north-south and 1.5 km wide, with lime-rich dunes up to 30 m high, and an extensive system of variably-flooded slacks, grassland and scrub, inland of a wide sandy foreshore. There is thus a variety of habitats for many flowering and lower plants, and for many birds and invertebrates. Several species are nationally rare or vulnerable.

Braunton Burrows is a key site for coastal geomorphology. It is one of the three largest sand dune systems on the west coast of Britain and the one least affected by underlying geology and afforestation. It is also important for its diversity of form and has the greatest height range of any west coast dune system. In the central part of the Burrows where the highest dunes occur (up to 30 m OD) there are three main parallel ridges, separated by slacks and fronted by a line of foredunes. To the north and south the structure of the dunes is influenced by Saunton Down and the Taw-Torridge Estuary respectively, while to the east there is an extensive area of low dunes and slacks. The legacy of major blowouts is also apparent. There is a good documentation of post-war changes in dune form, and cartographic records extend back to the beginning of the 19th century. This is one of the best documented dune systems in Europe. Academic research is undertaken on the physiography of the system, and on the ecology of several groups of plants and animals. Applied research is carried out on various methods of maintaining and enhancing the value of the site.

Figure 8: Braunton Burrows SAC 42

Without management intervention, a mix of dune scrub and woodland may eventually replace the habitats on stable areas of the dune system. Selective scrub management and grazing or mowing may be necessary. Light livestock grazing, at levels informed by grazing experiments, will prevent the invasion of scrub and retain open sand dune communities. Intensive stocking levels and supplementary feeding, leading to severe poaching of soils by livestock and nutrient enrichment, will not usually be acceptable.

Many of the vegetation types supported by sand dunes are fragile and vulnerable to erosion from heavy trampling or disturbance. Where activities are significant enough to result in the loss of vegetation cover and prevent recovery, it may be necessary to take steps to manage access by putting boardwalks in or controlling activities in vulnerable areas such as the fore dunes. Where pressure is not severe, the impact of trampling and disturbance can help to retain diversity on the site – sandy tracks break up the vegetation sward and provide areas of bare sand, thus increasing the diversity of habitats available. Recreational and other activities are listed as operations which, if sufficiently intensive, are likely to damage or disturb features of special interest including the sand- dunes.

SSSI condition summary – 1st April 2014 % Area meeting PSA target 92.87% % Area favourable 24.79% % Area unfavourable recovering 68.08% % Area unfavourable no change 0.00% % Area unfavourable declining 7.13% % Area destroyed / part destroyed 0.00% Table 20: SSSI Condition Summary

The single SSSI unit within Braunton Burrows SAC which is considered to be in an unfavourable and declining condition is Unit 107 which covers 95 hectares centred on Crow Point and the Neck at the mouth of the estuary. Natural England considers the area to be in decline due to inappropriate coastal management and the historical realignment of the shoreline defences.

An active programme of management has been implemented in recent years to halt the loss of the most species-rich dune habitats at Braunton Burrows. Much of this work has been funded by the current Higher Level Scheme agreement. Excavations have been carried out to recreate many of the important wet slack habitats that were becoming overgrown with scrub and gradually drying out, thus threatening the survival of several rare species such as water germander, petalwort and the amber sand bowl snail. Large areas of herb rich turf are now being maintained by a combination of scrub clearance, mowing and grazing. The habitat and species diversity on Braunton Burrows has been enhanced by the creation of 31 ponds within the dune system and these need to be periodically managed to conserve the different successional stages with their characteristic plant and animal communities that include specialities such as the crested newt.

8.2.1 Issues Arising from the Plan

Current management of the Burrows is carried out by Christie Estates through Natural England's Environmental Stewardship Scheme. The aim of the management is to maintain and increase the biodiversity of the dune system with a focus on specific species that are very rare or under threat of extinction nationally or locally. Successful management of the Burrows is dependent on an understanding of natural processes as well as on the impact of human activities.

Increased recreational activity has the potential to cause disturbance to designated habitats and species through a variety of different pathways. The revised HRA Screening Report of the Joint North Devon and Torridge Local Plan found that there is potential for an Increase in recreational pressure on sensitive sites (e.g. through dog walking, trampling, the use of motorised off-road vehicles) within northern Devon as a result of the cumulative housing growth that will be delivered through the Plan period to 2031.

8.2.2 How the SAC maybe Affected

An increasing local population may contribute to incremental increases in visitor numbers and recreational pressure leading to degradation of specific sites. The Screening Report has identified Braunton Burrows SAC as being at particular risk from a potential increase in visitor numbers, specifically as a result of the growing population of northern Devon. Recreational access and associated visitor pressure can lead to various impacts including trampling, increased fire risk, erosion, spread of disease and nutrient enrichment. Given the unique environment, assorted recreational opportunities and the spatial distribution of proposed development there is considerable difficulty in quantifying changes in visitor numbers as a direct result of residential development over the Plan period. Northern Devon has a strong seasonal tourism trade focused around the coastal resorts of Westward Ho!, Saunton, Croyde and Woolacombe. This results in large seasonal fluctuations in population although this can not be directly related to Local Plan led development and the subsequent growth of the local population.

Total visitor numbers to Braunton Burrows SAC are difficult to quantify given the geographic scope of the area with numerous potential access points including Saunton Beach car park, Crow Point car park and Sandy Lane car park. While it is clear there will be some impact on the SAC from increased visitor numbers to both Crow Point and Saunton Beach, it is assumed that the primary attraction for visitors to these areas is the beach and access to the estuary and sea. Therefore for the purpose of this study it is considered that an increase in the number of visitors to the area’s two most popular access points will have little impact on the SAC’s habitats and the sensitive species it contains.

The car park at Sandy Lane provides direct access to the centre of the SAC and is a considerable distance from both the western facing beach and the estuary. Given the difficult terrain and the distance to the beaches it is assumed that visitors to this area are most likely to remain within the dune system in order to enjoy the immediate environment, rather than to access the more peripheral, coastal regions of the designation. Therefore it is assumed that as a result of increased visitor numbers to Braunton Burrows the environment around Sandy Lane car park is the area most likely to suffer an adverse significant effect.

Future development may lead to an increasing number of dogs being exercised on the Burrows. Dog faeces add significant amounts of nutrients to the soil potentially resulting in a reduction on plant diversity especially around Sandy Lane car park. Numbers of ground nesting birds have also declined in this area and this is thought to be largely due to disturbance by dogs.

8.2.3 The Current Situation

The Biosphere Reserve Partnership has compiled a set of data to assess the nature of visitor trips to Braunton Burrows SAC in the area surrounding Sandy Lane car park. Table 21 contains a summary of the place of residence of those surveyed and the total number of visits per annum based on stated frequency of visits. A full set of survey data is available in Appendix 4.

Place of Residence Total Visits % Total per Annum Visits A Braunton (inc. Wrafton, Saunton, Knowle, Croyde, Georgeham, Woolacombe) 7704 59.80 B Barnstaple (inc. Bradiford, Fremington, Newport, Pilton, Roundswell, Sticklepath, Landkey, Muddiford) 3698 28.71 C Bideford (inc. Appledore, Instow, Westward Ho!) 526 4.08 D Ilfracombe (inc. Combe Martin, Lynton, West Down) 474 3.68 E Hartland (inc. Abbotsham, Bude, Clovelly, Parkham) 455 3.53 F All other areas (outside of northern Devon) 13 0.10 G South Molton 12 0.09 Total 12862 100 Table 21 Sandy Lane car park, Braunton Burrows summary visitor figures

The figures are grouped into the areas surrounding northern Devon’s main settlements to give a clear picture of the average distance travelled by visitors when accessing the Sandy Lane car park at Braunton Burrows.

A SL B

C G E

Figure 9: Place of residence of visitors to Sandy Lane car park, Braunton Burrows

Table 21 indicates that almost 60% of day trips to Sandy Lane car park originate in Braunton and the surrounding rural area. This is predominantly the coastal area surrounding the northern edge of the designation with those questioned having travelled relatively short distances and visiting on a semi- regular basis. The Local Plan has a planned provision for 380 dwellings and 10 hectares of employment land in Braunton and Wrafton during the period 2011-2031. A relatively low level of growth in the nearby rural villages of Croyde, Georgeham, Knowle and Woolacombe will add a further 119 dwellings. At 2.34 residents per household, the provision of approximately 500 new dwellings would result in 1170 additional residents over the Plan period. The 2011 Census provides a population count for Braunton and nearby rural villages in the region of 16,000 residents. Therefore new development is likely to account for a 7% increase in the population between 2011-2031 in Braunton and these rural villages.

Table 21 also indicates that a further 30% of day trips to Sandy Lane car park originate in the Barnstaple area. This area is considerably further from the Sandy Lane car park area of the SAC although those surveyed are still likely to visit on a semi-regular basis. The Local Plan has a planned provision for approximately 4,311 new homes and 33 hectares of employment land for the Barnstaple and Fremington area during the period 2011-2031. This is in addition to a relatively low level of growth in the nearby rural villages. This is likely to result in approximately 10,000 additional residents in the Barnstaple and Fremington area as a result of new strategic development in the Plan. The latest Barnstaple area (including Bickington, Landkey and Bishops Tawton) population estimate is in the region of 50,000 residents; therefore new development is likely to result in a 20% increase in the population between 2011-2031.

A record of daily car park tickets issued at Sandy Lane car park for the period between 31st March and 9th October 2012 is available in Appendix 5 and shows that the number of visits varies from day to day but exhibits relatively little seasonal fluctuation. A broad approximation of car park use throughout spring and summer and autumn would be in region of between 30 and 50 vehicles daily. This would lead to an estimate of between 11,000 and 18,000 cars using Sandy Lane car park annually. Many of these vehicles are likely to be low or single occupancy local dog walkers, trekkers and people taking regular exercise.

Adopting the precautionary principle and informed by the proportion of visitors from each area defined in Table 21 it is possible to estimate additional traffic load at Sandy Lane car park as a result of Local Plan led development. Under a worst case scenario, of the estimated 18,000 vehicles using Sandy Lane car park annually, 60% (10,800) are assumed to be from the Braunton rural area, with a further 30% (5,400) from the Barnstaple area. An estimated 7% growth in population in the Braunton area would result in an additional 756 car visits per annum by 2031, an average 2 per day. An estimated 20% growth in population in the Barnstaple area would result in an additional 1,080 car visits per annum by 2031, an average of 3 per day.

Assuming the worst case scenarios for existing and projected vehicle use at Sandy Lane car park it can be seen that Local Plan led development is estimated to result in an additional 1,836 vehicles per 45 year or, on average 5 vehicles per day by 2031. Therefore it can be assumed that any increase in footfall within the SAC is likely to be relatively small with related impacts occurring in close proximity to Sandy Lane car park.

8.2.4 The Potential for Adverse Effects on the Integrity of the Site

National experience has shown that coastal and estuarine sites have the potential to result in a significant draw. However a large proportion of visitors to the coastal fringes of Braunton Burrows SAC are seasonal tourists the majority of whom are beach goers and water users and are unlikely to spend any significant amount of time within the dune system. Local residents will be generally indistinguishable from the large numbers of seasonal visitors at Saunton Beach and Crow Point. Recreational pressure has not been identified as one of the key issues to which the site is vulnerable by JNCC29 or the RSS30 evidence base which indicates that the vast majority of visitors to the SAC will be primarily engaged in beach related activities in the coastal fringes.

Sandy Lane car park provides a cheap and relatively convenient point of access to visitors to Braunton Burrows. Both local and seasonal visitors would have to travel further and pay a parking premium to access the coast and therefore it is considered unlikely they would encroach into the dunes far enough to have a significant impact on any interest features of the SAC. While the overall number of visitors to Sandy Lane car park is relatively small, visits are frequent and likely to be made up of dog walkers, people taking exercise and people looking to experience the natural environment. At approximately 2kms from the nearest coastal area visitors here are generally not beach goers and are likely to spend a significant proportion of their visit within the dune system itself. Residents living in the local area have been identified as the most regular visitors and therefore new development in areas adjacent to the SAC will result in the largest increase in visitor pressure.

Future annual increases in the number of visitors using the Sandy Lane car park are likely to be made up of local residents from the Braunton and Barnstaple areas as defined in Table 21 and Figure 9. While there will clearly be additional visitors to the SAC who originate from outside of northern Devon these are predicted to make up only a small fraction of the overall numbers. The figures presented suggest that residents from the Braunton area make up a substantially greater proportion of total visitors to the Sandy Lane car park than those from Barnstaple. However, given the spatial distribution and the higher levels of development anticipated in Barnstaple as the sub-regional centre it is estimated that the growth in Barnstaple’s population is likely to lead to a rise in regular visitor numbers broadly equivalent to that originating from the Braunton area.

The projected increase in regular visitors to the SAC from Braunton and the rural area immediately around Braunton Burrows is the result of relatively low levels of Local Plan led development in numerous villages across a wide area. As such there are no appropriate means of avoiding an increase of visitors to the SAC without restricting the current level of access enjoyed by the public. Therefore it is crucial to consider an appropriate level of onsite management to mitigate against any potential adverse impacts arising as a result of future increases in visitor numbers. The aim of any proposed avoidance or mitigation measures would be to promote greater awareness of the site’s sensitivity and encouraging increased visitor responsibility.

8.2.5 Avoidance, Mitigation and Compensation Measures

Recent HRA Guidance for Plan Making Bodies in Scotland31 commissioned by Scottish Natural Heritage states that “the plan-making body should consider whether there are any straightforward mitigation measures that could be incorporated into the plan, so that the plan can then be screened again” including “programming a proposal so that it is dependent on key infrastructure provision or upgrading”. The importance of avoidance and mitigation measures at early stages of the plan-making process is underlined and encourages headline policies to be amended in such a way as to “to introduce measures to eliminate or reduce” any identified likely significant effect.

The identified growth in visitor numbers at Sandy Lane car park has been estimated to be relatively minor and unlikely to have a significant effect on integrity of the SAC. There is some uncertainty regarding current activity and the associated visitor impacts. Despite this the Local Plan should set out recommendations to ensure development does not result in a future adverse effect on Braunton

29 Braunton Burrows SAC. JNCC http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUCode=UK0012570 30 South West RSS HRA. South West Regional Assembly 2007. http://www.southwest-ra.gov.uk/nqcontent.cfm?a_id=2655 31 Habitats Regulations Appraisal of Plans. Scottish Natural Heritage 2012. http://www.snh.gov.uk/docs/B1116296.pdf 46

Burrows SAC as a whole. The Thames Basin Delivery Framework has defined a series of zones which can be translated into the Local Plan. There is no proposed single development within 400m of the SAC or within easy travel distance that would lead to any unavoidable significant effect. No residential development should be permitted within 400m of the SAC boundary and beyond 400m a series of measures must be identified which as a package will aim to remove potential adverse effects associated with Local Plan led housing and employment development. Between 400m and 5km onsite mitigation will be required through developer contributions, with larger development beyond the 5km boundary requiring individual appropriate assessment.

Onsite mitigation requires careful consideration of any unintended adverse impacts on the ecology of the SAC. Some monitoring, maintenance and interpretation is already in place but will be needed to be drawn together in the form of a coherent access management strategy. While visitors to the SAC are likely to value the Burrows and its wildlife there may be insufficient information available to enable them to appreciate potential impacts of their activity. There is clear scope for additional guidance, interpretation and better communication with users to ensure successful implementation of measures. Any emerging management strategy should be fully evidenced to identify the most appropriate onsite management measures, for example:

 Car park measures  Visitor monitoring  Dog warden and visitor management  Dog-waste removal contract  Regular maintenance of any gates  Interpretation and information boards and facilities  Fencing and boardwalks to reduce impact on dune system

Dog bins are already provided at Sandy Lane car park and further education and information could be provided for dog owners to help to reduce their impact. It is possible that existing fenced areas are already helping to reduce disturbance and allow sensitive parts of the site to recover. A review of car park related measures including parking charges at Sandy Lane car park could be taken forward and reviewed as part of an integrated access strategy within the Biosphere Management Plan.

Currently implemented measures such as the boardwalk, marked routes and education/awareness raising are helping to reduce the present level of visitor impacts to the SAC. Further bye laws could be used to restrict access to dog walkers to certain areas, to ensure visitors pick-up after their dog and to keep dogs on short leads at all times within the main dune area.

Restricting dog walking to specific locations would be one potential way of keeping visitors away from areas containing the most sensitive habitats within the SAC, but may result in the concentration of dog walking in other areas. Where it is not considered necessary to completely restrict dog walking, the Dog Control Orders Regulations can be used to control failing to remove dog faeces; not keeping a dog on a lead; not putting, and keeping, a dog on a lead when directed to do so by an authorised officer; permitting a dog to enter land from which dogs are excluded; and taking more than a specified number of dogs onto land.

Wardening of locations considered to be most sensitive to visitor impacts can be effective in reducing disturbance, particularly if the wardens are able to advise of and enforce byelaws and other statutory measures (e.g. SSSI legislation). A visible presence in the Burrows and the potential to talk directly to people to explain changes is likely to be important in effectively implementing further management measures.

There are various ways that this can be achieved  Face to face contact on site with access users, for example by wardens  Websites promoting access in particular areas, directing use and raising awareness  Direct contact with clubs and groups: for example through attending club meetings and events.  Interpretation and signage  Articles in the local press and media  Leaflets  Ongoing monitoring of habitat status and recreational patterns

Evidence suggests that dog walkers are generally accepting of measures aimed at drawing them to alternative, less sensitive sites. Any provision of alternative sites would need to be attractive to dog walkers and include sufficient open space containing circular walks and the ability to let dogs off leads. Wardens, dog bins and surfaced pathways are also considered attractive features. Any new site could be promoted to dog walkers through leaflets, interpretation boards and face-to-face contact.

The Local Plan seeks to provide an appropriate level of strategic green infrastructure in accordance with the North Devon and Torridge Green Infrastructure Strategy32. Parks officers from both Torridge and North Devon suggest that overall, in terms of parks and green spaces provision there is no significant shortfall in the quantity of provision but quality is variable with a need for improvement in many areas. Priorities for open space improvements as a result of development would be to improve existing facilities rather than the provision of new ones. Green space requirements and cost estimates are provided in Appendix 6.

8.2.6 Summary and Conclusions

The following provides a summary of the preceding sections including presented information which leads to the conclusion that there is unlikely to be a significant adverse impact on the integrity of the SAC as a result of increases in visitor pressure over the Plan period.

 93% of site meeting PSA target with 68% unfavourable recovering and 25% favourable  Small area (7%) at the mouth of the estuary considered to be in an unfavourable declining condition due to inappropriate coastal management practices (p8.2).  Three access points to the site including Saunton Beach car park, Crow Point car park and Sandy Lane car park. (p8.2.2)  Relatively small number of visitors to Sandy Lane car park considered to have the highest potential to significantly impact SAC interest features within the dune system through dog walking, trekking, exercise, etc.  Relatively large numbers of visitors to Saunton and Crow are primarily beach goers and water users and consist of large proportion of seasonal tourists. Small fraction of visitors to these areas may enter the dune system close to coastal fringe but not in significant numbers.  Biosphere visitor survey (Appendix 4) indicates that approximately 60% of visits to Sandy Lane car park originate in Braunton and the rural villages in close proximity to the SAC, with a further 30% originating in the Barnstaple area. (p8.2.3)  Sandy Lane car park usage between March and October 2012 average approximately 30 to 50 vehicles per day. (Appendix 5)  Using the visitor survey data it is estimated that Local Plan led development in these areas is estimated to lead to a 7% increase in visits originating from the Braunton and rural villages area, and a 20% increase in visitors originating from the Barnstaple area.  Using the car park data this level of growth would potentially lead to an increase of 756 visits per year from the Braunton area, and 1.080 visits per year from the Barnstaple area.  As a result of Local Plan led development a worst-case projection would lead to an estimated 1,836 additional vehicle visits per year, which equates to a modest increase on average of less than 5 cars per day by 2031.

Given the uncertainties in the existing visitor data it is recommended that future management at Sandy Lane car park should be coordinated strategically by Natural England working with the Local Authority and land managers to deliver an appropriate set of management measures for the SAC. Management measures should offset the potential effects of any Local Plan led development and ensure no net increase in visitor related recreational impacts over the Plan period. Measures should be proportional to any potential effect even if the implementation has beneficial consequences for both existing and new recreational pressure.

The Local Authority will develop the existing evidence base and implement a management strategy for the SAC to avoid impacts from increased recreational use. The strategy should be supported by a robust evidence base compiled through strategic monitoring which addresses current and future habitat condition, access management and visitor surveys. Management measures should focus on soft measures such as use of wardens rather than closures or restrictions. The Local Plan will support the development of the existing evidence base to further understand the potential for visitor impacts at Braunton Burrows SAC:

32 Green Infrastructure Strategy. North Devon and Torridge District Councils. 2013. 48

 Develop evidence relating to the number and frequency of visitors to the SAC  Understand where people go within the SAC and the activities they participate in  Develop a profile of where visitors live and how they access the SAC  Develop onsite management options which can reduce the potential impacts of increased levels of recreation

Specific work is already underway to understand the effects of North Devon and Torridge’s growth on the Braunton Burrows SAC. This includes Natural England’s draft Site Improvement Plan and the ongoing work of the Biosphere Reserve Management Team. The conclusions will be used to inform the management strategy and the measures that are necessary to avoid any potential adverse impacts arising from an increase in visitor pressure.

The LPA will adopt a joint strategy with Natural England and other stakeholders to establish a mechanism to co-ordinate the collection of developer contributions through the Community Infrastructure Levy and Infrastructure Delivery Plan. An initial step in the process will be to cost the contributions required to offset the identified level of impacts relating to visitor pressure. There is the potential for developer contributions to be used for this initial exercise as well as for the development and implementation of the subsequent management strategy. The overall objectives of the emerging visitor management strategy should include:

 Achieve a wide understanding amongst all users of the implications of the designated sites  Achieve favourable condition status of the SAC and SSSIs  Produce and implement an integrated monitoring plan for the designated sites  Ensure recreational access and use do not adversely affect the designated sites  Develop an effective strategy for ensuring that the disturbance caused by recreational activities is minimised  Develop and implement a flexible and responsive framework for recreation management  Understand the effects of military and recreational activity on the Burrows  Ensure that consistent approach to interpretation of the many qualities of the Burrows is created  Improve education and interpretation facilities around the Burrows  Encourage co-ordination between ongoing monitoring and develop partnership where possible.

Additional text has been added to the Local Plan at

4.37 North Devon’s Biosphere Reserve is the only new style Biosphere Reserve in England and the first to be designated in the UK. The Core Area is managed primarily for conservation of biodiversity and is defined by the Special Area of Conservation that comprises Braunton Burrows and part of the Taw-Torridge estuary. The Buffer Zone comprises the remainder of the Taw-Torridge estuary, Braunton Marsh and Great Field, and a large section of the AONB from Westward Ho! to Croyde. Land management in the Buffer Zone is promoted to be sympathetic to support the ecological value of the Core Area whereby local people can derive social and economic benefits from the ecosystem including through appropriate agriculture, recreation and tourism...... A visitor management strategy will be prepared for Braunton Burrows to avoid any potentially significant adverse impacts from increases in recreational use in order to satisfy the requirements of the Habitats Regulations Assessment.

The LPA will monitor the effectiveness of any adopted management strategy in co-operation with Natural England and other stakeholders. A review of any implemented mitigation measures will be necessary should monitoring indicate that measures delivered have not been effective.

Appendix 1: UK Traffic Data – Rose Ash on the A361 between B3227 and A396

Average Daily Flow 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Pedal Cycles 0 1 0 0 0 0 1 0 0 0 1 0 0 Motorcycles and 78 67 215 59 53 31 58 58 45 45 47 40 37 Mopeds Cars 7319 7161 11847 8480 8755 10603 8766 7711 11438 11403 12954 8045 7981 Buses and Coaches 40 62 89 67 84 110 71 67 133 137 95 33 34 Light Goods Vehicles 1613 1750 1419 1301 1700 1815 1941 2263 1926 1922 1787 1963 2030 Two-axle Rigid HGVs 312 354 431 332 263 385 323 288 183 168 263 402 397 Three-axle Rigid 86 133 126 79 98 106 110 151 86 86 125 83 88 HGVs Four-axle Rigid HGVs 37 62 27 37 37 145 83 67 42 40 32 61 68 Three-axle Articulated 105 88 92 62 59 85 94 82 42 39 48 73 54 HGVs Five-axle Articulated 253 206 129 143 152 124 116 133 81 70 57 236 224 HGVs Six-axle Articulated 195 245 260 282 237 355 378 350 352 340 346 278 282 HGVs All HGVs 988 1088 1065 935 846 1200 1104 1071 786 743 871 1133 1113 All motor vehicles 10038 10128 14635 10842 11438 13759 11940 11170 14328 14250 15754 11214 11195 Annual Change 0.01 0.45 -0.26 0.05 0.20 -0.13 -0.06 0.28 -0.01 0.11 -0.29 0.00 -1.0

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 % cars 72.9 70.7 80.9 78.2 76.5 77.1 73.4 69.0 79.8 80.0 82.2 71.7 71.3 % light goods vehicles 16.1 17.3 9.7 12.0 14.9 13.2 16.3 20.3 13.4 13.5 11.3 17.5 18.1 TOTAL LDV 89.0 88.0 90.6 90.2 91.4 90.3 89.7 89.3 93.3 93.5 93.6 89.2 89.4

% buses and coaches 0.4 0.6 0.6 0.6 0.7 0.8 0.6 0.6 0.9 1.0 0.6 0.3 0.3 % rigid HGV 4.3 5.4 4.0 4.1 3.5 4.6 4.3 4.5 2.2 2.1 2.7 4.9 4.9 % articulated HGV 5.5 5.3 3.3 4.5 3.9 4.1 4.9 5.1 3.3 3.2 2.9 5.2 5.0 TOTAL HDV 10.2 11.4 7.9 9.2 8.1 9.5 9.8 10.2 6.4 6.2 6.1 10.4 10.2

Appendix 2 Automatic Traffic Counter, A361, Beaples Moor

Yearly Growth Rate Report (Based on Initial Year): 2009 to 2013

Site Name: 7002

Site ID: 000000007002

Grid: 281892121658

Description: NDL....A361 Beaples Moor PVR

Direction: All directions Basis: Growth from initial year Vehicle type: All Vehicle Types

2009 2010 2011 2012 2013 Jan 9931 (28) 8456 (31) 10158 (31) 9668 (31) 9225 (31) −14.9% +2.3% −2.6% −7.1% Feb 10949 (24) 11645 (28) 11444 (28) 10841 (29) 11031 (28) +6.4% +4.5% −1% +0.7% Mar 12253 (31) 12305 (31) 11664 (31) 12008 (31) 11639 (31) +0.4% −4.8% −2% −5% Apr 14053 (30) 13903 (30) 14041 (30) 13062 (30) 12728 (30) −1.1% −0.1% −7.1% −9.4% May 14846 (31) 13960 (31) 13580 (31) 12908 (31) 14104 (31) −6% −8.5% −13.1% −5% Jun 14695 (30) 15025 (30) 13638 (30) 14740 (19) 14168 (30) +2.2% −7.2% +0.3% −3.6% Jul 15721 (31) 15596 (31) 14988 (31) 14735 (31) 15584 (31) −0.8% −4.7% −6.3% −0.9% Aug 17440 (31) 16831 (31) 16421 (31) 16218 (31) 17293 (31) −3.5% −5.8% −7% −0.8% Sep 14927 (30) 14846 (30) 14411 (30) 14345 (30) 14033 (30) −0.5% −3.5% −3.9% −6% Oct 13851 (31) 13712 (31) 13412 (31) 12690 (31) 13126 (31) −1% −3.2% −8.4% −5.2% Nov 11488 (30) 11583 (30) 11260 (30) 11303 (30) 12264 (11) +0.8% −2% −1.6% +6.8% Dec 10790 (31) 9529 (31) 10327 (31) 10227 (31) −11.7% −4.3% −5.2%

13115 12944 12660 Year 13500 (358) −2.9% (365) −4.1% (365) −6.2% (355) (315)

Figures in parentheses are the number of days' data used in each month's average daily flow.

Appendix 3: Devon Wildlife Trust Knowstone, Haresdown and Rackenford Moors SAC Mitigation Proposal

Introduction

The A361 (North Devon Link Road) has a significant impact on the Knowstone, Haresdown and Rackenford Moors Special Area of Conservation (hereafter to be referred to as Knowstone Moor). The road runs adjacent to, or dissects the Special Area of Conservation (SAC) for approximately 3200m. The road is located on embankment, cutting and also a section of bridge.

Knowstone Moor was designated as a SAC due to the internationally significant Culm grassland communities supported and also the presence of a marsh fritillary butterfly meta-population (a number of interacting populations). Culm grassland forms part of the UK Biodiversity Action Plan habitat purple moor-grass and rush pasture. This habitat has suffered extensive loss and fragmentation resulting from changes in agricultural practice. Even recently significant declines have been witnessed, with almost 50% being lost between 1984 and 1991. Only 4000 hectares remain, or approximately 1.4% of land area.

This report briefly introduces the impacts roads can have on the environment, making specific reference to Knowstone Moor. It also assesses habitat restoration methodology and the cost required to mitigate these impacts.

The Impacts of Roads upon the Environment

The effect of a road upon the environment is complex and includes disturbance during construction, and pollution from road material and from the traffic using an established road.

The Devon County Council projected 60% increase in vehicular traffic using the A361 resulting from planned development in North Devon will have a demonstrable impact on the SAC interest features. The impacts can be summarised as follows:

Run off from modern road surfaces has been shown to contain potential pollutants of neighbouring habitats including tyre particles, fuel oil, petrol, salt, calcium chloride, phenols, picric acid, fertilizers, organic wastes and bacteria (Detwyler 1971). Considerable attention has been focused on salt application, where impacts have been shown in the soil up to 15m from the road carriageway (Jones 1981).

A significant source of atmospheric pollution arises from car exhaust fumes. The list of pollutants is extensive and includes:

 Ethylene  Carbon Dioxide  Solid particulates  Sulphur dioxide  Oxides of nitrogen  Ozone

Human activity has substantially increased the amount of plant nutrients entering terrestrial ecosystems from atmospheric NO3 and CO2 deposition. Both gasses act as fertilizers which enhance growth of plants. A study by Angold (1997) has shown that the extent of edge effect from a busy road in the New Forest can extent to 200m. Culm grassland relies on its nutrient impoverished status. 52

Adding nutrients unbalances the vegetation community; competitive plants grow with increased vigor, out-competing the characteristic Culm plants. The increase in abundance of competitive grasses can be observed at Knowstone as a strip (approximately 30-50m wide) of luxuriant green grass growth adjacent to the road. If this strip were to extend to the 200m zone of impact observed in the New Forest, the extent of habitat affected would be 84.4 hectares. This calculation takes into account the presence of SAC on both side of the highway in certain locations.

The loss of habitat will have an impact on one interest feature, the marsh fritillary butterfly. This species requires abundant Devil’s-bit scabious, their caterpillars’ only food-plant. This plant is vulnerable to elevated nutrient levels and will not be found in sufficient abundance in such situations. Bulman et al. (2007) has shown that extinction rates for the marsh fritillary butterfly are dependent on habitat patch connectivity. With increasing fragmentation, extinction rates also increase. Marsh fritillary require 80 – 142 hectares of prime habitat to achieve 95% population persistence. As traffic flows increase a corresponding increase in habitat fragmentation will occur as the grassland habitat changes, jeopardising the status of the butterfly.

Knowstone Moor is also one of the few remaining breeding locations in Devon of curlew. This ground nesting bird requires extensive areas of wet grassland near to breeding sites to forage. Devon Bird Watching and Preservation Society has shown that frequent passes are made over the A361, placing this species and its future breeding status in Devon at risk.

Mitigation proposal

Knowstone Moor is under active management and is assessed by Natural England as achieving favorable condition. This mitigation proposal is however based on the assumption that the projected increase in traffic will have a chronic long-term impact on the ecosystem health of Knowstone. It also assumes that normal ‘on site’ restoration works would be unable to effectively mitigate these impacts.

This proposal therefore aims to improve the ecological health of the countryside surrounding Knowstone and hence improve the wider ecosystem viability. The impacts at Knowstone threaten the integrity of the Culm grassland SAC and as such efforts to restore favorable condition to constituent SSSIs (Thorne and Doves Moor, Common Moor East Putford) must also be a priority. This will ensure species such as the marsh fritillary butterfly are able to adapt to degradation of Knowstone by utilizing surrounding high value grasslands that have been restored.

This outcome would be achieved by employing an advisor who would target landowners and provide a whole farm, wildlife and farming advisory service. The Working Wetlands project methodology would be employed which has been proven to be successful in the Culm Natural Area. This approach recognises that the management of wildlife rich habitats can’t be tackled in isolation without influencing the management of the farming system.

Priority would be given to land holdings that are located within the Strategic Nature Areas (SNA) identified by South West Nature Map that incorporate Knowstone. This strategic document, adopted by a range of conservation and land management organisations and planning authorities, identifies land where conservation effort should be targeted. The SNA designation does not relate to landownership and as such taking a whole farm advisory approach will inevitably mean advice is also provided to land outside of the SNA area.

In order to achieve the required landscape scale gain, advisory services would be prioritised to the 4 associated SNAs (Please refer to Map 1). The project management cost of this service would be £5329.20 per annum (based on 2009 figures – inflation should be factored into future calculations) for the duration of the Core Strategy (2026). This indicative figure is based on the per hectare / per annum cost of delivering the Working Wetlands Project, multiplied by the area of the 4 SNAs. Project delivery resource would not have to be spread equally over this term and could be concentrated within a shorter time frame.

It is anticipated that the advisor would, where appropriate, draw upon additional funding sources (Environmental Stewardship) to deliver biodiversity gain, fund capital works and pay annual management grants. In a comparable suit of SNAs, also in the Knowstone Area, the Working Wetlands team have attracted over £750,000 (over 10 years) to restore robust ecosystems. These funding sources are however competitive and funding levels have only been agreed until 2013.

South West Nature Map sets targets within each Culm grassland Strategic Nature Area to achieve 30% prime habitat (Culm grassland), 30% other semi-natural habitat, and 40% other land uses. Table 1 illustrates the current ecological profile of the 4 Knowstone SNAs.

When the impacts of the road upon the prime habitat in Knowstone are taken into consideration the 4 SNAs would require the recreation / restoration of 52 hectares of prime habitat (6% of SNA area). An additional 223 hectares of other semi-natural habitat would also be restored and recreated. This would normally be met by new woodland planting, and species-rich lowland meadow restoration / recreation.

Area (Hectares) % of SNA Area SNA (4) 865 100 SAC / SSSI 221 26 Culm Grassland CWS 71 8 All Culm prime habitat 292 (71+221) 34 Other CWS 37 4 Area of SAC impacted by 85 10 A361 Total prime habitat 207 (292-85) 24 unaffected by road

Table 1: Ecological Profile Knowstone Moor

Habitat (restore Technique Unit Area Notes Sub Total (£) / recreate) Cost £ (Ha) (Ha) Culm Grassland Green Hay Sowing 300 13 Assume Culm restoration and 3900 Restoration recreation operations are Culm Grassland Reseeding into 1400 13 required in equal proportions 18200 Restoration established sward (52 hectares total) Culm Grassland Deep ploughing + 2100 13 27300 Recreation reseeding Culm Grassland Soil Stripping + 6500 13 84500 Recreation reseeding Lowland Green Hay Sowing 300 28 Assume lowland meadow 8400 meadow restoration and recreation restoration operations are required in Lowland Reseeding into 1400 28 equal proportions (112 39200 Meadow established sward hectares total) restoration Lowland Deep ploughing + 2100 28 58800 meadow reseeding recreation Lowland Soil Stripping + 6500 28 182000 meadow reseeding recreation Woodland Planting and 3200 112 112 (50% of non prime semi- 358400 Recreation establishment natural habitat restoration / recreation target) Total £780,700.00 Indicative Project Management Costs £5329.20/ annum Table 2: Knowstone Strategic Nature Area Restoration / Recreation Capital Costs (indicative)

Working at this scale would achieve considerable additional public benefit or ‘ecosystem services’. Knowstone is located in the headwaters of the Taw river. By securing targeted land use change the water holding capacity of land will be increased which will help to reduce the damaging peaks and troughs of river flows. Water quality will be improved as these habitats function as filters removing agricultural pollutants and also intercepting soil run-off. There are also aesthetic benefits to those crossing this wild and characteristic part of North Devon. Another important ecosystem service derived from sensitive management of wetland habitats is carbon sequestration. Dawson and Smith (2007) suggest undamaged peat soils sequester between 0.1 – 0.5 tonnes carbon per hectare per year.

Table 3 shows indicative costs associated with the restoration and recreation of Culm grassland habitat within the SAC to directly offset the area impacted arising by an increase in traffic flows (85 hectares). This approach would not however mitigate against the reduction in ecological integrity

54 caused by increased fragmentation of the SAC and would need to occur in tandem with conservation initiatives in the wider countryside.

Habitat (restore / Technique Unit Area Notes Sub Total (£) recreate) Cost £ (Ha) (Ha) Culm Grassland Green Hay Sowing 300 21.25 Assume Culm 6,375 Restoration restoration and Culm Grassland Reseeding into 1400 21.25 recreation operations 29,750 Restoration established sward are required in equal Culm Grassland Deep ploughing + 2100 21.25 proportions. 44,625 Recreation reseeding Culm Grassland Soil Stripping + 6500 21.25 138,125 Recreation reseeding Total £218,875 Table 3: Indicative Habitat Restoration Capital Costs - 85 hectares

Map 1: Knowstone Moor Biodiversity Designations

References

Angold, P.G. 1997. The impact of a road upon adjacent heathland vegetation: the effects on plant species composition.

Bulman, C.R. Wilson, R.J. Holt, A.R. Bravo, L.G. Early, R.I. Warren, M.S. Thomas, C.D. 2007. Minimum viable metapopulation size, extinction dept, and the conservation of a declining species. Ecological Applications, 17(5) pp. 1460-1473.

Dawson, J.J.C. Smith, P. 2007. Carbon losses from soil and its consequences for land use management. Science for the Total Environment. 382, 165-190.

Detwyler, T.R. 1971. Man’s impact on environment. McGraw-Hill, London.

Appendix 4: Full Biosphere Reserve visitor survey data.

Frequency of use Dog walking Fitness Landscape Other Wild life Wildlife & Landscape Daily 23 7 1 1 Monthly 7 4 2 2 1 Weekly 10 5 1 1 1 2 Yearly 7 2 8 1 5 11

Time of stay Dog walking Fitness Landscape Other Wild life Wildlife & Landscape 0-1 Hours 12 4 1 2 Hours 16 10 3 1 3 Hours 11 1 4 3 1 6 4 Hours 7 2 4 1 4 6 5 Hours 1 1 6 Hours 1 1 1

Location travelled from Dog walking Fitness Landscape Other Wild life Wildlife & Landscape Abbotsham 1 Appledore 1 Barnstaple 4 1 1 Bideford 3 1 2 3 Bradiford 1 Braunton 13 4 1 Bude 3 Clovelly 1 Combe Martin 1 1 Croyde 5 2 1 4 Dartfordon 1 Fremington 2 1 Georgeham 3 2 Gloucester 1 Hartland 1 Ilfracombe 2 1 1 Instow 1 Knowle 1 Landkey 1 lfracombe 1 Lynton 1 Muddiford 1 Newport 1 Parkham 1 Pilton 1 1 1 Roundswell 1 2 Saunton 1 1 1 South Molton 1 Sticklepath, Barnstaple 1 1 West down 1 Westward Ho! 3 1 1 Woolacombe 2 1 1 1 Wrafton 1

Location travelled from Daily Monthly Weekly Yearly Abbotsham 1 Appledore 1 56

Location travelled from Daily Monthly Weekly Yearly Barnstaple 1 2 2 1 Bideford 1 4 1 3 Bradiford 1 Braunton 13 2 1 2 Bude 1 1 1 Clovelly 1 Combe Martin 2 Croyde 3 3 6 Dartfordon 1 Fremington 2 1 Georgeham 2 2 1 Gloucester 1 Hartland 1 Ilfracombe 1 3 Instow 1 Knowle 1 Landkey 1 lfracombe 1 Lynton 1 Muddiford 1 Newport 1 Parkham 1 Pilton 1 2 Roundswell 1 1 1 Saunton 1 2 South Molton 1 Sticklepath, Barnstaple 2 West down 1 Westward Ho! 5 Woolacombe 5 Wrafton 1

Appendix 5: Sandy Lane Car Park Tickets

Appendix 6 Summary of Green Infrastructure Strategy Requirements

PARISH Amenity Greenspace Park, Sport and Recreation Ground Barnstaple main urban area -0.82 -0.62 Barnstaple sticklepath -0.50 1.64 Bideford -3.09 -5.42 Braunton urban -1.85 -5.21 Combe Martin -1.05 1.91 Bickington Roundswell 2.10 -2.17 Great Torrington -2.15 -1.01 Heanton Punchardon wrafton -0.22 -0.85 Holsworthy -1.85 0.33 Ilfracombe 2.55 -9.81 Landkey -1.21 1.86 Northam -1.04 -9.42 South Molton -1.40 1.62 Tawstock urban -0.30 -0.94 Barnstaple sub-regional area 0.48 -2.09 Table 1: Required provision of open space against recommended standards (hectares)

Area Parks Amenity Green Space Ilfracombe Good access Good access Combe Martin Good access Gaps across much of settlement area Braunton & Wrafton Gap in south and north of area Good access Barnstaple Good access Good access Northam and Bideford Gaps to west of Bideford Good access South Molton Good access Small gap in north Great Torrington Gap in east Good access Holsworthy Good access No access Table 2: Summary of access issues in urban areas

Typology Standard (m²) per Cost of provision person Cost / m² Contribution per person Allotments 1.5 £30.00 £45.00 Play Space (children’s and Youth combined) 0.7 £170.00 £119.00 Parks and Recreation grounds 13.0 £72.00 £936.00 Natural Green Space and amenity green 20.0 £15.00 £300.00 space (new provision) Total 35.20 £1,400 Table 3: Costs for providing open space

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Torridge District Council North Devon Council Riverbank House Civic Centre Bideford Barnstaple EX39 2QG EX31 1EA [email protected] [email protected]

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