HABITAT REGULATIONS ASSESSMENT OF DEANE BOROUGH COUNCIL'S

Site Allocations and Development Management Plan – Pre-submission

August 2014

This report was prepared by County Council on behalf of Taunton Deane Borough Council, as the 'competent authority' under the Conservation of Habitats and Species Regulations 2010.

Copyright The maps in this report reproduced from Ordnance Survey material are with the permission of Ordnance Survey on behalf of the Controller of Her Majesty’s Stationery Office. © Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. ()(Licence Number 100038382)(2014) ©

- 2 ­ Executive Summary

This report contributes to Taunton Deane Borough Council’s legal obligation under the Conservation of Habitats and Species Regulations 2010 [the ‘Habitat Regulations’] to carry out a Habitat Regulations Assessment (HRA) of its plans for effects on Natura 2000 sites. In this case it is the draft Site Allocations and Development Management Plan (SADMP) that is assessed.

Natura 2000 sites consist of Special Areas of Conservation (SAC) designated for habitats and animal species, and Special Protection Areas (SPA) designated for bird species. Ramsar sites designated under the Ramsar Convention on Wetlands 1971 are also included following Government policy.

Before a plan can be adopted the ‘competent authority’ (Taunton Deane Borough Council) needs to prove that the plan would have no significant effects on Natura 2000 sites’ integrity to the satisfaction of Natural England. An uncertain result is not acceptable and is treated as adverse until proven otherwise.

Stage 1 of the HRA screens policies and site allocations in the SADMP to determine whether there is any potential for a likely significant effect on Natura 2000 sites, either directly or indirectly, and in combination with other plans and projects. Following the screening analysis of each policy and site allocation the HRA then sets out counter-acting measures, either contained within the adopted Core Strategy or other SADMP policy or for minor amendments to wording of policy within the SADMP, to eliminate any uncertainty and ensure compliance with the Habitat Regulations. Where no conclusion can be reached a Stage 2 Appropriate Assessment is undertaken.

The HRA concluded at Stage 1 that the SADMP was unlikely to have a significant effect on Natura 2000 and Ramsar sites within its influence.

Nonetheless where losses to lesser horseshoe bat habitat, supporting the integrity of the Hestercombe House SAC, from site allocations at Staplegrove and Pyrland Farm the amount of replacement habitat was estimated as a check to ensure that these sites could be delivered. As with previous site allocations north of Taunton and Monkton Heathfield in the Core Strategy the value of the potential habitat loss was calculated using Somerset County Council’s Habitat Evaluation. These calculations showed that there is adequate land available for woodland habitat creation to mitigate the effects of loss of existing habitat for lesser horseshoe bats. Further requirements to ensure no significant effect include woodland buffer planting and specification of directional street lighting

As a matter of law further HRAs would be required on these site allocations when they come forward as planning applications, at which stage more detailed master plans would be available and further surveys of lesser horseshoe bat activity would enable refining the of the amount of habitat creation needed to offset the value of that lost.

It is the conclusion of Taunton Deane Borough Council that the draft Site Allocations and Development Management Plan is unlikely to have a significant effect on Natura 2000 or internationally designated sites for nature conservation.

- 3 ­

Contents

1. Introduction...... 5 2. Methodology ...... 6 Process ...... 6 Precautionary Approach ...... 6 Definitions ...... 7 3. Characteristics and Description of the Natura 2000 Sites ...... 8 Introduction ...... 8 Identification of Natura 2000 sites ...... 8 Ecological Zones of Influence ...... 8 Conservation Objectives ...... 10 Description and Characterisation of Natura 2000 Sites ...... 10 5. Other Relevant Plans or Projects ...... 27 6. Stage 1: Analysis of the Draft Site Allocations and Development Management Plan ...... 29 Introduction ...... 29 Management for Nature Conservation Purposes ...... 29 Plan Analysis ...... 29 Spatial Policy Analysis ...... 48 Counteracting Measures ...... 56 Recommendation ...... 60 7. Conclusion ...... 61 Appendix 1: Assessment of ...... 62 Introduction ...... 62 Summary of the Habitat Evaluation Procedure ...... 62 Replacement of Habitat Value Lost to Lesser Horseshoe Bats ...... 67 Site Assessment of Replacement Habitat Required ...... 68 Appendix 2: HEP Calculation for Staplegrove ...... 72 Appendix 3: Screening of Somerset Levels and Moors SPA / Ramsar (Royal Haskoning) ...... 74

- 4 ­ 1. Introduction

1 This report details the findings of the Habitat Regulations Assessment (HRA) process of the Taunton Deane Borough Council draft Site Allocations and Development Management Plan (SADMP). As the ‘competent authority’ under the Conservation of Habitats and Species Regulations 2010, Taunton Deane Borough Council is required to assess the SADMP through the HRA process as policies and site allocations in the plans can potentially affect Natura 2000 sites.

2 The purpose of the Site Allocations and Development Management Plan (SADMP) is:

• To set out a range of smaller allocations across the Borough consistent with the Core Strategy and in particular, the settlement hierarchy established by Policy SP1 of the Plan; and

• To define development management policies, where necessary, to ensure that sustainable development is delivered in accordance with the principles of the Taunton Deane Core Strategy and National Planning Policy Framework (The Framework).

3 Natura 2000 sites include European Sites - Special Protection Areas (SPA) classified under the EC Birds Directive 1979 and Special Areas of Conservation (SAC) and Special Areas of Conservation (SAC) designated under the EC Habitats Directive 1992, and, as a matter of Government policy, all Ramsar sites as if they are fully designated European Sites for the purpose of considering development proposals that may affect them.

4 The definition of ‘Habitat Regulations Assessment’ is simply an assessment, which must be appropriate to its purpose under the Habitats Directive and Regulations. According to The Conservation of Habitats and Species Regulations 2010, regulation 61 (1) before authorising a plan, which is likely to have a significant effect on a European site, and is not connected to the management of the site, the Council shall assess the implications for the site in view of its conservation objectives.

5 The purpose of HRA of land use plans is to ensure that protection of the integrity of European sites (Natura 2000 sites) is a part of the planning process at a regional and local level. The requirement for Appropriate Assessment of plans or projects is outlined in Article 6(3) and (4) of the European Communities (1992) Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (known as the ‘Habitats Directive’).

- 5 ­ 2. Methodology

Process 6 The methodology used in this HRA follows that given in ‘Draft Guidance for Plan Making Authorities in Wales: The Appraisal of Plans under the Habitats Directive.’(David Tyldesley and Associates, 2012)1

7 In the first stage of the assessment, the screening for likely significant effects, the HRA:

• Identifies all European and Ramsar sites potentially affected.

• States the conservation objectives of each European site potentially affected.

• Acknowledges the plan is not directly connected with or necessary for site management of European sites

• Considers any elements of the plan likely to have a significant effect on any interest feature in combination with other projects and plans, directly or indirectly

• Considers the policies and proposals in the SADMP and the effects that they may have on the identified European and Ramsar sites, estimating likely magnitude, duration, location and extent of these effects as far as they may reasonably be predicted at this level of plan making.

• Assesses counter-acting measures that can eliminate uncertainties arising from the test of likely significant effect at this stage.

8 If a significant effect cannot be ruled out a Stage 2 Appropriate Assessment needs to be undertaken. This will consider:

• The implications for each affected site in light of its conservation objectives, using the best information, science and technical know-how available

• Consider whether any possible adverse effect on integrity of any site could be avoided by changes to the plan, such as an alternative policy or proposal whilst still achieving plan’s aims and objectives.

Precautionary Approach 9. When carrying out this screening, it must be viewed as a coarse filter and therefore a ‘Precautionary Approach’ has been taken in the assessment of significant effect. The EC Guidance sets out a number of principles as to how to approach decision making during the process. The primary one is the ‘Precautionary Principle’, which requires that the

1

- 6 ­ conservation objectives of Natura 2000 sites should prevail where there is uncertainty. In other words if the answer is ‘don’t know’ an adverse impact is assumed. This is the case throughout the HRA process.

10. Once potential impacts have been identified, their significance will be considered. A judgement about significance is made in relation to the conservation objectives and targets using the Precautionary Principle.

Definitions 11. “Significant” is interpreted as an effect likely to adversely affect a Natura 2000 site’s integrity. A useful definition of what a significant effect is contained in an English Nature guidance note2 on the subject: “…any effect that may reasonably be predicted as a consequence of a plan or project that may affect the conservation objectives of the features for which the site was designated, but excluding trivial or inconsequential effects.”

12. “Integrity” is described in ODPM Circular 06/20053: Biodiversity and Geological Conservation as 'the site’s coherence, ecological structure and function across its whole area that enables it to sustain the habitat, complex of habitats and/or the levels of populations of species for which it was classified' (ODPM Circular 06/2005, para. 20).

13. Significance will vary from site to site according to conservation sensitivities and magnitude of the potential impact. Assessment is triggered by likelihood not certainty in line with precautionary principle. (European Communities, 2000) Therefore, the assessment considers whether effects are ‘likely’ and ‘significant’ and not every conceivable effect or fanciful possibility. The Waddensee tests are used:

• Would the effect undermine the conservation objectives for the site? • Can significant effects be excluded on the basis of objective information?

14. Significant effects are also determined in-combination with other plans or projects and take account of cumulative effects.

2 English Nature. 1999. Habitats Regulation Guidance Note 3: The Determination of Likely Significant Effect under The Conservation (Natural Habitats &c) Regulations 1994.

3 https://www.gov.uk/government/publications/biodiversity-and-geological-conservation-circular-06-2005

- 7 ­ 3. Characteristics and Description of the Natura 2000 Sites

Introduction 15. This section identifies which Natura 2000 sites are potentially affected

16. Special Areas of Conservation (SAC) are designated due to the presence or providing ecological support to habitats, listed in Annex I, and species, listed in Annex II of the Habitats Directive (92/43/EEC).

17. Special Protection Areas (SPA) are designated for bird species listed under Article 4 of the Birds Directive (79/409/EEC).

18. Ramsar sites are important wetland sites that have been designated under the Ramsar Convention on Wetlands 1971. Under Government policy, as set out in Planning Policy Statement 9: Biodiversity and Geological Conservation, they are to be treated as Natura 2000 sites.

Identification of Natura 2000 sites 19. The following Natura 2000 sites have component sites present within the geographic area administered by Taunton Deane Borough Council.

• Clean Moor and Holme Moor SAC • Hestercombe House SAC • Quants SAC • Somerset Levels and Moors SPA • Somerset Levels and Moors Ramsar

20. The following Natura 2000 site outside the geographic area administered by the Deane is also been considered as being potentially affected by the plan, such as from recreational pressure and increased levels of traffic.

• Exmoor and Quantock Oakwoods SAC • Exmoor Heaths SAC • Mendip Limestone Grasslands SAC • North Somerset and Mendip Bats SAC

Ecological Zones of Influence 21. Natura 2000 sites are designated for both species and habitat features. Conservation objectives and targets relate to maintaining the integrity of these features. This section describes how ‘Ecological Zones of Influence’ (EZI) are arrived at for each of the Natura 2000 sites potentially affected by the implementation of the Core Strategy. These are areas outside the designated Natura 2000 site, which nonetheless if affected can adversely impact on the integrity of the site’s conservation objectives. For example, bat flight lines and feeding areas supporting a designated roost site if lost may affect the

- 8 ­ viability of the population.

Map 1: Natura 2000 sites

22. Habitats are affected directly from on-site loss due to damage or destruction from land use change. However, they can also be influenced by off site factors such as hydrology. Where there are no significant off site requirements in maintaining a sites habitat the EZI is the same as the Natura 2000 sites boundary. However, sites affected by air pollution will be assessed by distances set out below. All flora species can be affected by airborne pollution, although some, such as lichens and bryophytes are more vulnerable.

23. Unlike habitats, species are not limited by the designated site boundary yet its integrity may depend on habitat several kilometres from the site. For each Natura 2000 site, where a qualifying species is listed as a feature, a description is given, the potential impacts, which are likely to affect that species population’s integrity in terms of the site’s nature conservation objectives, and the methodology of how the EZI is formed.

24. Finally all the EZI for each of a site’s features, i.e. the site itself, its species and habitats, are combined into one EZI per site. A map of the EZI is shown accompanying the Hestercombe House SAC site description and for other SACs at the end of this chapter

- 9 ­ Conservation Objectives 25. Each Natura 2000 site has a set of conservation objectives for its qualifying features. The HRA is concerned with the effects of the Plan on the integrity of these.

26. With regard to the natural habitats and/or species for which the site has been designated; avoid the deterioration of the qualifying natural habitats and the habitats of qualifying species, and the significant disturbance of those qualifying species, ensuring the integrity of the site is maintained and the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying features.

Subject to natural change, to maintain or restore:

• The extent and distribution of qualifying natural habitats and habitats of qualifying species; • The structure and function (including typical species) of qualifying natural habitats and habitats of qualifying species; • The supporting processes on which qualifying natural habitats and habitats of qualifying species rely; • The populations of qualifying species; • The distribution of qualifying species within the site.

Description and Characterisation of Natura 2000 Sites

Exmoor Heaths SAC

Qualifying Features • Northern Atlantic wet heaths with Erica tetralix • European dry heaths • Blanket bogs • Alkaline fens • Old sessile oak woods with Ilex and Blechnum in the British Isles; Western acidic oak woodland

27. Exmoor is representative of upland wet heath in south-west England. Exmoor Heath SAC is designated for the presence of Northern Atlantic wet heaths with Erica tetralix habitat, which predominates on gently-sloping and level ground. It is extremely variable in nature and has in places been modified by management, particularly burning.

28. Exmoor Heath SAC is also designated for the presence of European dry heaths, which are extensive.

29. A feature present along the north coast of Exmoor within the SAC is Vegetated Sea Cliffs of the Atlantic and Baltic Coasts. Vegetated sea cliffs are steep slopes fringing hard or soft coasts, created by past or present marine erosion, and supporting a wide diversity of vegetation types with variable maritime influence.

- 10 ­

30. Blanket bogs are a feature of the Exmoor Heaths SAC. These extensive peatlands have formed in areas where there is a climate of high rainfall and a low level of evapotranspiration, allowing peat to develop not only in wet hollows but over large expanses of undulating ground.

31. Alkaline fens form another feature of the Exmoor Heaths SAC. They consist of a complex assemblage of vegetation types, characteristic of sites where there is tufa and/or peat formation with a high water table and a calcareous base-rich water supply. The core vegetation is short sedge mire (mire with low-growing sedge vegetation).

32. In conjunction with heaths this site also supports tracts of old sessile oak woods. These woods are rich in bryophytes, ferns (including Dryopteris aemula) 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.

Table 1: Exmoor Heaths SAC Key Environmental Conditions

Qualifying features Key environmental conditions to support site integrity Northern Atlantic wet heaths with Erica Air quality tetralix Soil conditions Hydrological conditions Appropriate management Control of inappropriate invasive species

European dry heaths Air quality Appropriate management Soil conditions Control of inappropriate invasive species

Vegetated sea cliffs of the Atlantic and Maintain exposure of the geological interest by allowing Baltic Coasts natural processes to proceed freely. Appropriate management

Blanket bogs Appropriate management The control of inappropriate and invasive species. Hydrology Water quality Air quality

Alkaline fens Topography Hydrology Drainage Water quality Soil conditions Appropriate management

Old sessile oak woods with Ilex and Appropriate woodland management Blechnum in the British Isles Air quality

- 11 ­

Ecological Zone of Influence 33. For the purposes of this assessment it is considered that the EZI lies entirely within the site boundary as any impacts are only likely to be from visitor pressure.

Vulnerability 34. The site would be vulnerable to increasing visitor pressure from the Plan due to increasing the number of dwellings within the Deane resulting in rise in the local population, a proportion of who are likely to be attracted to areas of natural beauty, such as Dunkery Beacon. This site is also likely to be vulnerable to atmospheric deposition and eutrophication possibly from increased vehicle trips from visits to these sites. .

Exmoor and Quantocks Oak Woodlands SAC

Qualifying Features • Old sessile oak woods with Ilex and Blechnum in the British Isles; Western acidic oak woodland • Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae); Alder woodland on floodplains • Barbastella barbastellus; Barbastelle bat • Myotis bechsteinii; Bechstein`s bat • Lutra lutra; Otter

39 This site supports extensive tracts of old sessile oak woods in conjunction with heath. They are rich in bryophytes, ferns (including Dryopteris aemula) 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.

40 Alluvial forests with alder and ash comprises woods dominated by alder Alnus glutinosa and willow Salix spp. on flood plains in a range of situations from islands in river channels to low-lying wetlands alongside the channels. The habitat typically occurs on moderately base-rich, eutrophic soils subject to periodic inundation.

41 There are maternity colonies of Barbastelle Bat utilising a range of tree roosts in areas of predominantly oak woodland in the Horner Woods and Quantocks component sites. Foraging areas can lie several kilometres from the roost sites.

42 There is also a maternity colony of Bechstein’s bats, which are the rarest species in England, located at Horner Wood.

43 Otter are found on all types of watercourse including canals, ponds, lakes and reservoirs. They use tiny ditches and streams including dry watercourses as regular commuting routes. They may also cross overland between watersheds and will short cut across bends in rivers. An otter’s territory is approximately 15 to 20 kilometres long or the length of three riverside parishes in Somerset (Pers.Com. James Williams, Somerset Otter Group; Karen Coxon)

- 12 ­ Table 2: Exmoor and Quantocks Oak Woodlands Key Environmental Conditions Qualifying features Key environmental conditions to support site integrity Old sessile oak woods with Ilex (holly) and Appropriate woodland management Blechnum (fern) in the British Isles Avoidance of Air pollution

Alluvial forests with Alnus glutinosa (alder) and Appropriate woodland management Fraxinus excelsior (ash) Maintenance of hydrological regime

Barbastelle bat Barbastella barbastellus Undisturbed roosts Bechstein’s Bat Myotis bechsteinii Woodland management Availability of decaying and veteran trees Maintenance and connectivity of habitats used as flight lines on and off site Feeding areas

Otter Lutra lutra Maintenance of river water quality and flow Fish stocks Bankside vegetation Levels of disturbance

Ecological Zone of Influence 44 The woodland habitats are sensitive to changes in hydrology and to changes in air quality. The habitat therefore may be influenced outside the SAC by air pollution resulting from issues set out in Chapter 6. Any watercourse entering and upstream of the site in the catchment is also considered within the EZI.

45 Where barbastelle bats are present a buffer of 9 kilometres around the maternity roost site area is formed. The area of likely habitat use is then digitised by copying whole polygons from OS Mastermap, particularly flyways through woodland and along watercourses and hedgerows in unfragmented corridors connecting to the roost area. This process uses aerial photographic interpretation, field survey (EDF, 2011) and radio tracking data (Rush & Billington, 20134). This forms the EZI for barbastelle bats.

46 Bechstein’s’ bats are considered to forage within the home woodland. Radio tracking at Beckets Coppice also showed that bats stayed within the home woodland (Schofield & Morris, 20005).

47 There are records of otters for every watercourse within the SAC. The watercourses are digitised for 10 kilometres both sides of a record and then buffered by an extent of 100 metres. (Otter holts can be located up to 100 metres away from water but most are

4 Rush, T. & Billington, G. 2013.Report on a radio tracking study of Barbastelle bats at Hinkley Point C. Witham Friary: Greena Ecology.

5 Schofield, H. & Morris, C. 2000. Ranging Behaviour And Habitat Preferences Of Female Bechstein’s Bat, Myotis Bechsteinii (Kuhl, 1818), In Summer. Ledbury: The Vincent Wildlife Trust.

- 13 ­ within 3.5 metres [Liles, 20046]).This then forms the Ecological Zone of Influence for otters.

Vulnerability 48 Woodland habitat would be vulnerable to habitat deterioration and loss from increased trampling from an increased number of visitors using footpaths through the SAC. Visitors could include those walking, including with dogs, and potentially off road cyclists. Bat roosts may also be subject to increased disturbance from the proximity of visitors to the woodlands in which they are located.

Hestercombe House SAC

Qualifying Features • Rhinolophus hipposideros; Lesser horseshoe bat

49 The Hestercombe House lesser horseshoe bat maternity roost consists of two components; one is the roost site in the house, and the other is located in the stable block. The former roost continues to show a decline in numbers of bats and is an ‘unfavourable declining’ condition. The stable block shows that about the same number of bats is present as at notification and is in a ‘favourable’ condition. However, overall numbers of lesser horseshoe bats continue to fall. Another roost outside has been established in that may be linked to the SAC ones.

50 Hestercombe \House hosts a large lesser horseshoe bat maternity site in the vale of Taunton Deane. The bats roost in the roof void of part of a large building. Although only a small proportion of the UK population, this site has been included as representative of the species in South West England.

55. At Hestercombe House lesser horseshoe bats were radio tracked in the late summer of 2005 and found to be primarily feeding around tall hedgerows and moving in open pasture, through woodlands, over arable fields, along woodland tracks, field edges, over private allotments, across amenity grasslands (lawns, playing fields, etc.), marshy fields, ditches and lakes. In addition, marshland was being used for foraging. (Billington, 20057)

Table 3: Hestercombe House Key Environmental Conditions Qualifying features Key environmental conditions to support site integrity

Lesser horseshoe bat Undisturbed roosts Roost conditions maintained Appropriate management of vegetation at roost entrances Maintenance and connectivity of habitats used as flight lines on and off site Feeding areas

6 Liles, G. 2003. Otter Breeding Sites. Conservation and Management. Peterborough: English Nature

7 Billington, G. 2005. Radio tracking study of lesser horseshoe bats at Hestercombe House Site of Special Scientific Interest, July 2005. Peterborough: English Nature.

- 14 ­ Ecological Zone of Influence 56. Map 2 below shows the EZI for Hestercombe House SAC in the landscape north of Taunton (prior to surveys undertaken in 20138). Reference should be made to the Habitats Regulations Assessment of Hestercombe House SAC carried out by Somerset County Council in September 2009 for further detail.

Vulnerability 57 Bat numbers are down by more than 25% since notification. The cause is unknown. This could be a number of factors. There has been physical loss of habitat (woodland work/ building work) near to the roost. There has been housing development in the foraging area. Other reasons could be change in agricultural practice in the area south of the Quantocks resulting in degradation of feeding habitat and loss or severance of hedgerows.

Map 2: Hestercombe House SAC EZI

58 The viability of the colony is vulnerable to loss and fragmentation of feeding habitat due to development north of Taunton. Development in this area is subject to offsetting as established by the findings of HRA for the Core Strategy.

Holme Moor and Clean Moor SAC

Qualifying Features • Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae); Purple moor-grass meadows • Calcareous fens with Cladium mariscus and species of the Caricion davallianae;

8 Firman, B. 2013. Staplegrove. Protected Species Suvey: Bats. October 2013. Cardiff: Wildwood Ecology Ltd.

- 15 ­ Calcium-rich fen dominated by great fen sedge (saw sedge)* • Alkaline fens; Calcium-rich springwater-fed fens

61. This is a relatively small site but it is important as an outlier of calcareous fens in south­ west England, where Cladium is a local and rare species. The site occupies an unusual ecological situation on the spring line at the foot of a scarp slope.

62. Holme Moor & Clean Moor is important as a south-westerly site for alkaline fen. The most species-rich example of alkaline fen is on Clean Moor, where black bog-rush Schoenus nigricans and blunt-flowered rush Juncus subnodulosus have many associates including the moss Scorpidium scorpioides, small sedges such as Carex pulicaris, C. panicea and C. viridula ssp brachyrrhyncha, and other low growing species such as lousewort Pedicularis palustris and the orchids Gymnadenia conopsea, Dactylorhiza fuchsii and D. praetermissa.

63. Unimproved marshy grassland habitat, Molinia meadows on calcareous, peaty or clayey-silt-laden soils (Molinion caeruleae), is also present on the sites. Molinia meadows are found mainly on moist, moderately base-rich, peats and peaty gley soils, often with fluctuating water tables.

Table 4: Holme Moor and Clean Moor Key Environmental Conditions Qualifying features Key environmental conditions to support site integrity

Calcareous fens Hydrological conditions maintained. Water quality is extremely important. Healthy stands of Cladium are required in communities in which short herbs/sedges are a major and characteristic component

Alkaline fens Appropriate management The control of inappropriate and invasive species. Hydrology, water quality and air quality must be maintained.

Purple moor grass meadows on Appropriate management calcareous, peaty or clayey-silt-laden The control of inappropriate and invasive species. soils Hydrology, water quality and air quality must be maintained

Ecological Zone of Influence 64. The fen and grassland habitats are sensitive to changes in hydrology.

Vulnerability 66 No particular existing trends or pressures were identified in the site information, except for one off damage from an off road vehicle and deer browsing within woodland habitats. All habitats are sensitive to recreation pressure particularly the use of off road vehicles.

- 16 ­ Mendip Limestone Grasslands SAC

Qualifying Features • European dry heaths • Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco- Brometalia); Dry grasslands and scrublands on chalk or limestone • Caves not open to the public • Tilio-Acerion forests of slopes, screes and ravines; Mixed woodland on base-rich soils associated with rocky slopes • Rhinolophus ferrumequinum; Greater horseshoe bat

67 The primary reason for the sites designation is Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia). This site comprises coastal and inland sections of the Carboniferous Limestone outcrops of the Mendips.

68 Transitions to European dry heaths occur on flatter terrain. European dry heaths typically occur on freely-draining, acidic to circumneutral soils with generally low nutrient content. Most dry heaths are managed as extensive grazing for livestock

69 Tilio-Acerion forests of slopes, screes and ravines occur in the Crook Peak to Shute Shelve Hill component site of the SAC. Tilio-Acerion ravine forests are woods of ash, wych elm and lime (mainly small-leaved lime but more rarely large-leaved lime). The habitat is found on calcareous substrates associated with coarse scree, cliffs, steep rocky slopes and ravines, where inaccessibility has reduced human impact.

70 Caves not open to the public are present on the Crook Peak to Shute Shelve Hill component sites and are selected as features of the SAC as they provide important hibernation sites for greater and lesser horseshoe bats. Greater horseshoe bats are also a feature of the SAC.

Table 5: Mendip Limestone Grasslands Key Environmental Conditions Qualifying features Key environmental conditions to support site integrity

Semi-natural dry grasslands and scrubland facies Sward structure and composition on calcareous substrates Absence of negative indicator species

European dry heaths Appropriate management Control of inappropriate or invasive species

Tilio-acerion (lime-maple) forests on slopes, Appropriate management screes and ravines

Caves not open to the public Pressure from human activity above and below ground Management of overlying land and catchment

- 17 ­ Qualifying features Key environmental conditions to support site integrity

Greater horseshoe bat Undisturbed roosts Roost conditions maintained Appropriate management of vegetation at roost entrances Maintenance and connectivity of habitats used as flight lines on and off site Feeding areas

Ecological Zone of Influence 76. The unimproved calcareous grasslands, dry heath and Tilio-Acerion forests are sensitive to changes in air quality. The habitat therefore may be influenced outside the SAC by air pollution. Air pollution from traffic may have eutrophication effects, which would impact on species composition in the sward. 200 metres is the distance from a road where nitrogen deposition is expected to occur in the Habitat Regulations Assessment of the draft Regional Spatial Strategy for the South West (Land Use Consultants, 20069). Bignall et al, (2004)10 consider that 150 metres air quality returns to background levels. The greater distance is used, as a precautionary approach is required.

77. For horseshoe bats a buffer of 2.1 kilometres around the hibernation roost site area is formed based on winter foraging ranges. In England radio tracking of bats revealed that they foraged on average to a maximum distance of 1.2 kilometres from the hibernation site. One bat travelled to an absolute maximum distance of 2.1 kilometres. The winter foraging range appears to be approximately half the area covered in the summer months. (Bat Conservation Trust/BMT Cordah, 200511) Flyways and feeding areas are digitised based aerial photographic interpretation and available habitat data. This forms the EZI for horseshoe bats for this SAC.

Vulnerability 78 These sites are all open-access and are heavily used for informal recreation. Recreational pressure is becoming a problem with increased levels of trampling and erosion leading to localised loss of habitat (Natural England). There is also the illegal setting of fires.

79 Caves are sensitive systems, which often suffer significant pressure from human activities, both above and below ground. It is important to manage the overlying land and catchment in a manner, which takes account of potential consequences on the caves.

9 Land Use Consultants. 2006. Habitats Regulations Report of the Draft South West Regional Spatial Strategy: Screening Report. Taunton: South West Regional Assembly.

10 Bignall, K., Ashmore, M. & Power, S. 2004. The ecological effects of diffuse air pollution from road transport. English Nature Research Report No. 580. Peterborough: English Nature.

11 Bat Conservation Trust. 2005. A Review and Synthesis of Published Information and Practical Experience on Bat Conservation within a Fragmented Landscape. Cardiff: The Three Welsh National Parks, Pembrokeshire County Council, Countryside Council for Wales

- 18 ­ North Somerset and Mendip Bats SAC

Qualifying Features • Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco- Brometalia); Dry grasslands and scrublands on chalk or limestone • Caves not open to the public • Tilio-Acerion forests of slopes, screes and ravines; Mixed woodland on base-rich soils associated with rocky slopes • Rhinolophus hipposideros; Lesser horseshoe bat • Rhinolophus ferrumequinum; Greater horseshoe bat

80 This site in south-west England was selected on the basis of the size of population represented (3% of the UK greater horseshoe bat Rhinolophus ferrumequinum population) and its good conservation of structure and function, having both maternity and hibernation sites. This site contains an exceptionally good range of the sites used by the population, comprising two maternity sites in lowland north Somerset and a variety of cave and mine hibernation sites in the Mendip Hills.

81 The limestone caves of the Mendips provide a range of important hibernation sites for lesser horseshoe bat Rhinolophus hipposideros. The component site supports a number of possible bat hibernacula and a single maternity roost. The maternity roost is located in the show caves. At Wookey Hole the roost site is located off the show caves.

86. The Cheddar complex and Wookey Hole areas support a wide range of semi-natural habitats including Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia). The principal community present is CG2 Festuca ovina – Avenula pratensis grassland that occurs on rock ledges and on steep slopes with shallow limestone soil, especially in the dry valleys and gorges and on the south-facing scarp of the Mendips. The site is also important for the large number of rare plants, which are associated with Carboniferous limestone habitats.

87. The main block of Tilio-Acerion forest, listed on the SAC citation, is at King’s and Urchin’s Woods located in North Somerset.

88. Caves not open to the public are selected as features of the SAC as they provide important hibernation sites for greater and lesser horseshoe bats.

Table 6: North Somerset and Mendip Bats Key Environmental Conditions

Qualifying features Key environmental conditions to support site integrity Horseshoe bats Undisturbed roosts Roost conditions maintained Appropriate management of vegetation at roost entrances Maintenance and connectivity of habitats used as flight lines on and off site Feeding areas

- 19 ­ Qualifying features Key environmental conditions to support site integrity Semi-natural dry grasslands and scrubland facies Sward structure and composition on calcareous substrates Absence of negative indictor species

Caves not open to the public Pressure from human activity above and below ground Management of overlying land and catchment

Ecological Zone of Influence 89. For greater horseshoe bats a buffer of 6 kilometres around the maternity roost site areas are formed. Starting with maternity roosts OS Mastermap polygons of connected habitat within home range is digitised. This process is further analysed using aerial photographic interpretation and available habitat data. Identification of flyways and feeding areas are also based on radio tracking data produced (Jones & Billington, 199912). This forms the EZI for greater horseshoe bats.

90. Similarly lesser horseshoe bat roosts are mapped using data on roost size to determine the distance buffered. Hibernation roosts are buffered by 2.1 kilometres. This forms the EZI for horseshoe bats with roosts located in the SAC.

91. The unimproved calcareous grasslands are sensitive to changes in air quality. The habitat therefore may be influenced outside the SAC by dust and air pollution. Air pollution from traffic may have eutrophication effects, which would impact on species composition in the sward. 200 metres is the distance from a road where nitrogen deposition is expected to occur in the Habitat Regulations Assessment of the draft Regional Spatial Strategy for the South West (Land Use Consultants, 200613). Bignall et al, (2004)14 consider that 150 metres air quality returns to background levels. The greater distance is used, as a precautionary approach is required.

Vulnerability 93 There is concern regarding loss of bat foraging areas (Natural England). Problems are known to exist with recreational cavers in some of the caves used as hibernacula by bats. Natural England is working with the owners of these caves in order to minimise disturbance at critical times of the year. Further breeding roosts are believed to occur in the Cheddar area and steps are being taken to identify these. The bat population will potentially be at risk until these are discovered.

94. There are significant management problems associated with both the grassland and

12 Jones, Dr. G. & Billington, G. 1999. Radio tracking study of greater horseshoe bats at Cheddar, North Somerset. Peterborough: English Nature.

13 Land Use Consultants. 2006. Habitats Regulations Report of the Draft South West Regional Spatial Strategy: Screening Report. Taunton: South West Regional Assembly.

14 Bignall, K., Ashmore, M. & Power, S. 2004. The ecological effects of diffuse air pollution from road transport. English Nature Research Report No. 580. Peterborough: English Nature.

- 20 ­ woodland elements of the SAC. Maintaining appropriate grazing levels is a problem. Low levels of grazing are resulting in scrub invasion and the development of secondary woodland. There is also a problem with invasive and inappropriate species, such as gorse and bracken in the grassland. Recreational pressure may cause trampling issues particularly where footpaths occur within the SAC.

Quants SAC

Qualifying Features • Euphydryas aurinia; Marsh fritillary butterfly

1. This damp and sheltered site supports a medium-sized but strong marsh fritillary population in a neutral grassland/fen mosaic. It is strategically placed close to other smaller sub-populations, with which it forms a metapopulation, and may exchange individuals with the large population at Southey Moor (outside the SAC series).

Table 7: Quants Key Environmental Conditions Qualifying features Key environmental conditions to support site integrity

Marsh fritillary butterfly Appropriate management to maintain a mosaic of grassland and scrub habitats. Significant population of devil’s bit scabious

Ecological Zone of Influence 2. Within Quants SAC suitable habitat is digitised using aerial photographic interpretation and available layers of habitat mapping. A buffer zone of 2 kilometres is created around the habitat (Fowles, A. P. 2003, amended 200415). Any marsh fritillary sites within this zone are also analysed by means of aerial photography and habitat data. This cluster of sites is then further buffered by 2 kilometres to create the EZI for the marsh fritillary.

Vulnerability 3. The marsh fritillary population here is restricted to a comparatively small area (c. 2 ha) and is kept high by a considerable level of management directed at producing 'ideal' habitat in this area. If the highly interventionist nature of management is disrupted or discontinued the population may drop.

Somerset Levels and Moors SPA 98. The Somerset Levels and Moors SPA is one of the largest and richest areas of traditionally managed wet grassland and fen habitats in lowland UK. The majority of the site is only a few metres above mean sea level and drains through a network of ditches,

15 Fowles, A. P. 2003, amended 2004. Guidance Notes for the Definition and Mapping of Habitat Quality for Marsh Fritillaries (Natural Science Report No. 03/5/01). Cardiff: Countryside Council for Wales

- 21 ­ rhynes, drains and rivers. The site attracts important numbers of water birds in winter.

Qualifying Features Potentially Affected

• Cygnus columbianus bewickii; Bewick"s swan (Non-breeding) • Anas crecca; Eurasian teal (Non-breeding) • Pluvialis apricaria; European golden plover (Non-breeding) • Vanellus vanellus: Northern lapwing (Non-breeding)

Additional Qualifying Features Identified by the 2001 UK SPA Review: • Anas penelope; Eurasian wigeon (Non-breeding) • Anas clypeata; Northern shoveler (Non-breeding)

Assemblage qualification: A wetland of international importance. The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000 waterfowl’

Over winter, the area regularly supports 72,874 individual waterfowl (5 year peak mean 1991/2 - 1995/6) including: snipe Gallinago gallinago, lapwing Vanellus vanellus, pintail Anas acuta, gadwall Anas strepera, shoveler Anas clypeata, teal Anas crecca, wigeon Anas penelope, Golden plover Pluvialis apricaria, Bewick's swan Cygnus columbianus bewickii, whimbrel Numenius phaeopus.

Table 8: Somerset Levels and Moors Key Environmental Conditions

Qualifying features Key environmental conditions to support site integrity

Over wintering ­ Active management to maintain the ground and surface water levels of Bewick's swan, teal, golden the site. plover, lapwing, wigeon and Management of the habitats present is required to maintain the diverse shoveler structure and composition of vegetation. This would include hay cutting, light grazing and ditch drainage. Control of inappropriate or invasive species Waterfowl assemblage Maintenance of view lines Birdlife found on the site is vulnerable to disturbance.

Ecological Zone of Influence 4. Records for each of the species are analysed outside of the SPA and any supporting habitat that supports a bird species is digitised, i.e. some ducks and waders will switch habitats between day and night time periods (Guillemain et al, 200116; Cramp, 197917; 198318) In flight records are ignored, as are those over 10 years old. Examples of the

16 Guillemain, M., Fritz, H., & Duncan, P. 2001. The importance of protected areas as nocturnal feeding grounds for dabbling ducks wintering in western France. Biological Conservation, 113, 2002, 183-198

17 Cramp, S. (ed). 1977. Handbook of the Birds of Europe, the Middle East and North Africa – The Birds of the Western Palaearctic, Volume I Ostriches to Ducks. Oxford: Royal Society for the Protection of Birds/Oxford University Press

18 Cramp, S. (ed). 1983. Handbook of the Birds of Europe, the Middle East and North Africa – The Birds of the Western Palaearctic, Volume III Waders to Gulls. Oxford: Royal Society for the Protection of Birds/Oxford University Press.

- 22 ­ distances at which birds take flight from being disturbed are shown in Table 9. There would also be a distance from which birds are distracted from feeding and are alert, which is not given.

Table 9: Disturbance from Human Proximity Species Flight Distance (FD) Bewick’s Swan No data Wigeon 89-250 metres Gadwall No data Teal No data Pintail No data Shoveler No data Golden Plover 42-70 metres Lapwing No data Whimbrel 84 metres Water Rail No data Ruff No data (from Goss-Custard, 200519; Mathers et al, 200020)

5. The largest FD is 250 metres. Therefore, a distance of 300 metres is used for buffering the Natura 2000 site and any additional digitised habitat. This allows for a period of disturbance where birds are alert before taking flight. Records outside of the SPA/Ramsar site are examined and where it is considered that the habitat potentially supports the ecological requirements of the bird species listed for the designation this is digitised and buffered. A list of the sites is given in Appendix 1.Flight paths also need considering as many species listed fly in the lower air space and can be disturbed by land use change along these corridors between areas of use. These are digitised by forming MCPs around the records per species for the site, linking the habitat outside the site with that on the SPA site. These then form the EZI for the bird species of the Somerset Levels and Moors SPA.

Vulnerability 6. Birds may be vulnerable to recreational disturbance from increased access arising from new developments in Taunton Deane.

Somerset Levels and Moors Ramsar 7. The Ramsar site is a Wetland of International Importance because the site qualifies under several criteria for determining qualification.

8. Under Criterion 5 the Ramsar site regularly supports at least 20,000 waterfowl (specifically 97155 waterfowl) and under Criterion 6 – species/populations occurring at levels of international importance. These are listed below:

19 Goss-Custard, J. D. 2005. National Cycle Network – Exe Estuary Proposals: Assessment of the Anticipated Effects on the Exe Estuary Special Protection Area. Exeter: County Council.

20 Mathers, R.G., Watson, S., Stone, R. & Montgomery, W. I. 2000. A study of the impact of human disturbance on Wigeon Anas penelope and Brent Geese Branta bernicla hrota on an Irish sea loch. Wildfowl 51: 67 - 81.

- 23 ­

Species with peak counts in winter: • Bewick’s swan, Cygnus columbianus bewickii • Eurasian teal, Anas crecca • Northern lapwing, Vanellus Vanellus

9. Species/populations identified subsequent to designation for possible future consideration under Criterion 6 are also listed:

Species with peak counts in winter: • Mute swan, Cygnus olor • Eurasian wigeon, Anas penelope • Northern pintail, Anas acuta • Northern shoveler, Anas clypeata

10. The Ramsar designation also lists noteworthy species currently occurring at levels of national importance:

Species with peak counts in winter: • Gadwall, Anas strepera strepera • Water rail, Rallus aquaticus • European golden plover, Pluvialis apricaria apricaria, • Ruff , Philomachus pugnax • Common snipe, Gallinago gallinago gallinago

11. Under Criterion 2a the ditches and rhymes support an assemblage of rare, vulnerable or endangered species of sub species (specifically rare invertebrates, particularly beetles).

Table 10: Somerset Levels and Moors Key Environmental Conditions

Qualifying features Key environmental conditions to support site integrity

Rare invertebrates, particularly beetles Appropriate maintenance of rhynes and ditches Ground and surface water levels Water quality

Waterfowl Ground and surface water levels. Management of habitats

Control of inappropriate or invasive species Teal, lapwing and Bewick’s swan Maintenance of view lines Birdlife found on the site is vulnerable to disturbance.

Ecological Zone of Influence 12. Records for each of the bird species are analysed outside as for the Somerset Levels and Moors SPA.

- 24 ­ 13. Records of beetle species listed are compared to the Ramsar site boundary. It is considered that the longest ranging of the invertebrates species listed above would be beetles, which fly readily, or hoverfly. Beetles are known to disperse over several kilometres (Lundkvist et al, 200221). A rove beetle Aleochara bilineata in Ontario, Canada was recorded as being capable of flying at least 5 kilometres (Tomlin et al, 199222). Records of listed beetles and hover flies (Lejops vittata) are considered to be included if within 5 kilometres of the Ramsar site lacking further evidence. Valvata macrostoma is considered to be capable of moving 300 metres per annum (Kappes & Haase, 201223).The fields around any water, rove or soldier beetle or Lejops vittata records, inside and outside of the site, are digitised. Flight corridors also need considering as species can be disturbed by land use change along these paths between areas of use. These are digitised by forming MCPs around the records per species for the site, linking the habitat outside the site with that on the Ramsar site. It is considered that other species of invertebrates have limited dispersal capability and are confined to the Ramsar site. No buffer is formed in relation to these records.

14. Water beetles and large mouthed valve snails are also dependent on the maintenance of water quality (Foster & Eyre, 199224). Therefore, watercourses entering the Ramsar sites supporting these species should also be mapped.

15. This forms part of the EZI to take account of potential impacts on invertebrates for the Somerset Levels and Moors Ramsar.

Vulnerabilities 16. The majority of the site is only a few metres above mean sea level and drains through a large network of ditches, rhynes, drains and rivers. Water Level Management is critical and is being addressed through Water Level Management Plans process and the development of Raised Water Level Areas and Environmentally Sensitive Areas (ESA).

17. There is nutrient enrichment due to sewage treatment facilities in to watercourses (70%) and also water pollution from agricultural runoff (30%). This would particularly affect the vegetative composition of ditches and rhynes and hence the aquatic invertebrates they support. Invasive freshwater species are also occurring. Increased sewage and other surface water runoff from upstream development in the Deane may affect water quality that is detrimental to aquatic invertebrate assemblages.

18. Birds may be vulnerable to recreational disturbance from increased access arising from new developments in Taunton Deane.

21 Lundkvist, E., Landin, J. & Karlsson, F. 2002. Dispersing diving beetles (Dytiscidae) in agricultural and urban landscape in south- eastern Sweden. Ann. Zool. Fennici 39: 109-123.

22 Tomlin, A. D., McLeod, D. G. R., Moore, L. V., Whistlecraft, J. W., Miller, J. J. & Tolman, J. H. 2002. Dispersal of Aleochara bilineata [Col.: Staphylinidae] following inundative releases in urban gardens. Biocontrol, 37, 1, 55-63

23 Kappes, H. & Haase, P. 2012. Slow but steady: dispersal of freshwater molluscs. Aquat Sci (2012) 74:1–14

24 Foster, G. N. & Eyre, M. D. 1993. Classification and Ranking of Water Beetle Communities. Journal of Animal Ecology, Vol. 62, No. 1 (Jan., 1993), 216-217

- 25 ­ Ecological Zone of Influence Map

Map 3: Ecological Zones of Influence

- 26 ­ 5. Other Relevant Plans or Projects

19. Article 6(3) of the Habitats Directive requires a HRA of ‘…any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect there on, either individually or in combination with other plan or projects’. Therefore it is necessary to identify plans and projects that may have ‘in­ combination’ affecting the Nature 2000 sites, which are the focus of this assessment.

20. The assessment of significant effects for the Core Strategy needs to take account of the impact in combination with other plans and projects. For Natura 2000 sites where it is unlikely that the Core Strategy on its own will require a stage 2 Appropriate Assessment in relation to that site, it has been necessary to consider whether ‘in-combination’ effects are likely to result in an Appropriate Assessment being required

21. The guidance states that only those that are considered most relevant should be collected for ‘in combination’ testing - an exhaustive list could render the assessment exercise unworkable. The following plans or strategies are considered to have potential effects and therefore have been included within the assessment.

Table 10: Assessment of Plans and Projects for In-Combination Effects

Plan or Project Implications for Taunton Deane Core Strategy Taunton Deane The Core Strategy sets out plans for development in the areas of West Borough Council Core Monkton, the north side of Taunton and Comeytrowe in Taunton. The Strategy developments associated with Monkton Heathfield and the north side of Taunton are subject to Habitats Regulations Assessment due to effects on the lesser horseshoe bat colony at Hestercombe House SAC.

The Core Strategy contained Development Management Policies which are the base for those in the assessed Plan.

The Core Strategy has been subject to HRA whereby it was found to have no significant effect dependent on implementation of measures to counteract effects on Hestercombe House SAC from individual developments. Individual development proposals in this Plan will be subject to the same procedure of evaluation and offset where a significant effect is likely.

The Small Sites and Development Management Plan does not include any additional requirement for dwellings in the Deane above that in the Core Strategy, which has undergone its own HRA.

Somerset Local New housing resulting from policy in other district and borough council Authorities’ Core Strategies could have in-combination effects from increased traffic Development Plan generated by development. The A38 runs within 200 metres of the Documents Mendip Limestone Grasslands SAC and provides a link to and Bristol Airport from the Borough.

There are potential recreational effects on Natura 2000 sites from new housing development. This is most likely to occur at the Exmoor and

- 27 ­ Plan or Project Implications for Taunton Deane Core Strategy Quantocks Oak Woodlands SAC; Exmoor Heaths SAC; and the Somerset Levels and Moors SPA / Ramsar.

Water abstraction from new housing and other development may affect groundwater.

The Small Sites and Development Management Plan does not include any additional requirement for dwellings in the Deane in the Deane above that in the Core Strategy, which has undergone its own HRA. . Somerset Waste Core There is unlikely to be in combination effects as Somerset waste Strategy strategy is likely to focus growth on existing facilities.

Somerset Minerals There could be in-combination effects from transport resulting from Core Strategy housing development and minerals operations.

Somerset Local Major infrastructure schemes are concentrated within Taunton and other Transport Plan 2 policies work towards a reduction of traffic using roads. There is a Freight Strategy, which directs HGV traffic onto certain routes through the County. There could be in-combination effects where these routes run within 200 metres of sensitive Natura 2000 sites. The A38, a strategic freight route, runs within 200 metres of the Mendip Limestone Grasslands SAC.

The Small Sites and Development Management Plan does not include any additional requirement for dwellings in the Deane in the Deane above that in the Core Strategy, which has undergone its own HRA.

Somerset Rights of As there are potentially in-combination impacts arising from increased Way Improvement recreational pressure where previously obstructed rights of way are Plan 2006 opened up to access.

The Small Sites and Development Management Plan does not include any additional requirement for dwellings in the Deane in the Deane above that in the Core Strategy, which has undergone its own HRA.

River Tone Catchment The strategies set out in the CAMS identify that water is limited in this Abstraction region and that additional abstraction in Taunton Deane will not be Management Strategy permitted unless necessary. Settlements in Taunton Deane receive water from Wimbleball, Clatworthy or Fulwood Reservoirs.

The Small Sites and Development Management Plan does not include any additional requirement for dwellings in the Deane in the Deane above that in the Core Strategy, which has undergone its own HRA.

- 28 ­ 6. Stage 1: Analysis of the Draft Site Allocations and Development Management Plan

Introduction 22. This screening assessment is made on the SADMP which was published in July 2014. Each policy is outlined in Table 11 below, together with a broad assessment of impacts. For full details of each of the policies refer to the SADMP consultation report. Table 12 similarly sets out the Strategic Site Allocation Policies.

23. Each SADMP policy has then been assessed against each of the qualifying features for the Natura 2000 site. Many policies will have a neutral effect on each site feature and are therefore not detailed any further within this report as they would not have any significant effect on a Natura 2000 site.

24. A screening assessment of the Somerset Levels and Moors carried out by Royal HaskoningDHV of the preferred option SADMP is included in Appendix 3 and is used to inform this assessment where appropriate.

Management for Nature Conservation Purposes 25. The SADMP does not introduce any management measures for nature conservation purposes at this stage.

Plan Analysis 26. Table 16 analyses the Development Management policies given in the draft SADMP and for each gives an assessment of its potential impact on Natura 2000 sites. Those policies that have a potential significant effect are highlighted in Orange. Where impacts are identified on a qualifying feature measures to avoid significant effects are assessed in Chapter 7.

Table 11: Assessment Schedule Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EC1 Other uses in employment areas None likely None No significant effect likely - The In addition to industry and warehousing policy concerns criteria for other (Use Classes B1b-B8) and sui generis uses within employment areas only uses of a similar nature within permitted employment areas, other employment activities that generate an appropriate employment alternative (other than main town centre uses such as retail, leisure and office) within existing and committed employment areas, will generally be permitted subject to the following criteria:

A. Other relevant development plan policies being satisfied;

- 29 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected B. The proposal must be in a location accessible by means of a range of transport modes including public transport; C. Must not undermine the operational capabilities of Class B uses in the area; D. Where applicable, appropriate landscaping and screening.

Within larger employment areas (normally in excess of 8 ha) ancillary facilities which support the functioning of the employment area including childcare facilities, cafes and sandwich shops, banks and health and fitness facilities are also likely to be acceptable subject to the above criteria and provided they are not of a scale to become a destination in their own right and operational hours are limited to the hours of public transport accessibility.

TC1 Activities within primary retail None likely None No significant effect likely - The frontages policy concerns the proportion of In order to sustain and enhance the shops retained in frontages only vitality and viability of the retail core, within the Primary Shopping Frontages of Taunton and Wellington as defined on the inset Proposals Maps, non-retail activity falling within Use Classes A2, A3, A4 and A5 and other main town centre uses will be permitted at ground floor level where:

A. The proposal would not result in the number of non Class A1 units exceeding 25% of the frontage block within which the unit is located and/or the unit does not form an important, visual corner plot where the loss would undermine the vitality or viability of the immediate area; B. Within any frontage block, the maximum number of units falling within Classes A2, A4 and A5 and sui generis uses should not exceed 15%; C. The proposal would not result in more than two adjoining units permitted for non Class A1 uses in any one frontage block; or D. It allows for the restoration or rehabilitation of a listed building which is currently in a poor state of repair and which has been actively marketed for

- 30 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected retail use but remained vacant for a significant period of time; and

For all proposals: E. By condition, the use is open during normal (Monday to Saturday, 9-5pm) operating hours. F. By condition and if considered necessary, later operating hours may be restricted to protect the amenity of surrounding occupants and the vitality and viability of the area generally.

TC2 Activities within secondary retail None likely None No significant effect likely - The frontages policy concerns the flexibility for Within the secondary shopping services in frontages only frontages of Taunton and Wellington as defined on the inset Proposals Maps proposals for additional or enhanced retail facilities will be permitted.

Permission will also be granted to other uses which: A. Are appropriate and complementary to a town centre location; B. Generate customer activity; C. Retain commercial frontage; and D. Would not result in more than two adjoining units permitted for non Class A1 uses.

TC3 Local Shopping None likely None No significant effect likely - The Within existing Local or District Centres policy concerns the criteria for shown on the Proposals Map or proposals for shops only proposed through Plan allocations, development proposals will be expected to:

A. Generate a reasonable level of footfall and be of general public interest or service; B. Maintain an appropriate balance of uses in that centre; C. Would not give rise to unacceptable environmental effects which could not be overcome by the imposition of conditions; D. Maintain or provide active ground floor frontages.

Outside of defined centres but within defined settlement limits only, additional individual convenience shops and public houses will be

- 31 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected permitted subject to it being: i. Of a scale to primarily serve a 'walk­ in' catchment not otherwise served by or allocated for such a use; ii. Consistent with other Development Plan policies; and iii. Subject to no adverse impact upon the vitality and viability of a defined local or district centre (existing or proposed).

TC4 Primary shopping areas (PSA) None likely None No significant effect likely - The A sequential assessment will be policy concerns assessment of required for all retail proposals falling retail proposals only beyond the Primary Shopping Area (PSA) boundaries for Taunton and Wellington town centres as indicated on the relevant inset Proposals Maps.

Proposals that fall outside of the PSA will, where appropriate, require an impact assessment against planned and existing investment in the town centre.

TC5 Out-of-centre proposals Loss of habitat Hestercombe Uncertain – As the policy is non- Outside of the town centre or Primary House SAC locational there is potential for out Shopping Area for retail proposals, Disturbance of centre occurring to the north of change of use, development or from street Taunton and / or Monkton removal or variation of conditions or lighting Heathfield legal agreements for main town centre uses will only be acceptable where:

A. No sequentially preferable site is available, including consideration of alternative formats for the proposed uses; B. It would not have a significant adverse impact on the vitality, viability and diversity of an existing centre including local consumer choice and trade in the centre and taking into account the cumulative impact of recently completed developments, planning permissions and development plan allocations; C. It would not impact on existing, committed or planned investment within a centre; D. The proposal is well related to the town centre or Primary Shopping Area for retail proposals and accessible by public transport, cycling and pedestrians.

Specifically in relation to retail

- 32 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected proposals; E. Comparison retailing is restricted to an appropriate broad category of goods which cannot easily be sold from a centre and transportable by means other than a car, van or similar vehicle; F. The sale of related, non bulky type comparison goods, will only be acceptable if they remain incidental to the permitted category of goods.

H1a Permanent Rural workers dwellings Loss and / or Hestercombe Uncertain - The policy is for new New permanent agricultural worker fragmentation House SAC dwellings in the countryside to dwellings will only be allowed to of habitat support workers employed there. It support existing activities on well- Holme Moor is non-locational and therefore established units, where: Local and Clean could be located within SAC A. There is a clearly established disturbance to Moor SAC boundaries or features outside a existing functional need; birds designated site which supports its B. The need relates to a full-time Quants SAC integrity, e.g. structural habitat for worker, or one who is primarily bats employed in agriculture and does not Somerset relate to a part-time requirement; Levels and New dwellings in areas that C. The unit and the activity concerned Moors SPA / ecologically support birds may have been established for at least Ramsar cause localised displacement three years, have been profitable for at resulting in loss of resource least one of them, are currently financially sound, and have a clear prospect of remaining so; D. The functional need could not be fulfilled by another existing dwelling on the unit, or any other existing accommodation in the area which is suitable and available for occupation by the workers concerned; and E. Other planning requirements, including definition of domestic curtilage, access, or impact on the countryside, are satisfied.

Criteria A to E will also apply in instances where justification can be provided for other occupational dwellings associated with rural-based enterprises. In such cases, the enterprise itself, including any development necessary for the operation of the enterprise would need to meet with the provisions of Policy DM2 of the adopted Core Strategy. Where the above criteria can be satisfied by an applicant, new dwellings will be of a size commensurate with the established functional requirement.

Occupancy conditions will be applied

- 33 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected to new permanent dwellings. Applications to remove these conditions will not be permitted unless: i. The dwelling is no longer needed on that unit for the purposes of agriculture or other rural based enterprises; ii. There is no current demand for dwellings for agriculture or other rural based industries in the locality; and iii. The dwelling cannot be sold or let at a price which reflects its occupancy period for a reasonable period to be agreed with the local planning authority.

H1b Temporary rural workers dwellings Loss and / or Hestercombe Uncertain - The policy is for new If a new dwelling is essential to support fragmentation House SAC dwellings in the countryside to a new agricultural or other rural-based of habitat support workers employed there. It enterprise, whether on a newly-created Holme Moor is non-locational and therefore unit or an established one, it should Local and Clean could be located within SAC normally, for the first three years, be disturbance to Moor SAC boundaries or features outside a provided by a caravan, a wooden birds designated site which supports its structure which can be easily Quants SAC integrity, e.g. structural habitat for dismantled, or other temporary bats accommodation. It should satisfy the Somerset following criteria: Levels and New dwellings in areas that Moors SPA / ecologically support birds may A. Clear evidence of a firm intention Ramsar cause localised displacement and ability to develop the enterprise resulting in loss of resource concerned; B. A clearly demonstrated functional need; C. Clear evidence that the proposed enterprise has been planned on a sound financial basis; D. The functional need could not be fulfilled by another existing dwelling on the unit, or any other existing accommodation in the area which is suitable and available for occupation by the workers concerned; E. Other normal planning requirements can be satisfied including definition of domestic curtilage, siting and access, are satisfied; and F. An occupancy condition will be applied and permission tied for a maximum period of three years and not normally renewed.

If permission for temporary accommodation is granted, permission for a permanent dwelling should not subsequently be given unless Policy H1a can be satisfied.

- 34 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected C1 Reserved land for educational Habitat Loss Hestercombe Uncertain – all the sites lie outside purposes House SAC the zone of influence of the The following sites are reserved for Disturbance Hestercombe House SAC except educational purposes, as shown on the due to lighting potentially land at the Staplegrove Proposals Map: urban extension. Playing fields would be considered to be hostile A. St Augustine's School, Taunton; habitat for lesser horseshoe bats B. Land at Longrun off Heron Drive, Taunton; C. Land west of Courtfields School, Wellington; D. Land at Croft Way for Kingsmead Community School, Wiveliscombe; E. Land west of Wiveliscombe Primary School; F. Land north east of Bishops Lydeard Primary School.

In addition, land at Staplegrove Urban Extension will need to be provided for playing fields for Taunton Academy.

C2 Provision of recreational open None likely None No significant effect likely – The space policy concerns the need for The Council will seek to ensure that recreational space within increased demand for open space developments and the implications arising from new residential for design. development is met in line with relevant standards.

Applicants will be expected to demonstrate through a land-use budget how they have responded to this standard..

C3 Protection of recreational open Habitat Loss Hestercombe Uncertain – The policy states that space House SAC ‘Equivalent provision in a nearby Proposals involving the loss of Disturbance and accessible location is made to recreational facilities - including due to lighting at least an equal standard and with allotments, children’s play areas, equal community benefit’. provision for teenagers, parks and recreation grounds, outdoor sports This could potential be in areas facilities, cemeteries and churchyards, used lesser horseshoe bats on the amenity open space, indoor sport and northern edges of Taunton and recreation facilities, woodlands, Monkton Heathfield orchards, and semi-natural open space will not be permitted unless:

A. There is an excess of good quality recreational facilities of the type which would be lost, sufficient to meet local demand; or B. The proposed development provides recreational or community benefit greater than the long-term recreational value of the recreational

- 35 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected facility that would be lost; or C. Equivalent provision in a nearby and accessible location is made to at least an equal standard and with equal community benefit; or D. In the case of a school or college playing field only; the land is needed for the development of educational buildings and/or associated facilities, and adequate playing fields to meet statutory requirements would be retained or provided, and E. It is not required for other recreational uses.

C4 Protection of community facilities None likely None No significant effect likely – The The loss or change of use of existing policy concerns the protection of community, cultural and social facilities community facilities only will only be permitted where:

A. Evidence is submitted to demonstrate that the facility is not viable; and B. It could not be put to another similar, community use; or C. Replacement facilities are provided on site, or within the vicinity to meet the needs of the local population. In the case of destination facilities serving more that one community, it must be demonstrated that the need can be met in an alternative or existing facility in Taunton, Wellington or a defined rural centre and is accessible to its intended users by a range of sustainable transport modes.

C5 Provision of Community Facilities None likely None No significant effect likely – The The Council will seek to ensure that policy concerns the provision of increased demand for community halls community facilities only arising from new development is met in line with the relevant standards. Provision for new community halls will be secured through CIL although applicants will be expected to demonstrate through a land-use budget how they have responded to the standard.

- 36 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected C6 Accessible facilities None likely None No significant effect likely – The Within the public realm of major policy concerns access provision to development schemes with public facilities only access and serving a wider than local catchment area, provision must be made for fully accessible changing and toilet facilities. There should be enough space for those who cannot use standard accessible facilities and must contain the correct equipment including a toilet, shower, height adjustable changing bench and a hoist. A1 Parking requirements None likely None No significant effect likely – Parking provision in new development The policy concerns parking will normally be required to make standards within towns only provision for car parking in accordance with the standards in Appendix F.

In order to promote sustainable travel and to make efficient use of development land, the Borough Council will also consider the need for car parking against the following criteria:

A. The impact on urban design; B. The accessibility of the development by public transport, walking and cycling, and its proximity to employment and services; C. For residential development, the type and mix of the proposed dwellings.

Reductions in the level of car parking provision will be expected for elderly persons', student and single persons' accommodation, and for developments involving the conversion of buildings where off-road parking provision may be difficult to achieve. Car-free developments will be sought in appropriate locations, such as within or adjacent to Taunton and Wellington town centres.

The Borough Council will require all development to make provision for cycle parking equal to or in excess of the standards set out in Appendix F..

- 37 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected A2 Travel planning None likely None No significant effect likely – the All development proposals which policy concerns travel planning generate a significant amount of only movement will be required to include a travel plan. Where a travel plan is required, necessary measures will include:

A. Appointment of a travel plan co­ ordinator; B. Modal split targets (car/employee ratio) for non-residential developments; C. Monitoring and review procedures; D. Provisions in relation to speculative development, multi-occupation and future occupiers; E. Measures to manage travel generated by visitors to a site; F. Agreed time periods for contributions to scheme start-up costs; G. In phased developments, trigger points for the introduction of transport measures.

A3 Cycle network26 Fragmentation Hestercombe Uncertain – The policy is not Any new development should not of habitat House SAC locationally specific and where conflict with and where relevant appropriate is to loosely defined for provide for: Disturbance the purposes of the habitats from lighting Regulations. Lighting could lead A. On and off-road cycleways as the severance of flight lines shown on the Proposals Map; especially through the use of street B. Traffic calming, traffic management lighting to which lesser horseshoe and junction re-design; bats are adverse. C. Convenient and secure cycle parking facilities; D. Provision of lighting on paths within and where appropriate, between urban areas to enable use after dark.

26 In additional TDBC should be aware of the requirement to assess ‘Favourable Conservation Status’ of European protected species under regulation 9 of the Habitats Regulations.

- 38 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected A4 Protection of disused transport None likely None No significant effect likely – the corridors policy concerns transport corridors Proposals which would affect disused only which are located away from railway lines or canals will only be the zone of influence of SACs in permitted where a corridor suitable for Taunton Deane the potential re-use of the route for its original purpose is provided.

Where redevelopment takes place at a location where continuity of a former railway or canal has previously been lost, provision should be made for the potential restoration of the continuous line of route.

Within Taunton Deane the routes concerned are: former Taunton - Chard railway line, former Taunton ­ Barnstaple railway line, former Grand Western Canal.

DM6/4 Accessibility of development None likely None No significant effect likely – the Residential development should be policy sets distance criteria for within walking distance of, or should access from new development to have access by public transport to, services employment, convenience and comparison shopping, primary and secondary education, primary and secondary health care, leisure and other essential facilities.

All major non-residential development should be accessible within walking distance or by public transport to a majority of its potential users. Provision should also be made for cycling between residential development and non-residential facilities, or between a non-residential development and its catchment area, where these lie within 5km of the development. I1 Power lines Fragmentation Hestercombe Uncertain – the policy is not Where appropriate, the siting of and /or loss of House SAC locational and potentially features overhead lines should follow the habitat used by lesser horseshoe bats Holford Rules, positioned to minimise Somerset could be lost where lines are the impact on landscape and amenity, Mortality or Levels and undergrounded causing severance whilst also having regard to public barrier to birds Moors from feeding areas. No restoration safety. Consideration should be given is mentioned. to undergrounding local power lines (66kv and below) where the New power lines have the potential environmental reasons can be justified to be a source of mortality or and would not render the development present a barrier to movement of unviable. birds moving between SPA / Ramsar sites

- 39 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected I2 Telecommunications None likely None No significant effect likely – Proposals for the siting of The policy concerns the siting and telecommunication equipment must location of telecommunication demonstrate that they have sought to masts which are unlikely to affect use sites or solutions that minimise SAC features present in the Deane environmental and visual impact and aim to keep the number of masts and sites to a minimum consistent with the efficient operation of the network. Where possible, existing masts, buildings and structures should be utilised. If a new site or structure is required, sound justification must be provided. Consideration should be given to the sympathetic design and sensitive siting of communications infrastructure, particularly in areas where pedestrian and disability access could be compromised.

I3 Water management None likely None No significant effect likely – The Proposals for residential or commercial policy is regarding development development within the consultation within a certain distance of sewage zone of a sewage treatment works or infrastructure and does not affect within 15 metres of a standard SAC features present in the Deane pumping station must demonstrate through an impact assessment that they are not adversely affected by odour, noise or vibration. Proposals that are affected will not be agreed without adequate mitigation.

I4 Water infrastructure None likely None No significant effect likely – The Adequate foul drainage/sewage policy is for adequate drainage treatment facilities and surface water within development only disposal shall be provided for all new development. Separate systems of drainage with points of connection to the public sewer system or outfalls will be required. Surface water shall be disposed of by Sustainable Urban Drainage Systems (SUDS) unless it can be demonstrated that it is not feasible.

- 40 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected ENV1 Protection of trees, woodland, None likely None No significant effect likely – The orchards, and hedgerows policy concerns the protection of Development which would harm trees, trees, woodlands and hedgerows, woodlands, orchards, historic all of which are used by lesser parklands and hedgerows of value to horseshoe bats from the the area's landscape, character or Hestercombe House SAC wildlife will not be permitted. Where the loss is unavoidable, adequate provision must be made to compensate for this loss.

The proper management of this resource for nature conservation purposes will be sought.

ENV2 Tree planting within residential None likely None No significant effect likely – Policy areas is for trees in residential areas only The planting of trees within new residential developments will be sought where this would benefit wildlife and biodiversity, enhance landscape or public amenity. Trees should be planted in: A. Communal areas and along streets or/and between buildings; and B. On highway verges (depending on safety issues and reasonable cost of future maintenance).

Development proposals should where possible provide a broad mix of native and non-native trees in new residential developments. The proper management of this resource for nature conservation purposes will be sought.

ENV3 Special Landscape Features None likely None No significant effect likely – The Development which would harm the policy relates to the designation of appearance, character and contribution landscape features only to landscape quality of Special Landscape Features (as shown on the Proposals Map) will not be permitted unless appropriate mitigation measures would reduce such harm to an acceptable level.

ENV4 Archaeology None likely None No significant effect likely – The Where a development proposal affects policy relates to the archaeology a site of archaeological importance, only Area of High Archaeological Potential, or it is known or suspected that the development could affect archaeological remains, developers must provide for satisfactory evaluation of the archaeological value of the site,

- 41 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected and the likely effects on it as part of the planning process.

Development affecting sites or the setting of designated heritage assets will not be permitted unless their archaeological and historic interest, character and setting would be preserved. Designated heritage assets of archaeological importance should be preserved in situ. Proposals which do not provide for this will not be permitted unless:

A. The development would make preservation in situ physically impossible and the remains are not of sufficient importance to outweigh the need for development; and B. Developers would make adequate provision for excavation and recording of remains affected.

Where evaluation does not justify designation as a site of national or county importance and development is to be allowed, developers must provide for an adequate programme of works. ENV5 Development on, and adjacent to or None likely None No significant effect likely – rivers in the vicinity of Rivers and the and the canal lie outside the zone Canal27 of influence of SACs in the Deane. Development proposals on, adjacent to The River Tone is upstream of the or in the vicinity of rivers, streams and Somerset Level and Moors SPA / the canal shall: Ramsar. However, the policy is A. Improve public access to, along and unlikely to affect features of these from the waterway and improve the sites environmental quality of the waterway corridor; B. Optimise views of water space through siting, configuration, and orientation of buildings, recognising that appropriate boundary treatment and access issues may differ (between the towing path and offside of the canal); and C. Prevent adverse impact on amenity including noise, odour, visual and lighting impacts unless adequate compensation and mitigation is provided as part of the application.

27 In addition TDBC should be aware of the requirement to assess ‘Favourable Conservation Status’ of European protected species under regulation 9 of the Habitats Regulations 2010. There are potentially significant adverse effects on populations of bats, particularly Daubenton’s, and otter through removal of habitat and disturbance from street lighting.

- 42 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected ENV6 Wellington’s burgage patterns None likely None No significant effect likely – The policy concerns Wellington only Proposals for the development of land and lies outside the zone of behind premises in High Street and influence of any SAC Fore Street should seek to retain the existing burgage patterns.

D1 Taunton's Skyline None likely None No significant effect likely – The Development which would detract from policy concerns Taunton’s skyline the distinctive character and only attractiveness of Taunton's skyline will not be permitted.

D2 Approach routes to Taunton and None likely None No significant effect likely – the Wellington policy is regarding the visual quality Development which would harm the of setting only visual qualities of routes into and out of Taunton and Wellington will not be permitted.

D3 Outdoor advertisements and signs None likely None No significant effect likely – the Proposals for adverts and signs will be policy is regarding the visual quality permitted unless: of setting only A. Their siting, design, appearance, proportion and materials cause disharmony with or detract from their surroundings, including the design, character, architectural features, fabric and finishes of any supporting building or structure. Any signage, including projecting signage, should be below first floor window level only and any internal illumination should emphasise lettering and logos rather than the background itself; B. They intrude upon or harm views to and from the countryside, conservation areas, listed buildings, scheduled monuments or landmarks; C. They are unduly prominent or create visual clutter when viewed with any existing signs; D. They present a hazard to public safety.

D4 Shopfronts None likely None No significant effect likely – the Proposals for the alteration or policy is for shop fronts only construction of shopfronts will be permitted, provided that:

A. The shopfront, including any signage, is well proportioned, well suited to the character of the building of which it forms a part and of the street in which it is situated; B. Independent ground floor access to

- 43 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected the upper floors is retained, except where a safe and convenient rear or side access is available or is provided as part of the development; C. Materials should be appropriate to the character of the building and surrounding area; D. If the property is or would impact upon a listed building or conservation area, the colour scheme for any shopfront or signage is of a palette appropriate to that building or surrounding area; E. Applications for external grilles or shutters will usually only be acceptable provided that there is a demonstrable need for such a security measure which cannot be met by other means, that they do not detract from any architectural feature or the street scene generally and that they are designed and finished in a way which minimises their visual impact and is compatible with the shop front. D5 Extensions to dwellings Loss of or Hestercombe Potential significant effect – The Extensions to dwellings will be disturbance to House SAC policy is for extension of existing permitted provided they do not harm: roost sites dwelling and may affect roof A. The residential amenity of other spaces in which lesser horseshoe dwellings; bats roosts. Lesser horseshoe bats B. The future amenities, parking, are dependant on night roosts to turning space and other services of the exploit feeding areas away from dwelling to be extended; and the main roost28. Loss of or C. The form and character of the disturbance to these roosts could dwelling and are subservient to it in mean that feeding areas become scale and design. unviable and hence affect the conservation objectives of the SAC.

D6 Ancillary accommodation Loss of or Hestercombe Potential significant effect – The The conversion of an appropriate disturbance to House SAC policy for conversion of ancillary building within the curtilage of a roost sites buildings. Lesser horseshoe bats dwelling for ancillary accommodation are dependant on night roosts to will be permitted. The erection of a new exploit feeding areas away from building within the curtilage of the main roost. Loss of or a dwelling for ancillary accommodation disturbance to these roosts could will not be permitted unless: mean that feeding areas become unviable and hence affect the The proposal would be less damaging conservation objectives of the to the character of the main dwelling or SAC. the surroundings than an extension or conversion which meets the need; It would be close enough to the main

28 Knight, T & Jones, G. 2009. Importance of night roosts for bat conservation: roosting behaviour of the lesser horseshoe bat Rhinolophus hipposideros. Endang Species Res. 8: 79–86, 2009.

- 44 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected dwelling to maintain a functional relationship; It does not harm the residential amenity of other dwellings; It does not unacceptably prejudice the future amenities, parking, turning space and other services of the main dwelling; and It does not harm the form and character of the main dwelling and is subservient to it in scale and design.

Where ancillary accommodation is permitted, planning control over subsequent use or sale as a separate dwelling will be imposed.

D7 Design quality None likely None No significant effect likely – The New housing developments shall policy is concerned with design create a high standard of design quality quality and sense of place by:

A. Creating places with locally inspired or otherwise distinctive characteristics and materials; B. Reflecting the site and its context, including existing topography and landscape features; and C. Creating well designed streets and places which are easily legible for residents and visitors.

D8 Safety Fragmentation Hestercombe Uncertain –The policy is not The design of new developments shall of habitat House SAC locationally specific and could lead incorporate measures to reduce the the disturbance from street lighting likelihood of crime which are Disturbance as lesser horseshoe bats which compatible with the need to create an from lighting require dark areas29 could result in attractive and sustainable layout. This severance of flight lines on the should include the following elements: outer edges of development north of Taunton and Monkton Heathfield A. Maximising the number of neighbouring properties with entrances on street elevations; B. Locating public spaces, circulatory routes and car parking areas where they are visible from within the maximum number of properties; C. Minimising the possibility of direct access from public areas to the rear gardens of dwellings; D. Ensuring that the layout of buildings, landscaping and lighting avoids the creation of hidden or dark areas; and

29 e.g. see Stone, E.L., Jones, G., & Harris, S. 2009. Street lighting disturbs commuting bats. Current Biology 19, 1123-1127.

- 45 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected E. Incorporating a mix of land uses which encourages activity throughout the day, where this is consistent with accessibility and residential amenity.

D9 Co-ordinated approach to None likely None No significant effect likely – The development and highway planning policy is concerned with A co-ordinated approach should be coordination within development for adopted to the design of development highways and its associated highways. This should include:

A. Providing for safe walking and cycling routes; B. Promoting an inclusive environment that recognises the needs of people of all ages and abilities, including the need for social interaction; C. Reflecting and supporting pedestrian desire lines in networks and detailed designs; D. Creating networks of streets that provide permeability and connectivity to main destinations and a choice of routes; E. Developing street character types with reference to both the place and movement functions of each street; and F. Designing to keep vehicle speeds at or below 20 mph on residential streets unless there are overriding reasons for accepting higher speeds. Where appropriate, the Council will seek a flexible approach to street layouts and the use of locally distinctive, durable and maintainable materials, street furniture and soft landscaping, including trees.

D10 Dwelling sizes (proposed) None likely None No significant effect likely – The Specification of dwelling sizes policy is concerned with the floor area of dwellings only

D11 Subdivision of residential properties None likely None No significant effect likely – The To ensure that the needs of small policy is concerned with divisions households are catered for, proposals within residential property only for subdivision of residential properties into a number of dwellings within settlement limits will be permitted, provided that:

A. The existing residential property has a floor area greater than 115 square metres;

- 46 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected B. There would be adequate vehicular access, car parking, cycle storage, amenity space and provision for refuse storage; C. The accommodation provided would be acceptable taking into account the intensity of occupation envisaged; D. The proposed units would be self- contained; E. The character of the area and amenities of adjacent residents would not be harmed; and F. The proposal would not harm the character of the area having regard to the existing number of converted and non-family dwellings in the vicinity.

D12 Amenity space None likely None No significant effect likely – The New residential development will be policy is concerned with the expected to provide amenity space to amenity of dwellings only the following standards:

Houses of 2, 3 or more bedrooms should provide a private garden, of adequate proportions for the size of house proposed, for exclusive use by occupants of that house; Flats of 3 or more bedrooms should provide either a private balcony or terrace of usable level space, or, in the case of ground floor flats, direct access to a private or shared garden; 2 bedroom flats should comply with the same requirements as 3 bedroom flats, with the exception that access to a private shared garden will be acceptable as an alternative to a private balcony or terrace; 1 bedroom flats and bedsits should provide either access to a private shared garden, or to a private balcony or terrace of usable, level space . Adequate space and provision should be made in respect of all residential units for the safe, discreet and conveniently accessible storage of refuse and recycling.

- 47 ­ Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected D13 Public art Disturbance Hestercombe Uncertain – The policy is All development in excess of 15 House SAC concerned with public art but is not residential units or 2500 square metres specific about location or type and (gross) commercial floorspace will be therefore could include that which required to contribute towards the is illuminated and hence cause provision of public art and public realm disturbance to bats enhancements through commissioning and integrating public art into the design of the buildings and the public realm, or in exceptional circumstances, by providing a commuted sum. Location decisions for public art in Taunton town centre will be informed by the Taunton Town Centre Design Code SPD.

SB1 Settlement Boundaries None likely None No significant effect likely – The Outside of the settlement boundaries policy is concerned with the with identified in Core Strategy policy SP1, proposals outside of settlement proposals will be treated as being limits and includes provision for within open countryside and assessed meeting environmental legislation against Core Strategy policies CP1 only (g,h,i) and DM2 unless:

A. It accords with a specific development plan policy or proposal; B. Is necessary to meet a requirement of environmental or other legislation; and C. Is designed and sited to minimise landscape and other impacts.

Spatial Policy Analysis 27. This section analyses the strategic site allocation policies given in the draft SADMP and gives for each an assessment of its potential impact on Natura 2000 sites.

28. Policy SP1 of the Core Strategy states: ‘In order to create and maintain sustainable, balanced communities, provision will be made for the delivery of new services, facilities and infrastructure including the creation of at least 11,900 new jobs and at least 17,000 new homes, including an appropriate balance of affordable and market housing, over the Plan period.

‘Proposals should make efficient use of land and follow a sequential approach, prioritising the most accessible and sustainable locations and maximising opportunities to make best use of previously developed land where possible. Proposals should promote principles of sustainable development by: minimising and/or mitigating pressures on the natural and historic environment and valuable natural resources; ensuring that sufficient utilities and infrastructure can be provided to support new development; and directing development away from areas of greatest flood risk

- 48 ­ wherever possible. Development will be focused on the most accessible and sustainable locations…

‘The Taunton urban area will remain the strategic focus for growth within Taunton Deane Borough and the wider sub-region and as such will be the focal point for new development. It will accommodate at least 13,000 new homes as well as 9,500 new jobs, sustainable transport links and a range of other higher order services and facilities that will enhance and strengthen its role.

‘Wellington will act as a secondary focus for growth within the Borough, developing its role as a market town serving a wider rural hinterland. It will accommodate at least 2,500 new homes in the period up to 2028 in addition to new employment development and retail growth commensurate with its role and function.

‘Major Rural Centres are identified as Wiveliscombe and Bishops Lydeard. These settlements will provide the focus for essential facilities within rural communities, this will include an appropriate balance of housing provision, small-scale employment and other local services. In these settlements allocations of up to 200 new net additional dwellings will be made through the Site Allocations Development Plan Document. Minor Rural Centres are identified as Cotford St Luke, Creech St Michael, Milverton, North Curry and Churchinford. New housing development at these locations will include an appropriate balance of market and affordable housing together with some live-work units and will be small scale allocations, sites within the development boundary (primarily on previously developed land) and sites fulfilling affordable housing exceptions criteria outside of development boundaries. For these settlements a total allocation of at least 250 new net additional dwellings will be made through the Site Allocations and Development Management DPD.

‘The villages of Ashbrittle, Ash Priors, Bishopswood, Blagdon Hill, Bradford-on-Tone, Burrowbridge, , Combe Florey, Corfe, Fitzhead, Halse, Hatch Beauchamp, Henlade, , Langford Budville, Lydeard St Lawrence, Nynehead, Oake, Pitminster, Ruishton, Sampford Arundel, Stoke St Gregory, Stoke St Mary, West Bagborough, West Buckland and West Monkton will retain settlement boundaries, as shown on the Proposals Map insets, and have no further allocations made through the Site Allocations and Development Management DPD, but some scope for small scale proposals within settlement limits.

‘Outside of the settlements identified above, proposals will be treated as being within Open Countryside.

29. This policy was assessed in the HRA of the Core Strategy and any counter acting measures have been included in the published version of that strategy. The assessment included consideration of recreational effects on SACs from all new development in the Deane.

30. The policy sets out the principles by which the small site allocations are made in the draft SADMP. Further information explaining the site selection process is outlined in the Strategic Urban Extensions Report. The locations referred to are highlighted in grey in that report and assessed below. Those policies that have a potential significant effect are highlighted in Orange will be further assessed for counter-acting measures and those in Red at Stage 2: Appropriate Assessment.

- 49 ­

31. Table 12 gives the assessment for Taunton.

Table 12: Analysis of Spatial Policies Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected SB1 Settlement Boundaries None likely None No significant effect likely – The Outside of the settlement boundaries policy is concerned with the with identified in Core Strategy policy SP1, proposals outside of settlement proposals will be treated as being within limits and includes provision for open countryside and assessed against meeting environmental legislation Core Strategy policies CP1 (g,h,i) and only DM2 unless:

A. It accords with a specific development plan policy or proposal; B. Is necessary to meet a requirement of environmental or other legislation; and C. Is designed and sited to minimise landscape and other impacts.

TAU1 Comeytrowe / Trull None likely None No significant effect likely – the The policy includes the following urban extension is not within the provisions. zone of influence of any SAC. Potential recreational impacts on Phased delivery of up to 2,000 new the Somerset Levels and Moors homes at an overall average of 35-40 SPA and Exmoor and Quantocks dwellings per hectare; SAC sites have been assessed under the HRA of the Core Strategy. A new mixed-use local centre comprising The SADMP does not propose any a convenience store (Class A1) of up to increase the housing numbers over 500 m2 (gross); plus 500m2 of other that stated in the Core Strategy retailing (Class A1), financial/professional services (Class A2), restaurants and cafes (Class A3), at least one public house (Class A4), take­ away (Class A5) and a community hall, together with 0.25 ha of land for a place of worship. Residential or office uses should be provided on upper floors;

A minimum of 5 hectares of serviced employment land comprising Class B1 b and c., Class B2 and Class B8 use; Land reserved (approx 2.5ha) for a 14­ class, 2-form intake primary school with pre-school facilities;

Allotment provision at 15.4sqm per dwelling;

Equipped playing fields at 45 square metres per dwellings;

For every dwelling with 2 or more bedrooms, 20 sq m of equipped and non-equipped children's play provision;

- 50 ­ Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected Provision of a new 'Green Wedge' extending through the site on either side of the Galmington Stream;

Sufficient areas of created or enhanced habitat to enable populations of those European protected species recorded on site to be maintained or enhanced. This habitat will need to be accessible to the species affected;

A link road between Honiton Road and the A38 Wellington Road to serve the development area. The design and layout of the road should be sensitive to the Trull village conservation area and should minimise the impact on the prominent ridgeline to the north-west of the site;

Other provisions are detailed in the draft SADMP TAU2 Staplegrove Disturbance Hestercombe Uncertain – There is a potential The policy includes the following from street House SAC significant effect on the lesser provisions. lighting horseshoe bat population of leading to Hestercombe House SAC from Phased delivery of up to 1,500 new habitat loss habitat loss either directly or due to homes at an overall average of 35-40 and introduced street lighting. However, dwellings per hectare; severance the policy itself includes mitigation from feeding of offsite replacement habitat new mixed-use local centre at the areas creation and woodland buffer intersection of radial and orbital routes planting. An initial calculation using adjacent to Kingston Road, comprising a the method agreed by Natural convenience store (A1) of up to 500 England for the Appropriate m2 (gross); 500 m2 of other retailing Assessment of the Core Strategy30 (A1), financial/professional services (A2), is provided in Appendix 1 restaurants and cafes (A3); at least one Nonetheless the policy does not public house (A4), take-away (Class provide for the control of street A5) and a community hall of not less lighting on lesser horseshoe bat than 500 sq m, together with 0.25ha of habitat, including any lighting that land for a place of worship. Residential may occur on foot and cycle routes or office uses should be provided on through the woodland buffer. upper floors; Potential recreational impacts on A minimum of 2 hectares of serviced the Somerset Levels and Moors employment land comprising Class B1 SPA and Exmoor and Quantocks b and c., Class B2 and Class B8 use; SAC sites have been assessed under the HRA of the Core Strategy. A 2.5ha site for a 14-class, 2-form intake The SADMP does not propose any primary school with pre-school increase the housing numbers over facilities; that stated in the Core Strategy

30 See Somerset County Council. 2009. Habitats Regulations Assessment of Hestercombe House SAC: Taunton Deane Borough Council Local Development Framework Core Strategy/ Site Allocations Development Plan Document and Somerset County Council Taunton Transport Strategy Review 2. Taunton: Somerset County Council/ Taunton Deane Borough Council

- 51 ­ Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected

An extension of the existing Green Wedge on either side of Mill Lease Stream, between Corkscrew Lane and the open countryside north of the existing 132kV power lines;

Equipped playing fields at 45 square metres per dwellings, plus playing fields for Taunton Academy in close proximity to the school;

For every dwelling with 2 or more bedrooms, 20 sq m of equipped and non-equipped children's play provision; Land for provision of allotments at 15.4 sq m per dwelling;

Diversion of or placing underground the existing 33kV power lines between the A358 and Rectory Road;

A new Northern Link Road extending from the Silk Mills Road roundabout on the A358 to Kingston Road, with provision for a future eastern extension around North Taunton;

Off-site woodland planting in accordance with the Hestercombe House SAC Appropriate Assessment to mitigate the impact of the development on Lesser Horseshoe bats. The off-site habitat should be functional prior to the commencement of any development;

Structural landscaping, including a 20m wide belt along the outer edges of the development areas, facing bat activity from Hestercombe SAC;

Other provisions are detailed in the draft SADMP

TAU3 Pyrland Farm Disturbance Hestercombe Uncertain – There is a potential The policy includes the following from street House SAC significant effect on the lesser provisions. lighting horseshoe bat population of leading to Hestercombe House SAC from Land at Pyrland Farm as shown on the habitat loss habitat loss either directly or due to Proposals Map is allocated for 45 and introduced street lighting. However, dwellings. severance the policy itself includes mitigation from feeding of offsite replacement habitat The site should make provision for the areas creation and woodland buffer creation of offset planting to compensate planting. Nonetheless the policy for the loss of any habitat for Lesser does not provide for the control of

- 52 ­ Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected Horseshoe Bats. street lighting on lesser horseshoe bat habitat, including any lighting Development proposals shall also that may occur on foot and cycle comply with other policy requirements in routes through the woodland buffer. the plan including strategic landscaping and planting, other environmental matters, affordable housing, design and mix of dwellings and recreational space, where appropriate.

TAU4 Ford Farm None likely None No significant effect likely - Potential recreational impacts on the Land at Ford Farm, Norton Fitzwarren, Somerset Levels and Moors SPA as identified on the Proposals Map, is and Exmoor and Quantocks SAC allocated for 450 dwellings. The site will sites have been assessed under the be required to deliver: HRA of the Core Strategy. The SADMP does not propose any A. The completion of flood channel works increase the housing numbers over to the Halse Water; that stated in the Core Strategy B. The completion of the Norton Fitzwarren bypass; and C. 1 hectare of employment land.

Development of this site will not be permitted to commence until such time as the flood channel works have been completed.

Development proposals shall also comply with other policy requirements in the plan including strategic landscaping and planting, other environmental matters, affordable housing, design and mix of dwellings and recreational space, where appropriate.

TAU5 Bishops Hull / Stonegallows None likely None No significant effect likely – the site is outside of ecological zones of Land at Bishops Hull / Stonegallows as influence for SAC / SPA / Ramsar shown on the Proposals Map is allocated sites for 70 dwellings. Development of this site should:

A. Special Landscape Feature... B. Respect the amenity and privacy of existing residents particularly on Bishops Hull Road and Gwyther Mead; and C. Make provision for improvements to Chute Water and carefully manage surface water drainage

- 53 ­ Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected TAU6 Silk Mills None likely None No significant effect likely – the site is outside of ecological zones of Land at Silk Mills as identified on the influence for SAC / SPA / Ramsar Proposals Map is allocated for sites employment purposes subject to the following criteria:

A. Uses are restricted to Class B1b (research and development), Class B1c (light industrial), Class B8 (storage and distribution) and other sui generis uses normally associated with an employment area; B. Respect the alignment of the former Grand Western Canal and allow future access for any tourism benefit; C. The design and landscaping respects the visual importance of the Green Wedge to the east and south; D. Ensure that the operational ability of the adjoining Park and Ride site is not compromised.

TAU7 The Uppers None likely None No significant effect likely – the site is outside of ecological zones of Land at the Uppers, Taunton School, as influence for SAC / SPA / Ramsar identified on the Proposals Map is sites allocated for 60 dwellings. Any proposal will need to ensure that alternative sport provision is made as part of the development of the site. TAU8 Remainder of Norton Fitzwarren None likely None No significant effect likely – the site Allocation is outside of ecological zones of influence for SAC / SPA / Ramsar MoD land at Cross Keys, Norton sites Fitzwarren, as indicated on the Proposals Map, is allocated for 30 dwellings. Land at Taunton Trading Estate, as indicated on the Proposals Map, is allocated for a mixed-use development comprising around xx dwellings and circa 3.3 hectares of employment land within Use Classes B1, B2 and B8.

TAU9 Hamilton Road Bus Depot None likely None No significant effect likely – the site is outside of ecological zones of Land at Hamilton Road Bus Depot, as influence for SAC / SPA / Ramsar indicated on the Proposals Map, is sites allocated for 50 dwellings.

TAU10 East of Crown Industrial Estate None likely None No significant effect likely – the site is outside of ecological zones of Land east of the Crown Industrial Estate influence for SAC / SPA / Ramsar as indicated on the Proposals Map is sites

- 54 ­ Policy Brief Description Potential Natura 2000 Comment Impact on sites Natura 2000 Potentially Sites Affected allocated for employment purposes subject to the following criteria:

A. Uses are restricted to Class B1b (research and development), Class B1c (light industrial), Class B8 (storage and distribution) and other sui generis uses normally associated with an employment area; B. Measures are taken to solve any ground stability and landfill gas problems; C. The design and landscaping respects the visual importance of the Green Wedge to the east and views from the road and rail routes to the south. TAU11 Former Priorswood Landfill None likely None No significant effect likely – the site is outside of ecological zones of Land at the former Priorswood landfill influence for SAC / SPA / Ramsar site, as indicated on the Proposals Map, sites is proposed for community woodland or other appropriate recreational uses.

TAU12 Blackbrook Recreational Open Space None likely None No significant effect likely – the site is outside of ecological zones of A site of 5.8 hectares at Blackbrook as influence for SAC / SPA / Ramsar indicated on the Proposals Map is sites allocated for recreational open space, subject to measures to preserve the protected species present on the site.

32. The following allocation sites have policies in the draft SADMP.

• WEL1: Tonedale Mill, Wellington • WEL2: Sewage Works, Wellington • MAJ1: Style Road / Burges Lane, Wiveliscombe • MAJ2: South of Croft Way, Wiveliscombe • MAJ3: South of Taunton Road, Wiveliscombe • MAJ4: Land at Taunton Road, Bishops Lydeard • MAJ5: Land west of Bishops Lydeard Station, Bishops Lydeard • MIN1: East of Dene Barton, Cotford St Luke • MIN2: Hyde Lane, Creech St. Michael • MIN3: North of school, Creech St. Michael • MIN4: Land off Hyde Lane, Creech St. Michael • MIN5: Land at Butts Way, Milverton • MIN6: Overlands, North Curry • MIN7: Knapp Lane, North Curry • MIN8: Ford House Farm, Churchinford

- 55 ­ 33. None of these sites fall within the ecological zones of influence of SAC, SPA or Ramsar sites. Any recreational effects on the Somerset Levels and Moors SPA / Ramsar, Exmoor and Quantocks Oak Woodlands and Exmoor Heaths SAC have been assessed under the HRA for the Taunton Deane Borough Council Core Strategy. The SADMP does not propose any additional housing numbers than what is specified in the Core Strategy.

Counteracting Measures 34. ‘During the screening stage, or other early stages, the plan making authority may be able to introduce counter-acting measures that would obviously avoid the possibility of a significant effect on a European site. This speeds the appraisal process in its early stages and enables the assessors to concentrate on those aspects of the plan that could have significant effects on European sites that are not easily eliminated. It narrows the scope of the appraisal and reduces the time and cost of undertaking it.’ (Tyldesley et al, 201231)

35. ‘Measures to avoid, cancel or reduce the effects of a plan on a European site (here referred to as avoidance measures, cancellation measures and reduction measures respectively) should be proposed as part of the plan and the plan making authority will take these into account in the appraisal, often collectively referred to as ‘mitigation measures’ (Tyldesley et al, 2012)

36. ‘Avoidance measures eliminate the likelihood of any effects on the European site. Cancellation measures have the effect of cancelling out potentially adverse effects on the European site before their effects are felt. Reduction measures are designed to reduce likely significant effects, perhaps to a level that is insignificant or in a way that makes them unlikely to occur.’ (Tyldesley et al, 2012)

37. The following policies and site allocations have been identified as having uncertainty with regard to significant effects on European sites and are listed in the Table 13 along with any counter-acting measures that will eliminate that effect. These could include adjustment to policy text. The policies in the SADMP should not only be read as a whole but in conjunction with those in the Taunton Deane Borough Council Core Strategy to which it is a supplement.

38. Policies where counter-acting measures, at this stage, do not negate the potential for a significant effect will require a Stage 2 ‘Appropriate Assessment’.

Table 13: Counter-acting Measures Policy / Brief Potential Natura 2000 Counter- acting Comment Site Description Impact on sites Measure Allocation Natura 2000 Potentially Sites Affected TC5 Out-of-centre Loss of habitat Hestercombe Policy CP8 of the Core No significant proposals Disturbance House SAC Strategy (CS) states that effect likely from street ‘Proposals that will have lighting an adverse impact on Natura 2000 and Ramsar

31 David Tyldesley and Associates, 2012. Draft Guidance for Plan Making Authorities in Wales: The Appraisal of Plans under the Habitats Directive.

- 56 ­ Policy / Brief Potential Natura 2000 Counter- acting Comment Site Description Impact on sites Measure Allocation Natura 2000 Potentially Sites Affected sites and/or features which provide ecological support for their conservation objectives will not be supported.’ And ‘Planning applications for development on sites within the Bat Consultation Zone will require a 'test of significance' under the Habitat Regulations to be carried out.’

H1a Permanent rural Loss and / or Hestercombe Policy DM2 of the Core No significant workers fragmentation of House SAC Strategy (CS) states that effect likely dwellings habitat all development in the Holme Moor countryside must be Local and Clean compliant with the disturbance to Moor SAC Habitats Regulations birds Quants SAC Policy CP8 (CS) states that ‘Proposals that will Somerset have an adverse impact Levels and on Natura 2000 and Moors SPA / Ramsar sites and/or Ramsar features which provide H1b Temporary rural ecological support for workers their conservation dwellings objectives will not be

supported.’ And ‘Planning applications for development on sites within the Bat Consultation Zone will require a 'test of significance' under the Habitat Regulations to be carried out.’

C1 Reserved land Loss of habitat Hestercombe The land is included No significant for educational Disturbance House SAC within Policy TAU2 which effect likely purposes from street will be assessed under lighting the Habitats Regulations at a project level. At the plan It will be subject to the provisions of policy TAU2 and CP8.

C3 Protection of Loss of habitat Hestercombe Policy CP8 of the Core No significant recreational Disturbance House SAC Strategy (CS) states that effect likely open space from street ‘Proposals that will have lighting an adverse impact on Natura 2000 and Ramsar sites and/or features which provide ecological support for their

- 57 ­ Policy / Brief Potential Natura 2000 Counter- acting Comment Site Description Impact on sites Measure Allocation Natura 2000 Potentially Sites Affected conservation objectives will not be supported.’ And ‘Planning applications for development on sites within the Bat Consultation Zone will require a 'test of significance' under the Habitat Regulations to be carried out.’

A3 Cycle network Fragmentation Hestercombe Policy CP8 (CS) states No significant of habitat House SAC that ‘Planning effect likely applications for Disturbance development on sites However, it is from lighting within the Bat recommended Consultation Zone will that an addition to require a 'test of paragraph 1.5.9 significance' under the as follows: Habitat Regulations to be carried out.’ ‘It may not always be necessary to use highway-type lights and less obtrusive methods should be considered in sensitive areas, such as where light averse bat species occur’

I1 Power lines Fragmentation Hestercombe Policy DM2 of the Core No significant . and /or loss of House SAC Strategy (CS) states that effect likely habitat all development in the Somerset countryside must be Mortality or Levels and compliant with the barrier to birds Moors SPA / Habitats Regulations Ramsar Policy CP8 (CS) states that Proposals that will have an adverse impact on Natura 2000 and Ramsar sites and/or features which provide ecological support for their conservation objectives will not be supported.’ And ‘Planning applications for development on sites within the Bat Consultation Zone will require a 'test of significance' under the Habitat Regulations to be

- 58 ­ Policy / Brief Potential Natura 2000 Counter- acting Comment Site Description Impact on sites Measure Allocation Natura 2000 Potentially Sites Affected carried out.’

D5 Extensions to Loss of or Hestercombe Policy CP8 (CS) states No significant dwellings disturbance to House SAC that ‘Planning effect likely roost sites applications for development on sites within the Bat Consultation Zone will D6 Ancillary require a 'test of accommodation significance' under the Habitat Regulations to be carried out.’

D8 Safety Disturbance to Hestercombe Policy CP8 (CS) states No significant habitat features House SAC that ‘Planning effect likely used for applications for commuting and / development on sites or feeding from within the Bat lighting effects Consultation Zone will require a 'test of significance' under the Habitat Regulations to be carried out.’

D13 Public art Disturbance to Hestercombe Policy CP8 (CS) states No significant habitat features House SAC that ‘Planning effect likely used for applications for commuting and / development on sites or feeding from within the Bat lighting effects Consultation Zone will require a 'test of significance' under the Habitat Regulations to be carried out.’

TAU2 Staplegrove Disturbance to Hestercombe Policy CP8 (CS) states No significant habitat features House SAC that ‘Planning effect likely used for applications for commuting and / development on sites For information or feeding from within the Bat Appendix 1 sets lighting effects Consultation Zone will out the likely require a 'test of amount of offsite significance' under the offset habitat Habitat Regulations to be creation required carried out.’ to develop the site

TAU3 Pyrland Farm Disturbance to Hestercombe Policy CP8 (CS) states No significant habitat features House SAC that ‘Planning effect likely used for applications for commuting and / development on sites For information or feeding from within the Bat Appendix 1 sets lighting effects Consultation Zone will out the likely require a 'test of amount of offsite significance' under the offset habitat Habitat Regulations to be creation required carried out.’ to develop the site

- 59 ­ Recommendation 39. Policy A3: Cycle Network was identified in Table 13 as benefiting from additional textual wording for clarification by giving an example of a ‘sensitive area’, which if affected could cause a significant effect on a European feature. Paragraph 1.5.9 should be amended as follows:

• ‘It may not always be necessary to use highway-type lights and less obtrusive methods should be considered in sensitive areas, such as where light averse bat species occur.’

- 60 ­ 7. Conclusion

40. Potential impacts on the lesser horseshoe bat feature of the Hestercombe House SAC were identified. However, policy the SADMP both sets out mitigation measures that counteract the effect of policy and site allocations and ensures that further Habitats Regulations Assessment will be required, as well as being a matter of Government policy and law, when individual developments within the SAC’s zone of influence are submitted for planning permission. Appendix 1 gives guidance on the amount of replacement habitat required to enable development to take place. This should inform Master Plans, which include more detail of development areas and up to date survey data to fully take account of potential impacts on the integrity of the Hestercombe House SAC. It is considered that a Sage 2 Appropriate Assessment is not required at this stage.

41. Other uncertainties in the draft SADMP have been resolved by reading the Plan as a whole and in combination with the Core Strategy, which has undergone its own Habitats Regulations Assessment prior to adoption by Taunton Deane Borough Council.

42. It is considered by Taunton Deane Borough Council that the draft Site Allocations and Development Management Plan is unlikely to have a significant effect on the integrity of European and Ramsar sites.

- 61 ­ Appendix 1: Assessment of

Introduction 1. The Somerset County Council Habitats Evaluation Procedure (HEP) is used in calculating the value of the habitat lost to lesser horseshoe bats due to proposed development.The HEP uses a Habitat Suitability Index and methodology which has been developed for lesser horseshoe bats, initially researched in 2008 and agreed to by Natural England for the Appropriate Assessment of the Habitats Regulations Assessment of the Taunton Deane Borough Council Core Strategy and based on a literature search, faecal analysis and invertebrate survey, and radio tracking. The scoring used at that time a decimal scale of 0 to1 has been translated into the current numeric range of 0 to 6 used in the current HEP used by Somerset County Council, which available as a pdf from the County’s biodiversity offsetting webpage .

Summary of the Habitat Evaluation Procedure

Introduction 2. The Habitat Evaluation Procedure is structured around the calculation of Habitat Units (HU), which are the product of a Habitat Suitability Index (quality) for a species and the total area of habitat (quantity) affected.

3. Habitat Suitability Indices (HSI) has been used in the United States and Canada since the early 1980s as way of assessing the impacts of development on species' populations and distributions and has been used to predict what needs to be created to maintain species' populations. HSI have also been used in conservation planning and has proven useful in the USA for such as screening permits in the Southeast and the comprehensive planning of refuges in the Northeast32. In Somerset they have been successfully employed in calculating the impacts of proposed development sites on habitat loss since 2009.

4. The process assumes that the suitableness of habitat for a species can be quantified - the HSI. The overall suitability of an area for a species can be represented as a product of the geographic extents of each habitat and the suitability of those habitats for the species33.

Description 5. The Integrated Habitat System coding is used as a base in applying scores to a species’ Habitat Suitability Index. The Integrated Habitat System (IHS)34 classification comprises over 400 habitat categories, the majority drawn from existing classifications, together with descriptions, authorities and correspondences arranged in a logical hierarchy that allow application for different purposes. The classification can be customised for a geographical area or special project use without losing data integrity.

32 http://www.fws.gov/r5gomp/gom/habitatstudy/Gulf_of_Maine_Watershed_Habitat_Analysis.htm 33 http://www.fort.usgs.gov/Products/Software/HEP/ 34 http://www.somerc.com/products-services/integrated-habitat-system-ihs/

- 62 ­ 6. The IHS represents a coded integration of existing classifications in use in the UK with particular emphasis on Biodiversity Broad Habitat Types, Biodiversity Priority Habitat Types, Annex 1 of the Habitats Directive and Phase 135.

7. In constructing the HSI the index scores are applied to each Habitat and Matrix, and Formation and Land Use / Management codes in the Integrated Habitat System (IHS) based on analysis of the ecological requirements, from existing literature and professional judgement, for each species assessed or mapped.

8. Each IHS ‘Habitat’ code will be scored on a scale of 0 to 6 (as defined below) using a potential or precautionary approach as a starting point. The score will be the same across each of the hierarchical levels of the IHS Habitat coding (e.g. poor is scored as 1 whether this is at broadest habitat level or priority habitat level unless there is discernible differences in the type of habitat used, e.g. oak or beech woodland36. This means that the full range of scoring is used before the modifiers (the IHS matrix, formation and management codes) are applied.

9. Matrix Codes37 are added to or subtracted from the Habitat Code to a maximum score of 6, e.g. grassland score 3 + scrub score 2 would equal 5. Where there is no effect from a Matrix type then a default score of 0 is used.

10. All other Codes are scored between 0 to 1 and are multipliers. Where there is no effect from formation or management codes then a default score of 1 is used.

11. Scores will be applied such that a precautionary approach or 'potential' approach is taken, e.g. if a species requires grassland which is most valuable when grazed then grassland scores the top score. This potential score will take into account a combination of the Habitat and Matrix codes. The management modifier would then maintain the habitat score at this high level by a multiplier of 1. If the management is not grazed a decimal multiplier is applied to reduce the value of the habitat. For example a grassland habitat is valued at 6 but by applying the relevant management code, i.e. either mown or other management type, the value of the habitat will be reduced. Only one management code is allowed.

Density Band 12. The HSI score is multiplied by the location of the proposed site in relation to that of the species record. The Consideration Zone (CZ) is divided into three Density Bands. The three Bands are, ‘A’ closest to the record, ‘B’ and ‘C’ furthest from the record valued at 3, 2 and 1 respectively. An example is shown in Figure A1 and the values given in Table A1 below.

Table A1: Density Band Scoring Band Score A 3 B 2 C 1

35 Phase 1 (JNCC, 1993) habitat mapping can be converted to IHS by using the software provided by Somerset Environmental Records Centre. 36 The 1 to 6 scale matches Defra's habitat distinctiveness range used in its metric. 37 IHS considers that patches of scrub and single trees are matrix habitat acting in combination with main habitats types rather than separate habitats in their own right.

- 63 ­ 13. The modifiers start from a confirmed record outward for the species affected. The CZ density band widths will vary from species to species depending on its characteristic use of its home range. For example species which use a single focus for a population, such as a bat roost or a pond for great crested newts, are likely to have a decreasing density of use the further removed from the centre (e.g. Rainho & Palmeirim, 201138; Knight, 200639; Rosenberg & McKelvey, 199940), whereas other species populations are spread throughout the area it occupies, such as common dormice which nest throughout the home range would have a large A band and small width B and C bands. The density bands used in this assessment are informed by the work of Knight (2006)41 .

Figure A1: Example of Density Bands within the Consideration Zone for a Species with Single Focus such as a roost

Calculating the Habitat Unit Value 14. For information the value of the proposed site to a species in Habitat Suitability value is calculated by using the HSI Score and the Density Band (See Table A1). The outcome of the Habitat Suitability Units used in the HEP is on a scale of 0 to 18, and is in line with that used for the habitat metric used by Defra in its biodiversity offsetting pilot projects 2012 - 2014.

38 Rainho, A. & Palmeirim, J. W. 2011. The Importance of Distance to Resources in the Spatial Modelling of Bat Foraging Habitat. PLoS ONE, April 2011, 6, 4, e19227. 39 Knight, T. 2006. The use of landscape features and habitats by the lesser horseshoe bat (Rhinolophus hipposideros). PhD thesis. University of Bristol 40 Rosenberg, D. K. & McKelvey, K. S. 1999. Estimation of Habitat Selection for Central-place Foraging Animals. Journal of Wildlife Management 63 (3): 1028 -1038. 41 Knight, T. 2006. The use of landscape features and habitats by the lesser horseshoe bat (Rhinolophus hipposideros). PhD thesis. University of Bristol

- 64 ­ Table A2: Matrix Combining Habitat Suitability Score and Density Band Habitat Suitability Score Poor Marginal Average Good Very Good Excellent

1 2 3 4 5 6 A (3) 3 6 9 12 15 18

B (2) 2 4 6 8 10 12

Band C (1) 1 2 3 4 5 6

15. The habitat offset required is calculated by multiplying the score by the hectarage of the habitat affected (hectares x [HSI / Band]) giving figure in Habitat Units. For example a HSI/Band score of 12 for an area of 1.50 hectares would give a value of 18 Habitat Units.

16. The area values used in calculating Habitat Units (HU) are in hectares and derived from interrogating OS Mastermap and the value entered into the calculation worksheet (Table 5). If more than one habitat is present in a single OS Mastermap polygon than then this need to be divided by editing a mapping layer with the total of the divided segments adding up to the hectares for the whole OS polygon.

17. Hedgerows and some watercourses are not mapped as separate polygons in OS Mastermap and if a width is not known a default width of 3 metres is used and multiplied by the length to give an area in hectares. These values are usually small and do significantly affect the overall area of a site and for simplicity’s sake and considering their value to wildlife are not deducted from the area of bordering fields, compartments or OS Mastermap polygons. If preferred calculations can be carried out separately for these features using linear measurements but the end result is the same, especially if a direct replacement value of the hedgerow or watercourse is required.

Fraction Multipliers 18. In order that any offset habitat creation would functionally replace habitat lost to development (and the need to take a precautionary approach in the case of EPS) a ‘fraction multiplier’ (also known as a ‘habitat multiplier’ or ‘compensation ratio’) is applied to the resultant Habitat Units needed to replace biodiversity lost to development in order to provide robust compensation, e.g. to maintain ‘favourable conservation status’. This may also be needed due to the limited nature of the surveys; that the IHS mapping does not include an assessment of habitat quality for a species; potential errors of omission; the use of ‘foreign’ data in establishing a HSI; non validation; and the variability of time required for the offset habitat to become functional.

19. A multiplier of 2 was established for the Habitats Regulations Assessment of the Taunton Deane Borough Council Core Strategy in 2009. This is now replaced by those established subsequently by Defra.

20. As different habitats have different levels of difficulty in creation or restoration of there will be

- 65 ­ different risks associated with each. Defra (2011a42) consider that restoration is likely to be a lower risk than creation.

21. ‘Once there is an estimate of the failure risk, it is possible to work out the necessary multiplier to achieve a suitable level of confidence (Bill Butcher pers com; Moilanen, 200943; Treweek et al, 201044). The work of Moilanen provides a basis for different multipliers of various levels of risk. We have used this work to come up with categories of difficulty of restoration/expansion, and associated multipliers, as set out in Table A3 below.’ (Defra, 2011a)

Table A3: Multipliers for different categories of delivery risk (Defra, 2011a) Difficulty of recreation/restoration Multiplier Very High 10 High 3 Medium 1.5 Low 1

22. Spatial risk is considered to be taken account as likely flight lines have been established through radio tracking and hedgerow survey.

23. In delivering mitigation there may be a difference in timing between the implementation of the development and the functionality and maturity of the replacement habitat. Where a time lag occurs a multiplier will be applied to take account or the risk involved to the ‘no net loss’ objective. Defra (2011a) have based the time period multiplier recommendation from their Environmental Liability Directive guidance and that used in the Treasury Green Book, which recommends a discount rate of 3.5%.

Table A4: Multipliers for different time periods using a 3.5% discount rate Years to target condition Multiplier 5 1.2 10 1.4 15 1.7 20 2.0 25 2.4 30 2.8 32 3

24. In this case where broadleaved woodland with water bodies are considered for replacement habitat then a multiplier of 1.5 for difficulty and 1.7 for temporal lag is used based on tables in the Habitat Evaluation Procedure methodology45.

42 Defra. 2011a. Biodiversity Offsetting. Technical paper: proposed metric for the biodiversity pilot in England. London: Department for Environment, Food and Rural Affairs. https://www.gov.uk/government/publications/technical-paper-the-metric-for-the-biodiversity-offsetting-pilot-in-england 43 Moilanen, A., Van Teeffelen, A., Ben-Haim, Y. & Ferrier, S. 2009. How much compensation is enough? A framework for incorporating uncertainty and time discounting when calculating offset ratios for impacted habitat. Restoration Ecology 17, 470-478. 44 Treweek, J., Butcher, B. & Temple, H. J. 2010. Biodiversity offsets: possible methods for measuring biodiversity losses and gains for use in the UK. In Practice, 69, 29-32 45 www.somerset.gov.uk/biodiversityoffsetting

- 66 ­ 25. An allowance for existing habitat on the replacement habitat creation site as this will be lost or included in the value of any enhancement. The formula applied to offset losses of existing habitat at the offset site is:

Area Equivalent of Habitat Units Needed to Offset from Development (Habitat Value of Desired Habitat Type – Habitat Value of Offset Habitat Creation Site)

Replacement of Habitat Value Lost to Lesser Horseshoe Bats 26. The most significant foraging habitat for lesser horseshoe bats is woodland associated with water (Barataud et al, 200046), In Belgium research has shown that the feeding grounds for lesser horseshoe bats were deciduous woodland along with copses or mixed coniferous woodland. Bats selected areas that were undulating countryside with hedgerows, tree lines and woodland in preference to flat open intensively farmed areas. (Motte & Dubois, 200247) In fragmented habitats linear features, such as hedgerows, provide valuable corridors between roosts and foraging areas. Commuting corridors are important features for lesser horseshoe bats as they avoid crossing open areas and are vulnerable to the loss of these corridors. (Bat Conservation Trust, 200548)

27. The adopted Core Strategy has previously been subjected to appropriate assessment for development sites north of Taunton for effects on the same SAC49. The sites identified above are now assessed by the Habitat Evaluation Procedure, which has been updated from the method previously developed in consultation with and agreed by Natural England50, used in the County.

28. Recent surveys for the eastern development area of the proposed Staplegrove development51 has shown that lesser horseshoe bats are present in the this area of the urban extension, extending the area of occurrence previously recorded in radio tracking and transect surveys carried out between 200552 and 200853. It is possible given the distances individual bats were recorded from the Hestercombe House roost in the radio tracking studies, up to 6km, that lesser horseshoe bats are possibly using areas in the western area

46 Barataud, M., Faggio, G., Pinasseau, E. & Roué, S. G. 2000. Protection et restauration des habitatas de chasse du Petit rhinolophe (Rhinolophus hipposideros) Année 2000. Paris: Ministère de l’Environnement – Direction de la Nature et des Paysages. 47 Motte, G. & Libois, R. 2002. Conservation of the lesser horseshoe bat (Rhinolophus hipposideros Bechstein, 1800) (Mammalia: Chiroptera) in Belgium. A case study in feeding requirements: in Belg. J. Zool., 132 (1): 47-52. 48 Bat Conservation Trust. 2005. A Review and Synthesis of Published Information and Practical Experience on Bat Conservation within a Fragmented Landscape. Cardiff: The Three Welsh National Parks, Pembrokeshire County Council, Countryside Council for Wales 49 Somerset County Council. 2009. Habitats Regulations Assessment of Hestercombe House SAC: Taunton Deane Borough Council Local Development Framework Core Strategy/ Site Allocations Development Plan Document and Somerset County Council Taunton Transport Strategy Review 2. Taunton: Somerset County Council/ Taunton Deane Borough Council 50 Somerset County Council. 2009. Habitats Regulations Assessment of Hestercombe House SAC: Taunton Deane Borough Council Local Development Framework Core Strategy/ Site Allocations Development Plan Document and Somerset County Council Taunton Transport Strategy Review 2. Taunton: Somerset County Council/ Taunton Deane Borough Council 51 Firman, B. 2013. Staplegrove. Protected Species Suvey: Bats. October 2013. Cardiff: Wildwood Ecology Ltd. 52 Billington, G. 2005. Radio tracking study of lesser horseshoe bats at Hestercombe House Site of Special Scientific Interest, July 2005. Peterborough: English Nature. 53 Duvergé, L. 2009. Report on bat surveys carried out at Hestercombe House SSSI Taunton, Somerset, in 2007 and 2008. Cullompton: Kestrel Wildlife Consultants.

- 67 ­ of the Staplegrove extension as well.

29. The main flight paths and hedgerows likely to be used for commuting by lesser horseshoe bats, along with the density banding used in the current HEP, are shown in Map 4 below.

Site Assessment of Replacement Habitat Required 30. This section considers those sites listed above assessing the amount of replacement habitat required to ensure that the ‘Favourable Conservation Status’ of the lesser horseshoe bat population at Hestercombe House is maintained.

31. The amount of habitat required may be created on or off site and includes a minimum of a 20 metre buffer planting of woodland on boundaries that face lesser horseshoe bat activity. The specification for this woodland belt is set out in the Habitats Regulations Assessment of the Core Strategy carried out in 200954 and carried for development schemes at the project level.

TAU3 Pyrland Farm 32. The total site area is 39.95 hectares. However, this area has been significantly reduced from the original proposal and now is for 40 to 50 dwellings. These will occupy about 1 hectare at 40 dwelling per hectare (e.g. see Crysell, 2013). Therefore it is considered that the required replacement habitat for lesser horseshoe bats, using the methodology described above can easily be accommodated within the site area. There is unlikely to be a significant effect

54 Somerset County Council. 2009. Habitats Regulations Assessment of Hestercombe House SAC: Taunton Deane Borough Council Local Development Framework Core Strategy/ Site Allocations Development Plan Document and Somerset County Council Taunton Transport Strategy Review 2. Taunton: Somerset County Council/ Taunton Deane Borough Council

- 68 ­ on the integrity of the Hestercombe House SAC. A project level Appropriate Assessment will be required.

TAU2 Staplegrove 33. The outline of the Staplegrove Urban Extension as defined by Taunton Deane Borough Council is shown in Map 6 against the background of site allocations included in this assessment. This extent of the development in the urban extension on its northern side will be determined by a link road running between the A358 Langford roundabout and Kingston Road. The approximate route of this road is also shown in Map 6. An area to the east of Kingston Road is also proposed for development but is unlikely to extend to the northern limit of the urban extension’s red line.

Map 5: Staplegrove Urban Extension

34. Currently most of the Staplegrove Urban Extension lies within both Density Bands B and C going out from the lesser horseshoe bat roosts at Hestercombe House SAC. Site surveys from the Staplegrove east extension either side of Kingston Road has shown the presence of lesser horseshoe bats further west from the Hestercombe roost that has been identified by previous surveys. There is a possibility that they may be travelling into the western Staplegrove site allocation area. This is entirely within Density Band C, the lowest density. It is assumed, contrary to previous assessments, that lesser horseshoe bats could also be present in this area too. As a precautionary approach is required calculations are carried out for this area as well. For the purposes of the HEP it is assumed that the whole site allocation area would be lost or be inaccessible to lesser horseshoe bats. Any suitable habitat on land to the south of Corkscrew Lane is not included, although it would be isolated by the Urban Extension, as the road is street lit and would therefore form a barrier to access by lesser horseshoe bats.

35. The calculations carried out for the Staplegrove Urban Extension is set out in Appendix 2. The amount estimated for the entire site allocation is likely to require up to 16.27 hectares

- 69 ­ of habitat enhancement, of which 9.7 hectares are needed for the eastern Staplegrove allocation area located either side of Kingston Road. The replacement habitat will need to be accessible to the Hestercombe House lesser horseshoe bat population. It will include a minimum of a 20 metre woodland buffer planting on development edges adjacent to areas used by bats and either on or off site woodland planting with water bodies to the specifications set out in the HRA of the Taunton Deane Borough Council Core Strategy.

36. It is considered that the amount of land available north of the link road and within site allocation boundaries would be able to provide any on site replacement habitat lost due to development or inaccessibility bearing in mind the whole of the allocation is accounted for in the HEP calculation. If offsite offset land is required land to the north of the eastern Staplegrove development this is in the same landownership and the prospective developer (TA137 and TA169).

37. Boundaries requiring buffer planting are also identified for each site. Buffer planting is required due to the presence of street lighting on site. This has two effects on lesser horseshoe bats. Firstly, lesser horseshoe bats are adverse to even low levels of artificial lighting and would be displaced away from features on a site otherwise used for commuting and/or feeding (Billington, 200555). Stone et al, 200956 has shown that lesser horseshoe bats are disrupted from flying along hedgerows by introduced artificial light levels above 0.5 Lux. Secondly, lighting will draw insect prey in from the neighbouring countryside and thereby reduce the value of surrounding feeding habitats (Stone, 200957; Outen, 200258). Therefore, street lights will need to be of the LED type, which has low or no UV and are highly directional59.

38. The Staplegrove Urban Extension will need to be Master Planned as a whole guided by habitat requirements to maintain the Favourable Conservation Status of the Hestercombe House lesser horseshoe bat population. The Master Plan will need to include woodland buffer and other planting along the northern and eastern edges of any development and to the north of the proposed development to the specification used previously for replacement habitat used at other sites affecting the Hestercombe House SAC lesser horseshoe bat population to the north of Taunton and Monkton Heathfield60. It is also considered that the use of directional LED street lighting would reduce light levels sufficiently to allow use of at least the outer edges of these wooded strips if and where such situations arise within a Master Plan. Any access paths through buffer planting will be no more than 3 metres wide, unlit and constructed at an angle through the planting to minimise light spill if any.

39. Created woodland habitat can be used for community purposes provided that there is no artificial lighting and that rides and glades do not exceed 10 metres in width. Footpaths or

55 Billington, G. 2005. Bats and roads. Presentation to Somerset Highways, October, 2005. 56 Stone, E. L., Jones, G. & Harris, S. 2009. Street Lighting Disturbs Commuting Bats. Current Biology 19, 1123–1127, July 14, 2009 57 Stone, E. L. 2009. The impact of street lighting on lesser horseshoe bats: Presented at the South West Bat Conservation Trust Conference, 25 April, 2009. 58 Outen, A. R. 2002. The ecological effects of road lighting: in Sherwood, B., Cutler D. & Burton J. (eds.) 2002. Wildlife and Roads: The Ecological Impact. London: Imperial College Press. 59 Stone, E.L., Jones, G., & Harris, S. 2012. Conserving energy at a cost to biodiversity? Impacts of LED lighting on bats. Global Change Biology. 18 (8) doi: 10.1111/j.1365-2486.2012.02705 x. 60 Somerset County Council. 2009. Habitats Regulations Assessment of Hestercombe House SAC: Taunton Deane Borough Council Local Development Framework Core Strategy/ Site Allocations Development Plan Document and Somerset County Council Taunton Transport Strategy Review 2. Taunton: Somerset County Council/ Taunton Deane Borough Council

- 70 ­ cycle tracks with any associated amenity cutting will be no wider than 3 metres. All other habitat will be managed for the benefit of lesser horseshoe bats.

40. There is unlikely to be a significant effect on the integrity of the Hestercombe House SAC. However, project level Appropriate Assessments will be required for developments within the Staplegrove Urban Extension allocation using the HEP methodology outlined above, which be supported by up to date bat activity surveys and habitat mapping to inform an assessment based on more detailed proposals for development.

- 71 ­ Appendix 2: HEP Calculation for Staplegrove

Field No. Area (hectares) IHS Codes HSI Score Density Band Habitat Units Lost F1 9.951 GI0.TS21.GM11.GL21 1 2 19.90 P2 0.053 AS0.AP1 5 2 0.53 F3 0.049 WB3.WF21.WM51 4.8 2 0.47 F4 0.034 GI0.TS21.GM11.GL21 1 2 0.07 F5 0.362 WB1.WF3.WM1 4.8 2 3.48 F6 0.344 GI0. GM23. GL1Z 0.025 2 0.02 F7 0.362 WB1.WF3.WM1 4.8 2 3.48 F8 0.2 UR0.UA32 0.1 2 0.04 F9 0.086 UR0.UA32 0.1 2 0.02 F10 0.154 WB1.WF2.CL31 4.8 2 1.48 F11 3.484 CR7.CL1 0 2 0.00 F12 0.833 CR7.CL1 0 2 0.00 F13 5.56 CR0.TS21.CL1 0 2 0.00 F14 0.894 WB1.WF2.WM1.WG4 2.4 2 4.29 F15 1.358 CR7.CL1 0 2 0.00 F16a 1.045 GP0.GM2.GL2 0.75 2 1.57 F16b 0.277 GP0.GM2.GL2 0.75 1 0.21 F17 0.49 GP0.GM0.GL2 0.75 2 0.74 F18 0.268 CR0.TS21.CL1 1 2 0.54 F19 3.102 CR4.TS21.CL1 0 2 0.00 F20 1.25 CR0.TS21.CL1 1 2 2.50 F21 0 CR35.CL1 0 2 0.00 P22 0.051 AS0.AP1 5 2 0.51 F23 1.465 GI0.GM2.GL2 0.75 2 2.20 P24 0.081 AS4Z.AO1Z.AP1Z 3.75 2 0.61 F25 2.669 CR7.CL1 0 2 0.00 F26 0.602 CR61.CL1 2 2 2.41 F27a 3.223 CR4.CL1 0 2 0.00 F27b 1.422 CR4.CL1 0 1 0.00 F28 0.311 UR0.UA32 0.1 1 0.03 F29 1.178 GP0.GM0.GL21 0.75 1 0.88 F30 0.094 UR0.UA32 0.1 1 0.01 F31 2.844 GP0.SC1.GMZ.GL21 0.5 1 1.42 F32a 1.052 CRZ.CL2 0 2 0.00 F32b 0.486 CRZ.CL2 0 1 0.00 F33 0.906 CR3Z.CL2 0 1 0.00 F34 0.222 GP0.SC1.GMZ.GL21 0.5 1 0.11 F35 6.911 GI0.GM3.GL21 0.75 1 5.18 F36 0 Not assigned 0 0 0.00 F37 0.237 UR0.UA32 0.1 1 0.02

- 72 ­ Field No. Area (hectares) IHS Codes HSI Score Density Band Habitat Units Lost F38 0.316 UR0.TS0.UA32 0.1 1 0.03 F39 0.049 UR0.UA32 0.1 1 0.00 F40 0.053 UR0.UA32 0.1 1 0.01 F41 0.064 UR0.UA32 0.1 1 0.01 F42 0.047 UR0.UA32 0.1 1 0.00 F43 0.289 UR0.TS0.UA32 0.1 1 0.03 F44 6.629 GP0.GM0.GL21 0.75 1 4.97 F45 1.86 GI0.GM23.GL12 0.025 1 0.05 F46 2.939 CR7.CL1 0 1 0.00 F47 3.472 GP0.GM2.GL21 0.75 1 2.60 F48 4.291 CR4.CL1 0 1 0.00 F49 2.964 CR4.CL1 0 1 0.00 F50 0.548 GP0.GMZ 0.5 1 0.27 F51 3.546 GP0.GM11.GL21 1 1 3.55 F52 1.922 GP0.GM11.GL2 1 1 1.92 F53 0 Not assigned 0 1 0.00 F54 1.414 GI0.GM11.GL21 1 1 1.41 F55 0.685 GP0.GM11.GL21 1 1 0.69 F56 1.103 WB3.WF3.WM1 4.8 1 5.29 F57 0.635 GI0.TS0.GM23.GL1 0.025 1 0.02 F58 1.577 GP0.GM11.GL21 1 1 1.58 F59 3.305 GP0.GM11.GL21 1 1 3.31 F60 0.178 UR0.TS0.UA32 0.1 1 0.02 F61 0.513 GP0.GM11.GL21 1 1 0.51 H1 0.399 LF11.LM3 6 2 4.79 H2 0.083 LF11.LM2 5.4 2 0.90 H3 0.507 LF11.LM1 1.8 2 1.83 H4 1.05 LF11.LM3 6 1 6.30 H5 0.243 LF11.LM2 5.4 1 1.31 H6 0.915 LF11.LM1 1.8 1 1.65 Habitat Units 95.73

Woodland with ponds Delivery Risk 1.50

Temporal Risk 1.70

Habitat Units 244.12

Assumed enhancement on HSI of 1 Value of offset site 292.95

HU/18 Hectares 16.27

- 73 ­ Appendix 3: Screening of Somerset Levels and Moors SPA / Ramsar (Royal Haskoning)

The following is the separate screening, following the Habitats Regulations Assessment process, carried out for the Taunton Deane Core Strategy in 2012.

Introduction

1. Royal HaskoningDHV was commissioned to carry out a plan-level assessment of the Taunton Deane Borough Council (TDBC) Site Allocations and Development Management Plan – Preferred Options, considering potential effects of implementation of the plan with respect to The Conservation of Habitats and Species Regulations 2010 (as amended) (the ‘Habitats Regulations’).

2. An initial screening assessment, of the Taunton Deane Borough Council Draft Core Strategy, was undertaken in May 2011. That report (Royal HaskoningDHV, 2011) specifically considered the Somerset Levels and Moors International Sites61. A complementary assessment was carried out by the Somerset County Ecologist in respect of other International Sites.

3. Through discussion with Natural England and other consultees, and based on the interest features of the International Sites, two potential mechanisms by which the Plan might impact the Somerset Levels and Moors were identified, namely increased recreational disturbance and increased water quality-related impacts.

4. Following detailed consideration, Royal HaskoningDHV advised that it was possible to conclude that implementing the Core Strategy would not, either alone or in-combination with other plans and programmes, result in adverse effects on the integrity of the Somerset Levels and Moors international sites. The Core Strategy was adopted in September 2012.

5. Whilst the Core Strategy establishes the long-term requirements for growth within the Borough greater detail, including detailed Development Management policies, are to be included in subsequent documents. One such document is the Site Allocations and Development Management Plan (SADMP).

6. The objectives of the SADMP are:

• “To set out a range of smaller allocations across the Borough consistent with the Core Strategy and in particular, the settlement hierarchy established by Policy SP1 of the Plan; and

61 Special Areas of Conservation (SAC, or candidate Special Area of Conservation (cSAC)), designated under the Habitats Directive, and Special Protection Areas (SPA) designated under the Birds Directive (79/409/EEC), form part of the EU-wide Natura 2000 network. ‘Ramsar sites’, designated under the Ramsar Convention (The Convention on Wetlands of International Importance, especially as Waterfowl Habitat) are subject to the same provisions. The term International Sites is used throughout this document when referring to these areas.

- 74 ­ • To define development management policies, where necessary, to ensure that sustainable development is delivered in accordance with the principles of the Taunton Deane Core Strategy and National Planning Policy Framework.”

7. The Preferred Options for the SADMP were consulted on from October to December 2013. This technical note provides an assessment of those options, prior to the preferred options being finalised.

8. The assessment outlined in the sections below represents the first stage of a HRA, an assessment of whether the policies and land allocations from the SADMP have the potential to have a Likely Significant Effect (LSE), either alone or in-combination, on the site(s) for which the assessment is for. Those policies that can be scoped out of the further assessment stages can be considered suitable for inclusion in the plan.

Screening Assessment

Development Management

9. The SADMP proposes a number of Development Management policies which cover the following 8 strategic objectives:

• Climate change; • Economy; • Town and other centres; • Housing; • Inclusive communities; • Accessibility; • Infrastructure; and • Environment.

Climate change

10. With regard to climate change, TDBC are not proposing any policies above those that are identified in the Core Strategy (e.g. CP1 and DM5). These include addressing impacts on the environment from developments associated with renewable and low carbon energy. Neither policy was assessed as having an LSE previously and as such there are no identified issues in relation to the Habitats Regulations and this strategic objective.

Economy

11. The preferred options with regard to the economy will create a series of policies relating to the size of employment areas and their usage. Given the specific nature of these options and that any potential effects of economic development should be addressed through the requirement for compliance with Core Strategy policy CP8 Environment, no significant effects as a result of economic policies is anticipated.

- 75 ­ 12. It is recommended that specific reference to CP8 is made in either the policy text, or supporting paragraphs.

13. The other options considered as alternatives to the preferred options are also considered unlikely to have a significant effect on the International Sites.

Town and other centres

14. The preferred options for this strategic objective relate to within-town measures seeking to ensure that retail frontages are effective and the shops are designed appropriately. Given the localised scale of these proposed measures it is considered unlikely that they will have any implications in relation to the Habitats Regulations.

15. The alternatives to these preferred options are also considered unlikely to significantly affect the International Sites as they are also focused on within town development.

16. The preferred policy which relates to out of centre proposals could potentially impact the International Sites if locations are not selected carefully. However, this option does also state that these areas will be well connected to town centres which imply proximity to the developed areas of the Borough. This, together with the fact that development would also require compliance with Core Strategy policy CP8 Environment supports a conclusion that there will be no LSE on the International Sites.

Housing

17. The preferred option relating to rural workers’ dwellings will set out the restrictions this form of development should meet, in line with Planning Policy Statement 7. This type of development will be small scale although there is the potential for it to be located close to the International Sites and cause limited disturbance. At the Plan level, this policy would have to comply with CP8 and therefore impacts to the International Sites would be avoided. However, as with other policies it is recommended that reference to that policy is included in the policy or its supporting text.

18. The alternative proposed for this issue would result in proposals for this type of development be assessed against the existing Core Strategy policies. This would also mean that impacts to the International Sites are taken into account through CP8.

Inclusive communities

19. TDBC are proposing policies regarding educational land, open space, horse riding establishments, community facilities and accessibility. A number of these preferred options could be of benefit to the International Site as alternative recreational areas to, for example, walk dogs, would be provided. Provision of facilities such as this can help ease existing and any future pressures on designated sites.

20. There is the potential for the development of horse riding establishments to be located close to the International Sites, but they are likely to be small in scale and also subject to the requirements of CP8.

- 76 ­ 21. The alternatives to these preferred options would mean relying on existing development plan policies and could result in requirements for open space and accessibility not being met. However, whilst this could potentially mean that there are fewer alternative areas for people to use recreationally, it is considered that it would not have a significant effect on the International Sites.

Accessibility

22. The preferred options in relation to accessibility are very specific and focus on parking requirements, cycle networks, disused transport corridors and accessibility targets. Given the localised nature of these policies, it is considered unlikely to be any implication in relation to the Habitats Regulations.

23. The alternatives to these options would be to do nothing or with regard to parking, relying instead on County Council standards. Again, as these policies are very specific and focused on limited areas, no significant effects are anticipated.

Infrastructure

24. With regard to the preferred options (power lines, telecommunications, water management and water infrastructure) there is not likely to be any implication in relation to the Habitats Regulations. Adequate protection is likely to be provided through existing Core Strategy policies. In respect of local power lines, consideration should be given in limited areas to any barrier effect they may represent to bird movement. This could include adding the requirement to undertake assessments of bird movements between the Somerset Levels and Moors individual sites, other International Sites and also the coast. This would form part of a project specific assessment in line with the Habitats Regulations.

25. The alternatives to these options would be that no specific policy is identified and applications for relevant development would be considered against existing policies, including CP8.

Environment

26. The potential for ecological enhancements to reduce pressures on (internationally and nationally) designated sites is well-recognised, and measures to increase the coherence of ecological networks should be encouraged. Core Strategy policy CP8, together with on­ going work in the county, should support the delivery of this.

27. The preferred options presented in the SADMP relate to environmental features which are not relevant to the International Sites (e.g. tree planting, landscape, and archaeological features). The preferred option to protect the Borough’s ecological network could have potential beneficial impacts on the International Sites by enhancing surrounding areas and providing another level of protection. It will provide resilience to ecological networks, creating buffers and corridors which will enhance connectivity.

28. The alternatives proposed for these preferred options would be not providing a relevant policy. Whilst this would not have any implications in relations to the Habitats Regulations, environmental benefits which may lead to greater resilience of the International Site network would not be achieved.

- 77 ­

Site Selection

29. The overall scale of development within the Borough remains as considered within the Core Strategy. As a result the key consideration for the HRA is the location of this development.

30. The Higher Assessment Framework identified by TDBC to assess all potential housing sites includes proximity to and impact on International Sites. This is considered to be a reinforcement of Core Strategy Policy CP8 Environment and prevents development within International Sites.

31. Of the potential Site Allocations identified, residential and employment sites in Taunton, Wellington, Wiveliscombe, Bishops Lydeard, Creech St Michael, Cotford St Luke, Milverton, and Churchinford are all considered to be equivalent in respect of the Habitats Regulations, due to the distance from these settlements to the International Sites, no LSE is anticipated.

32. Although development in North Curry has the potential to increase recreational pressures on the interest features of the Somerset Levels and Moors, development in this settlement is small scale (i.e. approximately 40 homes), and could be considered insufficient to change existing conditions. Therefore it is not anticipated that this development would have a likely significant effect on the International Sites. However, it is recommended that actions could be undertaken at the local level to raise awareness of the local population to the sensitivity and value of the International Site.

Conclusion

33. In summary, the majority of the preferred options set out in the Site Allocation and Development Management Plan are considered unlikely to result in a significant effect on the International Sites.

34. At the Plan level it is considered that the framework of the policies within the Core Strategy which relate to the natural environment should ensure that any potential impacts on the International Sites are suitably assessed and mitigated.

35. Recommendations have been included on a number of preferred options regarding the cross-referencing to Core Strategy Policy CP8 to ensure that impacts on the International Sites are avoided.

36. Following this assessment of the current preferred option suite it is suggested that the conclusion can be drawn that there will be no adverse effect on the integrity of the identified International Site from implementing the SADMP.

- 78 ­