Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

London Borough of Bromley

Project Number: 60474250

November 14 2016

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Quality information

Prepared by Checked by Approved by

Isla Hoffmann-Heap Dr James Riley Max Wade Consultant Ecologist Associate Director Technical Director

Revision History

Revision Revision date Details Authorized Name Position 0 15/11/16 Draft JR James Riley Associate

Prepared for: London Borough of Bromley AECOM

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Prepared for: London Borough of Bromley

Prepared by: Isla Hoffmann-Heap Consultant Ecologist T: 01256 310 486 M: 07920 789 719 E: [email protected]

AECOM Limited Midpoint Alencon Link Basingstoke Hampshire RG21 7PP UK

T: +44(0)1256 310200 aecom.com

© 2016 AECOM Limited. All Rights Reserved.

This document has been prepared by AECOM Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

Prepared for: London Borough of Bromley AECOM

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table of Contents 1. Introduction ...... 6 1.1 Background to the project ...... 6 1.2 Current Legislation ...... 6 1.3 Scope of the Project ...... 7 1.4 This Report ...... 8 2. Methodology ...... 9 2.1 HRA Task 1 - Likely Significant Effects (LSE) ...... 9 2.2 Principal Other Plans and Projects That May Act ‘In Combination’ ...... 10 3. The Plan ...... 11 3.1 Chapter 2: Living in Bromley ...... 11 3.2 Chapter 3: Supporting Communities ...... 13 3.3 Chapter 5: Valued Environments ...... 15 3.4 Chapter 6: Working in Bromley ...... 19 3.5 Chapter 7: Environmental Challenges ...... 22 3.6 Chapter 8: Delivery and Implementation ...... 24 4. Potential Impact Pathways ...... 25 4.1 Recreational Pressure ...... 25 4.2 Atmospheric Pollution ...... 28 4.3 Water Quantity ...... 29 4.4 Water Quality ...... 29 5. European Designated Sites Screening ...... 30 5.1 Wimbledon Common SAC ...... 30 5.2 Richmond Park SAC ...... 33 5.3 Epping Forest SAC ...... 33 5.4 Lee Valley SPA and Ramsar ...... 35 5.5 Mole Gap to Reigate Escarpment SAC ...... 36 5.6 North Downs Woodlands SAC ...... 38 5.7 Thames Estuary and Marshes SPA and Ramsar ...... 39 6. Screening Conclusions ...... 41 Appendix A : Figure A1: Location of European Designated Sites in Relation to the London Borough of Bromley...... 42

Figures Figure 1: Four Stage Approach to Habitats Regulations Assessment. Source CLG, 2006...... 9 Figure 2: Traffic Contribution to Concentrations of Pollutants at Different Distances from a Road (Source: DfT) ...... 28

Tables Table 1: European designated sites with the potential sphere of influence of the London Borough of Bromley...... 8 Table 2: Broad summaries of policies within Chapter 2 (Living in Bromley) of the Draft Local Plan. ... 11 Table 3: Broad summaries of policies within Chapter 3 (Supporting Communities) of the Draft Local Plan ...... 14 Table 4: Broad summaries of policies within Chapter 4 (Getting Around: Transport and Accessibility) of the Draft Local Plan ...... 15 Table 5: Broad summaries of policies within Chapter 5 (Valued Environments) of the Draft Local Plan16 Table 6: Broad summaries of policies within Chapter 6 (Working in Bromley) of the Draft Local Plan 20 Table 7: Broad summaries of policies within Chapter 7 (Environmental Challenges) of the Draft Local Plan ...... 23

Prepared for: London Borough of Bromley AECOM

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 8: Broad summaries of policies within Chapter 8 (Delivery and Implementation) of the Draft Local Plan...... 24 Table 9: Critical Loads of Wimbledon Common SAC and existing Nitrogen deposition rates upon SAC features ...... 32

Prepared for: London Borough of Bromley AECOM

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

1. Introduction

1.1 Background to the project

AECOM has been appointed by The London Borough of Bromley (referred to as “the Council” and “the Authority”) to assist in undertaking a Habitats Regulations Assessment (HRA) of the potential effects of Council’s Proposed Submission Draft Local Plan (known henceforth as the ‘Draft Local Plan’ or the ‘Plan’).

The London Borough of Bromley (Bromley Council) is currently preparing a new Local Plan to replace the Unitary Development Plan (July 2006) which currently forms part of the borough’s Development Plan. Bromley Council is in the process of preparing their updated Local Plan. The Plan will set out the vision and objectives for the borough to the 2030s, strategic and more detailed policies used in determining local planning applications, and strategic site allocations.

The objective of this assessment is to:

• identify any aspects of the Draft Local Plan that would cause an adverse effect on the integrity of Natura 2000 sites, otherwise known as European sites (Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and, as a matter of Government policy, Ramsar sites1), either in isolation or in combination with other plans and projects; and • to advise on appropriate policy mechanisms for delivering mitigation where such effects are identified.

1.2 Current Legislation

The need for Appropriate Assessment is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British law by the Conservation of Habitats and Species Regulations 2010. The ultimate aim of the Directive is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates to habitats and species, not the European sites themselves, although the sites have a significant role in delivering favourable conservation status.

The Habitats Directive applies the precautionary principle to European sites. Plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. Plans and projects with predicted adverse impacts on European sites may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead. In such cases, compensation would be necessary to ensure the overall integrity of the site network.

In order to ascertain whether or not site integrity will be affected, an Appropriate Assessment should be undertaken of the plan or project in question:

1 Wetlands of International Importance designated under the Ramsar Convention 1979

Prepared for: London Borough of Bromley AECOM 6

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Habitats Directive 1992

Article 6 (3) states that:

“Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives.”

Conservation of Habitats and Species Regulations 2010

The Regulations state that:

“A competent authority, before deciding to … give any consent for a plan or project which is likely to have a significant effect on a European site … shall make an appropriate assessment of the implications for the site in view of that sites conservation objectives… The authority shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site”.

Box 1: The legislative basis for Appropriate Assessment Over time the phrase ‘Habitats Regulations Assessment’ (HRA) has come into wide currency to describe the overall process set out in the Habitats Directive from screening through to Imperative Reasons of Overriding Public Interest (IROPI). This has arisen in order to distinguish the process from the individual stage described in the law as an ‘appropriate assessment’. Throughout this report we use the term Habitat Regulations Assessment for the overall process and restrict the use of Appropriate Assessment to the specific stage of that name.

1.3 Scope of the Project

There is no pre-defined guidance that dictates the physical scope of a HRA of a Plan document. Therefore, in considering the physical scope of the assessment, we were guided primarily by the identified impact pathways rather than by arbitrary ‘zones’. Current guidance suggests that the following European sites be included in the scope of assessment:

• All sites within the Bromley Council’s boundary; and • Other sites shown to be linked to development within the borough boundary through a known ‘pathway’ (discussed below). Briefly defined, pathways are routes by which a change in activity provided within a Local Plan document can lead to an effect upon a European designated site. Guidance from the former Department of Communities and Local Government states that the HRA should be ‘proportionate to the geographical scope of the [plan policy]’ and that ‘an AA need not be done in any more detail, or using more resources, than is useful for its purpose’ (CLG, 2006, p.6). More recently, the Court of Appeal 2 ruled that providing the Council (competent authority) was duly satisfied that proposed mitigation could be ‘achieved in practice’ and satisfied that the proposed development would have no adverse effect, then this would suffice. This ruling has since been applied to a planning permission (rather than a Core Strategy document)3. In this case the High Court ruled that for ‘a multistage process, so long as there is sufficient information at any particular stage to enable the authority to be satisfied that the proposed mitigation can be achieved in practice it is not necessary for all matters concerning mitigation to be fully resolved before a decision maker is able to conclude that a development will satisfy the requirements of the Habitats Regulations’.

No European designated sites are located within the London Borough of Bromley. The nearest European designated site to the London Borough of Bromley is Wimbledon Common SAC located 9.8km north east of the Borough.

2 No Adastral New Town Ltd (NANT) v Suffolk Coastal District Council Court of Appeal, 17th February 2015 3 High Court case of R (Devon Wildlife Trust) v Teignbridge District Council, 28 July 2015

Prepared for: London Borough of Bromley AECOM 7

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Beyond this (i.e. within a potential sphere of influence) are the European designated sites as identified in the following table:

Table 1: European designated sites with the potential sphere of influence of the London Borough of Bromley.

European Designated Site Distance from the Borough Richmond Park SAC 12.2km west Epping Forest SAC 14.5km north Lee Valley SPA and Ramsar 15.9km north Mole Gap to Reigate Escarpment SAC 16.1 south west North Downs Woodlands SAC 17.1km east Thames Estuary and Marshes SPA and Ramsar 17.6km east Full details including features of designation, conservation objectives and environmental vulnerabilities for all European designated sites can be found in Chapter 5. All the European sites are illustrated in Appendix A, Figure A1.

1.4 This Report

Chapter 2 of this report explains the process by which the HRA has been carried out. Chapter 3 explores policies of the Draft Local Plan and identifies potential impact pathways that could result from the Plan. Chapter 4 describes the potential impact pathways identified in the previous chapter. Chapter 5 sets out details of the European designated sites assessed. This includes qualifying features, conservation objectives, and environmental vulnerabilities and explores how the identified impact pathways potentially provided by the Draft Local Plan could interact with the European designated sites. The key findings are summarised in Chapter 6: Screening Conclusions.

Prepared for: London Borough of Bromley AECOM 8

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

2. Methodology

The HRA has been carried out in the continuing absence of formal central Government guidance, although general EC guidance on HRA does exist4. The former Department of Communities and Local Government (DCLG) released a consultation paper on the Appropriate Assessment of Plans in 20065. As yet, no further formal guidance has emerged. However, Natural England has produced its own internal guidance6 as has the RSPB7. Both of these have been referred to in undertaking this HRA.

Figure 1 below outlines the stages of HRA according to current draft DCLG guidance. The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no significant adverse effects remain.

Evidence Gathering – collecting information on relevant European sites, their conservation objectives and characteristics and other plans or projects.

HRA Task 1: Likely significant effects (‘screening’) – identifying whether a plan is ‘likely to have a significant effect’ on a European site

HRA Task 2: Ascertaining the effect on site integrity – assessing the effects of the plan on the conservation objectives of any European sites ‘screened in’ during HRA Task 1

HRA Task 3: Mitigation measures and alternative solutions – where adverse effects are identified at HRA Task 2, the plan should be altered until adverse effects are cancelled out fully

Figure 1: Four Stage Approach to Habitats Regulations Assessment. Source CLG, 2006. 2.1 HRA Task 1 - Likely Significant Effects (LSE)

Following evidence gathering, the first stage of any Habitat Regulations Assessment and the purpose of this assessment is a Likely Significant Effect (LSE) test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:

“Is the Plan, either alone or in combination with other relevant projects and plans, likely to result in a significant effect upon European sites?”

The objective is to ‘screen out’ those plans and projects that can, without any detailed appraisal, be said to be unlikely to result in significant adverse effects upon European sites, usually because there is no mechanism for an adverse interaction with European sites.

4 European Commission (2001): Assessment of plans and projects significantly affecting Natura 2000 Sites: Methodological Guidance on the Provisions of Article 6(3) and 6(4) of the Habitats Directive. 5 CLG (2006) Planning for the Protection of European Sites, Consultation Paper 6 http://www.ukmpas.org/pdf/practical_guidance/HRGN1.pdf 7 Dodd A.M., Cleary B.E., Dawkins J.S., Byron H.J., Palframan L.J. and Williams G.M. (2007) The Appropriate Assessment of Spatial Plans in England: a guide to why, when and how to do it. The RSPB, Sandy.

Prepared for: London Borough of Bromley AECOM 9

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

In evaluating significance, AECOM have relied on our professional judgement as well as the results of previous stakeholder consultation regarding development impacts on the European sites considered within this assessment.

The level of detail in land use plans concerning developments that will be permitted under the plans will never be sufficient to make a detailed quantification of adverse effects. Therefore, we have again taken a precautionary approach (in the absence of more precise data) assuming as the default position that if an adverse effect cannot be confidently ruled out, avoidance or mitigation measures must be provided. This is in line with the former Department of Communities and Local Government guidance and Court rulings that the level of detail of the assessment, whilst meeting the relevant requirements of the Conservation Regulations, should be ‘appropriate’ to the level of plan or project that it addresses. This ‘tiering’ of assessment is summarised in Box 2.

Box 2: Tiering in HRA of Land Use Plans

Policy Statements and other HRA national strategies

Sub-regional strategies if HRA Increasing specificity applicable in terms of evidence base, impact evaluation, mitigation, etc. Local Plans HRA

Individual projects HRA

When discussing ‘mitigation’ for a Local Plan document, one is concerned primarily with the policy framework to enable the delivery of such mitigation rather than the details of the mitigation measures themselves since the Local Plan document is a high-level policy document.

2.2 Principal Other Plans and Projects That May Act ‘In Combination’

It is neither practical nor necessary to assess the ‘in combination’ effects of the Plan within the context of all other plans of neighbouring authorities. In practice therefore, in combination assessment is of greatest relevance when the plan would otherwise be screened out because its individual contribution is inconsequential. This is undertaken for each of the European designated sites within Chapter 5.

Prepared for: London Borough of Bromley AECOM 10

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

3. The Plan

This chapter summarises key policies and elements of development (including strategic site allocations) of the Draft Local Plan.

The Draft Local Plan is set out in chapters which contain 125 policies. Many of these policies are development management policies which do not provide for any quantum, location or type of development. All policies are discussed within the following sections, with policies that could provide for impact pathways that could link to a European designated site highlighted in orange.

3.1 Chapter 2: Living in Bromley

3.1.1 The Policies

This chapter sets out the planning policies that relate to living in Bromley. This chapter contains the following policies as discussed in Table 2:

Table 2: Broad summaries of policies within Chapter 2 (Living in Bromley) of the Draft Local Plan.

Policy Broad policy description

Draft Policy 1: Housing Supply. This policy provides for a minimum average of 641 additional homes per annum over the ten year plan period and where possible over the fifteen year Plan period. These will be provided via allocated sites and sites with planning permission; delivery of housing in town centres, Renewal areas, windfall sites, the conversion of suitable properties; mixed use development, suitable non self-contained units; vacant properties being brought back into use; resisting the loss of existing housing and the development of housing in broad Locations (additional large sites within Bromley Town Centre, Orpington Town Centre and other areas where there is existing large scale retail) and sites due to public sector restructuring and other land disposal. It includes the following Site Allocations (locations illustrated in Appendix A, Figure A1) ─ Bromley Civic Centre (70 units) ─ Land adjacent to Bromley North Station (525 units) ─ The Hill Car Park and adjacent sites (150 units) ─ Gas holder site, Homesdale Road (60 units) ─ Land adjacent to Bickley Station (30 units) ─ Bromley Valley Gym, Chipperfield Road and adjoining land (200 units)

Prepared for: London Borough of Bromley AECOM 11

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

─ Orchard Lodge, William Booth Road (200 units) ─ Bassetts Campus, Broadwater Gardens (115 units) ─ Former Depot, Bruce Grove Orpington (30 units) ─ West of Bromley High Street and land at Bromley South (1230 units) ─ 18-44 Homefield Rise, Orpington ─ Small Halls, York Rise, Crofton Road ─ Banbury House, Bushell Way, Chislehurst

Draft Policy 2: Provision of Affordable Housing Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 3: Backland and Garden Land Development Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 4: Housing Design Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 5: Parking of Commercial Vehicles Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 6: Residential Extensions Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 7: Accommodation for Family Members Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 8: Side Space Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 9: Residential Conversions Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 10: Conversion of Non-Residential Buildings to Residential Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 11: Specialist & Older Peoples Accommodation Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 12: Traveller’s Accommodation Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

Prepared for: London Borough of Bromley AECOM 12

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Draft Policy 13: Renewal Areas Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 14: Development Affecting Renewal Areas Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 15: Crystal Palace, Penge & Anerley Renewal Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 16: Bromley Common Renewal Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 17: Cray Valley Renewal Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 18: Mottingham Renewal Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 19: Ravensbourne, Plaistow, Sundridge Renewal Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

3.1.2 Potential Impact Pathways

Draft Policy 1: Housing Supply has potential to lead to impact pathways relating to:

• Recreational pressure • Atmospheric pollution • Water quality and water quantity The screening of these impact pathways relating to European designated sites is undertaken in Chapter 5.

3.2 Chapter 3: Supporting Communities

3.2.1 The Policies

This chapter sets out the planning policies that help support communities. This includes through the provision of social infrastructure, such as education and community, recreation and leisure facilities. Policies are broadly summarised in Table 3.

Prepared for: London Borough of Bromley AECOM 13

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 3: Broad summaries of policies within Chapter 3 (Supporting Communities) of the Draft Local Plan

Policy Broad policy description

Draft Policy 29: Education Site Allocations Provides for site allocations for new/ enhanced education facilities. Draft Policy 20: Community Facilities Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 21: Opportunities for Community Facilities Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 22: Social Infrastructure in New Developments Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 23: Public Houses Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 24: Allotments and Leisure Gardens Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 25: Burial Space Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 26: Health & Wellbeing Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 27: Education Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 28: Educational Facilities Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

3.2.2 Potential Impact Pathways

No policies within Chapter 3: Supporting Communities provide for any impact pathways that could feasibly link to a European designated site.

3.2.3 The Policies

This chapter sets out the planning policies to deliver the transport objectives as set out in the Plan. This chapter supports the importance of accessibility to employment, shopping and services to residents, customers, and the supply chain for businesses, and they mitigate impacts on quality of life, and the economic and social well-being of the Borough. Policies are broadly summarised in Table 4.

Prepared for: London Borough of Bromley AECOM 14

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 4: Broad summaries of policies within Chapter 4 (Getting Around: Transport and Accessibility) of the Draft Local Plan

Policy Broad policy description Draft Policy 30: Parking Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 31: Relieving Congestion Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 32: Road Safety Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 33: Access for All Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 34: Highway Infrastructure Provision Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 35: Transport Investment Priorities Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 36: Safeguarding Land for Transport Improvements. It is noted that the schemes for which land is safeguarded could result in likely significant effects; however this policy is merely for the retention of land for future schemes.

3.2.4 Potential Impact Pathways

No policies within Chapter 4: Getting Around (Transport and Accessibility) provide for any impact pathways that could feasibly link to a European designated site.

3.3 Chapter 5: Valued Environments

3.3.1 The Policies

This chapter sets out the draft policies to protect and enhance the natural and built environment of the Borough. Policies are broadly summarised in Table 5.

Prepared for: London Borough of Bromley AECOM 15

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 5: Broad summaries of policies within Chapter 5 (Valued Environments) of the Draft Local Plan

Policy Broad policy description Draft Policy 37: General Design of Development. This is a positive development management policy. It provides for sustainable design, which by definition will not result in likely significant effects. It also provides for recycling and waste storage facilities. Draft Policy 38: Statutory Listed Buildings Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 39: Locally Listed Buildings Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 40: Other Non-Designated Heritage Assets Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 41: Conservation Areas Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 42: Development Adjacent To a Conservation Area Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 43: Trees in Conservation Areas Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 44: Areas of Special Residential Character Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 45: Historic Parks and Gardens A positive policy that provides for the protection of historical parks and gardens that can be used for recreational activities that could divert people from European designated sites vulnerable to increases in recreational pressure. Draft Policy 46: Ancient Monuments and Archaeology Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 47: Tall & Large Buildings Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 48: Skyline Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 49: The Green Belt Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 50: Metropolitan Open Land Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

Prepared for: London Borough of Bromley AECOM 16

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Policy Broad policy description Draft Policy 51: Dwellings in the Green Belt or on Metropolitan Open Land Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 52: Replacement Residential Dwellings in the Green Belt Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 53: Land Adjoining Green Belt or Metropolitan Open Land Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 54: South East London Green Chain Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 55: Urban Open Space. A positive development management policy that provides for the protection of urban open space that can be used for recreational activities that could divert people from European designated sites vulnerable to increases in recreational pressure. Draft Policy 56: Local Green Space. A positive development management policy that provides for the protection of local green space that can be used for recreational activities that could divert people from European designated sites vulnerable to increases in recreational pressure. Draft Policy 57: Outdoor Recreation and Leisure Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 58: Outdoor Sport, Recreation and Play Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 59: Public Open Space Deficiency. A positive development management policy that aims to redress a deficiency on public open space that can be used for recreational activities that could divert people from European designated sites vulnerable to increases in recreational pressure Draft Policy 60: Public Rights of Way and Other Recreational Routes Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 61: Horses, Stabling and Riding Facilities Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 62: Agricultural Land Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 63: Development Related to Farm Diversification Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 64: Agricultural Dwellings Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

Prepared for: London Borough of Bromley AECOM 17

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Policy Broad policy description Draft Policy 65: Temporary Agricultural Dwellings Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 66: Occupancy Conditions Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 67: Minerals Workings and Associated Development Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 68: Development and SSSI Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 69: Development and Nature Conservation Sites Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 70: Wildlife Features Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 71: Additional Nature Conservation Sites Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 72: Protected Species Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 73: Development and Trees Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 74: Conservation and Management of Trees and Woodlands Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 75: Hedgerows and Development Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 76: Kent Downs Area Of Outstanding Natural Beauty Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 77: Landscape Quality And Character Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 78: Green Corridors Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 79: Biodiversity and Access to Nature Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development.

Prepared for: London Borough of Bromley AECOM 18

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

3.3.2 Potential Impact Pathways

No policies within Chapter 5: Valued Environments provide for any impact pathways that could feasibly link to a European designated site.

3.4 Chapter 6: Working in Bromley

3.4.1 The Policies

This chapter sets out planning policies relating to the delivery of foreseen employment growth. Employment is expected to grow by 22% (i.e. from 116,000 jobs in 2011 to 141,000 jobs in 2031). Policies are broadly summarised in Table 6.

Prepared for: London Borough of Bromley AECOM 19

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 6: Broad summaries of policies within Chapter 6 (Working in Bromley) of the Draft Local Plan

Policy Broad policy description Draft Policy 81: Strategic Industrial Locations (SIL). A development management policy that identifies broad locations for strategic Class B1 (b) and B1 (c) (business use); ii. Class B2 (general industrial use); and Class B8 (storage and distribution use) development. Draft Policy 82: Locally Significant Industrial Sites (LSIS). A development management policy that provides for Class B1 (a), B1 (b) and B1(c) (business use); ii. Class B2 (general industrial use); and Class B8 (storage and distribution use) development in locally significant industrial sites. This policy does not identify any quantum or exact type of development within these LSIS sites. Draft Policy 83: Non-Designated Employment Land. A development management policy providing for improvements to quality and quantity of employment floorspace outside of SILs and LSISs. Draft Policy 84: Business Improvement Areas (BIA). A development management policy providing for the management and improvement of the supply of high quality floorspace in Bromley Town Centre at the following BIAs: Bromley South BIA, Bromley North BIA, and London Road BIA. Draft Policy 85: Office Clusters (OC). A development management policy providing for the retention and management of office space via safeguarding Office Cluster locations. Draft Policy 86: Office Uses Outside Town Centres A development management policy providing for location of new office development within the town centre provided the retain function of the town centre is not impaired. Draft Policy 87: Home Working. Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 88: Hotels. Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 89: Telecommunications Development Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 90: Bromley Town Centre Opportunity Area Provides for the preparation of an Opportunity Area Planning Framework for Bromley Town Centre to deliver 2,500 new homes and approximately 2,000 new jobs to support the Draft Local Plan. Draft Policy 91: Proposals for Main Town Centre Uses Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development. Draft Policy 92: Metropolitan & Major Town Centres Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development. Draft Policy 93: Bromley Shopping Centre (formally The Glades) Purely development management policy relating to the policy title. The policy does not provide any type or quantum of development.

Prepared for: London Borough of Bromley AECOM 20

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Policy Broad policy description Draft Policy 94: District Centres Purely development management policy relating to the District Centres of Beckenham, Crystal Palace, Penge, Petts Wood and West Wickham. The policy does not provide any type or quantum of development. Draft Policy 95: Local Centres Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development. Draft Policy 96: Neighbourhood Centres, Local Parades and Individual Shops Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development. Draft Policy 97: Change in Use of Upper Floors Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development. Draft Policy 98: Restaurants, Pubs & Hot Food Takeaways Purely development management policy relating to the policy title. The policy does not provide any exact location or quantum of development. Draft Policy 99: Residential Accommodation A development management policy relating to change of use of ground floor premises in shopping areas to residential uses. No exact location of development is identified Draft Policy 100: Markets A development management policy relating to markets. No exact location, type or quantum of development is identified. Draft Policy 101: Shopfronts and Security Shutters Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 102: Advertisements Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 103: Biggin Hill Strategic Outer London Development Centre (SOLDC) Purely development management policy relating to the policy title. The policy does not provide any type or quantum of development. Draft Policy 104: Terminal Area A development management policy for the safeguarding of land for future aviation-related employment generating uses. Draft Policy 105: West Camp A development management policy supporting aviation-related employment and proposals for Class C1 (hotels), D1 (non-residential institutions), and B1 (a & b) (business) uses at West Camp. No exact location or quantum of development is identified. Draft Policy 106: South Camp A development management policy supporting aviation-related employment and proposals for Class B2 (general industrial), B1 (b and c) (business) and C1 (hotels) uses at South Camp. No exact location or quantum of development is identified. Draft Policy 107: Land East of South Camp A development management policy for the safeguarding of this land for future aviation related employment generating uses. No exact location, specific type or extent of development is identified.

Prepared for: London Borough of Bromley AECOM 21

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Policy Broad policy description Draft Policy 108: East Camp A development management policy for the safeguarding of this land for future aviation related employment generating uses. No exact location, specific type or extent of development is identified. Draft Policy 109: Airport Public Safety Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 110: Noise Sensitive Development in Biggin Hill Purely development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 111: Crystal Palace Strategic Outer London Development Centre Purely development management policy relating to the policy title. The policy does not provide any exact location, type or quantum of development.

3.4.2 Potential Impact Pathways

Draft Policy 90: Bromley Town Centre Opportunity Area has potential to lead to impact pathways relating to:

• Atmospheric pollution • Water quality and water quantity The screening of these impact pathways relating to European designated sites is undertaken in Chapter 5.

3.5 Chapter 7: Environmental Challenges

3.5.1 The Policies

This chapter provides Bromley’s planning policy relating to environmental issues such as waste management, flood risk management, sustainable design and construction, and carbon reduction. Policies are broadly summarised in Table 7.

Prepared for: London Borough of Bromley AECOM 22

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Table 7: Broad summaries of policies within Chapter 7 (Environmental Challenges) of the Draft Local Plan

Policy Broad policy description Draft Policy 112: Planning for Sustainable Waste Management A positive development management policy relating to the policy title. This policy provides for allocating and safeguarding strategic waste management sites at Waldo Road, Churchfields and Cookham Road. The policy does not provide any specific location, type or quantum of development. Draft Policy 113: Waste Management in New Development A positive development management policy relating to the policy title. The policy does not provide any location, type or quantum of development. Draft Policy 114: New Waste Management Facilities and Extensions and Alterations to A positive development management policy relating to the policy title. The policy does not Existing Sites provide any location, type or quantum of development. Draft Policy 115: Reducing Flood Risk A positive development management policy relating to reducing flood risk. The policy does not provide any location, type or quantum of development. Draft Policy 116: Sustainable Urban Drainage Systems (SUDS) A positive development management policy relating to the provision of SUDS. The policy does not provide any location, type or quantum of development. Draft Policy 117: Water and Wastewater Infrastructure Capacity A positive development management policy relating to capacity of water and waste water infrastructure. The policy does not provide any location, type or quantum of development. Draft Policy 118: Contaminated Land A positive development management policy relating to contaminated land. The policy does not provide any location, type or quantum of development. Draft Policy 119: Noise Pollution A positive development management policy relating to noise pollution. The policy does not provide any location, type or quantum of development. Draft Policy 120: Air Quality A positive development management policy relating to air quality. The policy does not provide any location, type or quantum of development. Draft Policy 121: Ventilation and Odour Control A development management policy relating to ventilation and odour control. The policy does not provide any location, type or quantum of development. Draft Policy 122: Light Pollution A positive development management policy relating to light pollution. The policy does not provide any location, type or quantum of development. Draft Policy 123: Sustainable Design and Construction A positive development management policy relating to sustainable design and construction. By definition sustainable development would not result in likely significant effects upon European designated sites. The policy does not provide any location, type or quantum of development. Draft Policy 124: Carbon Dioxide Reduction, Decentralised Energy Networks and A positive development management policy relating to carbon dioxide reduction, Renewable Energy decentralised energy networks and renewable energy. The policy does not provide any location, type or quantum of development.

Prepared for: London Borough of Bromley AECOM 23

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

3.5.2 Potential Impact Pathways

No policies within Chapter 7: Environmental Challenges provide for any impact pathways that could feasibly link to a European designated site.

3.6 Chapter 8: Delivery and Implementation

3.6.1 The Policies

This chapter sets out the policy importance of implementing, delivering and monitoring the Draft Local Plan. This includes the Council’s approach to delivery, working in partnership with residents and partner agencies, and the annual and longer term monitoring of the policies and the contribution to meeting the vision and objectives of the Local Plan. Policy is broadly summarised in Table 8.

Table 8: Broad summaries of policies within Chapter 8 (Delivery and Implementation) of the Draft Local Plan

Policy Broad policy description Draft Policy 125: Delivery and implementation of the Local Plan A development management policy relating to the delivery and implementation of the plan. It does not itself provide for any location, type or quantum of development.

3.6.2 Potential Impact Pathways

Draft Policy 125: Delivery and implementation of the Local Plan within Chapter 8: Delivery and Implementation does not provide for any impact pathways that could feasibly link to a European designated site.

Prepared for: London Borough of Bromley AECOM 24

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

4. Potential Impact Pathways

Chapter 3 identifies that the Draft Local Plan contains policies that provide for residential development and employment development that have the potential to lead to the following impact pathways that could link to a European designated site. These are:

• Recreational pressure • Atmospheric pollution • Water quality and quantity. This chapter details these impact pathways.

4.1 Recreational Pressure

Recreational use of a European designated site has potential to:

• Cause damage through mechanical/ abrasive damage and nutrient enrichment; • Cause disturbance to sensitive species, particularly ground-nesting birds and wintering wildfowl; and • Prevent appropriate management or exacerbate existing management difficulties.

4.1.1 Recreational pressure

Different types of European designated sites are subject to different types of recreational pressures and have different vulnerabilities. Studies across a range of species have shown that the effects from recreation can be complex.

4.1.1.1 Mechanical/abrasive damage and nutrient enrichment

Most types of terrestrial European designated sites can be affected by trampling, which in turn causes soil compaction and erosion. Walkers with dogs contribute to pressure on sites through nutrient enrichment via dog fouling and also have potential to cause greater disturbance to fauna as dogs are less likely to keep to marked footpaths and move more erratically. Motorcycle scrambling and off-road vehicle use can cause serious erosion, as well as disturbance to sensitive species.

There have been several papers published that empirically demonstrate that damage to vegetation in woodlands and other habitats can be caused by vehicles, walkers, horses and cyclists:

• Wilson & Seney (1994)8 examined the degree of track erosion caused by hikers, motorcycles, horses and cyclists from 108 plots along tracks in the Gallatin National Forest, Montana. Although the results proved difficult to interpret, it was concluded that horses and hikers disturbed more sediment on wet tracks, and therefore caused more erosion, than motorcycles and bicycles. • Cole et al (1995a, b)9 conducted experimental off-track trampling in 18 closed forest, dwarf scrub and meadow and grassland communities (each tramped between 0 – 500 times) over five mountain regions in the US. Vegetation cover was assessed two weeks and one year after trampling, and an inverse relationship with trampling intensity was discovered, although this relationship was weaker after one year than two weeks indicating some recovery of the vegetation. Differences in plant morphological characteristics were found to explain more variation in response between different vegetation types than soil and topographic factors. Low- growing, mat-forming grasses regained their cover best after two weeks and were considered most resistant to trampling, while tall forbs (non-woody vascular plants other than grasses,

8 Wilson, J.P. & J.P. Seney. 1994. Erosional impact of hikers, horses, motorcycles and off road bicycles on mountain trails in Montana. Mountain Research and Development 14:77-88 9 Cole, D.N. 1995a. Experimental trampling of vegetation. I. Relationship between trampling intensity and vegetation response. Journal of Applied Ecology 32: 203-214 Cole, D.N. 1995b. Experimental trampling of vegetation. II. Predictors of resistance and resilience. Journal of Applied Ecology 32: 215-224

Prepared for: London Borough of Bromley AECOM 25

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

sedges, rushes and ferns) were considered least resistant. Cover of hemicryptophytes and geophytes (plants with buds below the soil surface) was heavily reduced after two weeks, but had recovered well after one year and as such these were considered most resilient to trampling. Chamaephytes (plants with buds above the soil surface) were least resilient to trampling. It was concluded that these would be the least tolerant of a regular cycle of disturbance. • Cole (1995c)10 conducted a follow-up study (in 4 vegetation types) in which shoe type (trainers or walking boots) and trampler weight were varied. Although immediate damage was greater with walking boots, there was no significant difference after one year. Heavier tramplers caused a greater reduction in vegetation height than lighter tramplers, but there was no difference in effect on cover. • Cole & Spildie (1998)11 experimentally compared the effects of off-track trampling by hiker and horse (at two intensities – 25 and 150 passes) in two woodland vegetation types (one with an erect forb understorey and one with a low shrub understorey). Horse traffic was found to cause the largest reduction in vegetation cover. The forb-dominated vegetation suffered greatest disturbance, but recovered rapidly. Higher trampling intensities caused more disturbance. The total volume of dog faeces deposited on sites can be surprisingly large. For example, at Burnham Beeches National Nature Reserve over one year, Barnard12 estimated the total amounts of urine and faeces from dogs as 30,000 litres and 60 tonnes respectively. The specific impact on Epping Forest has not been quantified from local studies; however, the fact that habitats for which the SAC is designated appear to be subject already to excessive nitrogen deposition, suggests that any additional source of nutrient enrichment (including uncollected dog faeces) will make a cumulative contribution to overall enrichment. Any such contribution must then be considered within the context of other recreational sources of impact on sites.

4.1.2 Disturbance

Concern regarding the effects of disturbance on birds stems from the fact that they are expending energy unnecessarily and the time they spend responding to disturbance is time that is not spent feeding13. Disturbance therefore risks increasing energetic output while reducing energetic input, which can adversely affect the ‘condition’ and ultimately the survival of the birds. In addition, displacement of birds from one feeding site to others can increase the pressure on the resources available within the remaining sites, as they have to sustain a greater number of birds14.

The potential for disturbance may be less in winter than in summer, in that there are often a smaller number of recreational users. In addition, the consequences of disturbance at a population level may be reduced because birds are not breeding. However, winter activity can still cause important disturbance, especially as birds are particularly vulnerable at this time of year due to food shortages, such that disturbance which results in abandonment of suitable feeding areas through disturbance can have severe consequences. Several empirical studies have, through correlative analysis, demonstrated that out-of-season (October-March) recreational activity can result in quantifiable disturbance:

• Underhill et al15 counted waterfowl and all disturbance events on 54 water bodies within the South West London Water bodies Special Protection Area and clearly correlated disturbance with a decrease in bird numbers at weekends in smaller sites and with the movement of birds within larger sites from disturbed to less disturbed areas.

10 Cole, D.N. (1995c) Recreational trampling experiments: effects of trampler weight and shoe type. Research Note INT-RN-425. U.S. Forest Service, Intermountain Research Station, Utah 11 Cole, D.N., Spildie, D.R. (1998) Hiker, horse and llama trampling effects on native vegetation in Montana, USA. Journal of Environmental Management 53: 61-71 12 Barnard, A. (2003) Getting the Facts - Dog Walking and Visitor Number Surveys at Burnham Beeches and their Implications for the Management Process. Countryside Recreation, 11, 16 - 19 13 Riddington, R. et al. 1996. The impact of disturbance on the behaviour and energy budgets of Brent geese. Bird Study 43:269-279 14 Gill, J.A., Sutherland, W.J. & Norris, K. 1998. The consequences of human disturbance for estuarine birds. RSPB Conservation Review 12: 67-72 15 Underhill, M.C. et al. 1993. Use of Waterbodies in South West London by Waterfowl. An Investigation of the Factors Affecting Distribution, Abundance and Community Structure. Report to Thames Water Utilities Ltd. and English Nature. Wetlands Advisory Service, Slimbridge

Prepared for: London Borough of Bromley AECOM 26

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

• Evans & Warrington16 found that on Sundays total water bird numbers (including shoveler and gadwall) were 19% higher on Stocker’s Lake LNR in Hertfordshire, and attributed this to displacement of birds resulting from greater recreational activity on surrounding water bodies at weekends relative to week days. • Tuite et al17 used a large (379 site), long-term (10-year) dataset (September – March species counts) to correlate seasonal changes in wildfowl abundance with the presence of various recreational activities. They found that on inland water bodies shoveler was one of the most sensitive species to disturbance. The greatest impact on winter wildfowl numbers was associated with sailing/windsurfing and rowing. • Pease et al18 investigated the responses of seven species of dabbling ducks to a range of potential causes of disturbance, ranging from pedestrians to vehicle movements. They determined that walking and biking created greater disturbance than vehicles and that gadwall were among the most sensitive of the species studied. • In a three-year study of wetland birds at the Stour and Orwell SPA, Ravenscroft19 found that walkers, boats and dogs were the most regular source of disturbance. Despite this, the greatest responses came from relatively infrequent events, such as gun shots and aircraft noise Birds seemed to habituate to frequent ‘benign’ events such as vehicles, sailing and horses, but there was evidence that apparent habituation to more disruptive events related to reduced bird numbers – i.e. birds were avoiding the most frequently disturbed areas. Disturbance was greatest at high tide and on the Orwell, but birds on the Stour showed greatest sensitivity. A number of studies have shown that birds are affected more by dogs and people with dogs than by people alone, with birds flushing more readily, more frequently, at greater distances and for longer. In addition, dogs, rather than people, tend to be the cause of many management difficulties, notably by worrying grazing animals, and can cause eutrophication near paths. Nutrient-poor habitats such as heathland are particularly sensitive to the fertilising effect of inputs of phosphates, nitrogen and potassium from dog faeces20 .

Underhill-Day21 summarises the results of visitor studies that have collected data on the use of semi- natural habitat by dogs. In surveys where 100 observations or more were reported, the mean percentage of visitors who were accompanied by dogs was 54.0%.

However the outcomes of many of these studies need to be treated with care. For instance, the effect of disturbance is not necessarily correlated with the impact of disturbance, i.e. the most easily disturbed species are not necessarily those that will suffer the greatest impacts. It has been shown that, in some cases, the most easily disturbed birds simply move to other feeding sites, whilst others may remain (possibly due to an absence of alternative sites) and thus suffer greater impacts on their population22. A literature review undertaken for the RSPB23 also urges caution when extrapolating the results of one disturbance study because responses differ between species and the response of one species may differ according to local environmental conditions. These facts have to be taken into account when attempting to predict the impacts of future recreational pressure on European designated sites.

16 Evans, D.M. & Warrington, S. 1997. The effects of recreational disturbance on wintering waterbirds on a mature gravel pit lake near London. International Journal of Environmental Studies 53: 167-182 17 Tuite, C.H., Hanson, P.R. & Owen, M. 1984. Some ecological factors affecting winter wildfowl distribution on inland waters in England and Wales and the influence of water-based recreation. Journal of Applied Ecology 21: 41-62 18 Pease, M.L., Rose, R.K. & Butler, M.J. 2005. Effects of human disturbances on the behavior of wintering ducks. Wildlife Society Bulletin 33 (1): 103-112. 19 Ravenscroft, N. (2005) Pilot study into disturbance of waders and wildfowl on the Stour-Orwell SPA: analysis of 2004/05 data. Era report 44, Report to Suffolk Coast & Heaths Unit. 20 Shaw, P.J.A., K. Lankey and S.A. Hollingham (1995) – Impacts of trampling and dog fouling on vegetation and soil conditions on Headley Heath. The London Naturalist, 74, 77-82. 21 Underhill-Day, J.C. (2005). A literature review of urban effects on lowland heaths and their wildlife. Natural England Research Report 623. 22 Gill et al. (2001) - Why behavioural responses may not reflect the population consequences of human disturbance. Biological Conservation, 97, 265-268 23 Woodfield & Langston (2004) - Literature review on the impact on bird population of disturbance due to human access on foot. RSPB research report No. 9.

Prepared for: London Borough of Bromley AECOM 27

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Disturbing activities are on a continuum. The most disturbing activities are likely to be those that involve irregular, infrequent, unpredictable loud noise events, movement or vibration of long duration (such as those often associated with construction activities). Birds are least likely to be disturbed by activities that involve regular, frequent, predictable, quiet patterns of sound or movement or minimal vibration. The further any activity is from the birds, the less likely it is to result in disturbance.

The factors that influence a species response to a disturbance are numerous, but the three key factors are species sensitivity, proximity of disturbance sources and timing/duration of the potentially disturbing activity.

It should be emphasised that recreational use is not inevitably a problem. Many European designated sites are also nature reserves managed for conservation and public appreciation of nature. At these sites, access is encouraged and resources are available to ensure that recreational use is managed appropriately.

Where increased recreational use is predicted to cause adverse impacts on a site, avoidance and mitigation should be considered. Avoidance of recreational impacts at European designated sites involves location of new development away from such sites; Local Development Frameworks (and other strategic plans) provide the mechanism for this. Where avoidance is not possible, mitigation will usually involve a mix of access management, habitat management and provision of alternative recreational space.

4.2 Atmospheric Pollution

The main pollutants of concern for European sites are oxides of nitrogen (NOx), ammonia (NH3) and sulphur dioxide (SO2). NOx can have a directly toxic effect upon vegetation. In addition, greater NOx or ammonia concentrations within the atmosphere will lead to greater rates of nitrogen deposition to soils. An increase in the deposition of nitrogen from the atmosphere to soils is generally regarded to lead to an increase in soil fertility, which can have a serious deleterious effect on the quality of semi- natural, nitrogen-limited terrestrial habitats.

According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”24. This is therefore the distance that has been used throughout this HRA in order to determine whether European sites are likely to be significantly affected by development under the Local Plan.

Figure 2: Traffic Contribution to Concentrations of Pollutants at Different Distances from a

Road (Source: DfT)

24 http://www.dft.gov.uk/webtag/documents/expert/unit3.3.3.php#013 [accessed 14/11/2016]

Prepared for: London Borough of Bromley AECOM 28

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

4.3 Water Quantity

London is generally an area of high water stress. It is particularly vulnerable to climate change now and in the future. It is already the driest region in the country and the predicted changes will affect the amount and distribution of rainfall, and the demand for water from all sectors. The average natural summer flows of rivers could drastically reduce; the period where groundwater resources are replenished could be shorter; and resources could become much more vulnerable. By 2050, climate change could reduce water resources by 10 -15% on an annual average basis, and reduce summer river flows by 50 -80%. Drought and floods may become more frequent in the future. The reliability of existing reservoirs, groundwater extractions and river intakes will change. The delivery of housing and economic development throughout the region could therefore result in adverse effects on many European designated sites. The Thames Water Water Resource Management Plan (WRMP) for London25 (which includes the London Borough of Bromley) identifies that whilst there is a significant supply demand deficit against the dry year annual average demand through the plan period (to 2040), provisions have been put in place to ensure water supply will be sufficient to allow for future development through to 2040. This includes provision such as reducing leakages, use of meters, new water trading agreements, development of new groundwater schemes, and promotion of water efficiency, raw water transfer, and waste water reuse.

4.4 Water Quality

The quality of the water that feeds European sites is an important determinant of the nature of their habitats and the species they support. Poor water quality can have a range of environmental impacts:

• At high levels, toxic chemicals and metals can result in immediate death of aquatic life, and can have detrimental effects even at lower levels, including increased vulnerability to disease and changes in wildlife behaviour. • Eutrophication, the enrichment of plant nutrients in water, increases plant growth and consequently results in oxygen depletion. Algal blooms, which commonly result from eutrophication, increase turbidity and decrease light penetration. The decomposition of organic wastes that often accompanies eutrophication deoxygenates water further, augmenting the oxygen depleting effects of eutrophication. In the marine environment, nitrogen is the limiting plant nutrient and so eutrophication is associated with discharges containing available nitrogen. • Some pesticides, industrial chemicals, and components of sewage effluent are suspected to interfere with the functioning of the endocrine system, possibly having negative effects on the reproduction and development of aquatic life. Sewage and some industrial effluent discharges contribute to increased nutrients in the European sites and in particular to phosphate levels in watercourses.

25 Thames Water (2015). Final Water resource Management Plan (2015-2040)

Prepared for: London Borough of Bromley AECOM 29

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

5. European Designated Sites Screening

This chapter provides further details of the European designated sites that are considered within this document as introduced in section 1.3. It includes details of their reasons for designation, conservation objectives (where appropriate), and environmental vulnerabilities. Following this, each site is assessed for the presence of potential impact pathways linking the European designated site to the London borough of Bromley’s Proposed Submission Draft Local Plan.

European designated sites that are considered to be located within a potential sphere of influence are:

• Wimbledon Common SAC • Richmond Park SAC • Epping Forest SAC • Lee Valley SPA and Ramsar • Mole Gap to Reigate Escarpment SAC • North Downs Woodlands SAC • Thames Estuary and Marshes SPA and Ramsar

5.1 Wimbledon Common SAC

5.1.1 Introduction

Wimbledon Common is one of the largest areas of uncultivated land in the conurbation of London and sits in the Thames Valley Natural Character Area. It supports a mosaic of habitats including broadleaved woodland, acid grassland, dry and wet heath, scrub and mire.

5.1.2 Qualifying Features26

The site is designated for the following habitats listed in Annex II species:

• Stag beetle Lucanus cervus The site is designated for the following habitats listed in Annex I habitats

• European dry heaths • Northern Atlantic wet heaths with Erica tetralix. (Wet heathland with cross-leaved heath)

5.1.3 Conservation Objectives27

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

• The extent and distribution of qualifying natural habitats and habitats of qualifying

26 Natural England (2005). Citation for Special Area of Conservation (SAC) Wimbledon Common SAC. http://publications.naturalengland.org.uk/file/5779849067102208 [accessed 09/11/2016] 27 Natural England (2014). European Site Conservation Objectives for Wimbledon Common Special Area of Conservation Site code: UK0030301. http://publications.naturalengland.org.uk/file/6449586067472384 [accessed 09/11/2016]

Prepared for: London Borough of Bromley AECOM 30

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Species

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

5.1.4 Environmental Vulnerabilities

• Recreational pressure • Habitat fragmentation • Invasive non-native species • Atmospheric pollution • Hydrology

5.1.5 Likely Significant Effects of the Draft Local Plan

Wimbledon Common SAC is the closest European designated site to the London Borough of Bromley. It is located 9.8km from the borough boundary. The environmental vulnerabilities of recreational pressure, atmospheric pollution and hydrology (listed in section 5.1.4) have potential to be linked to a Plan document such as the Draft Local Plan.

5.1.5.1 Recreational pressure

There is no information available that indicates visitors to the SAC or the key points of visitor origin. However, the site can be compared to other designated sites with similar habitat features (albeit sites located within a less urban environment). Wimbledon Common SAC is a large heathland site surrounded by urban development. This is broadly similar to other SACs such as the more rural Thames Basin Heaths SAC, and Wealden Heaths Phase II SPA (Woolmer Forest SAC) and these sites have had visitor surveys conducted. However, Wimbledon Common is a much more urban site than these other heathland sites and is time consuming to reach if one does not live very locally. It is therefore probable that its core catchment for Wimbledon Common SAC is more local than that of the two SPAs.

Visitor studies undertaken at the rural Thames Basin Heaths SPA28 and Wealden Heaths Phase II SPA 29 identified that whilst some local visitors arrived by foot, the majority originated within 5km of the SPAs. This 5km core catchment was agreed by Natural England, indicating that any new housing beyond 5km of these SPAs would not result in a likely significant effect alone or in combination with any project or plan. Whilst it is acknowledged that this does not identify the core catchment for Wimbledon Common SAC, it gives a broad indicator of core catchment for heathland habitats within the south of England. In addition, it can be considered that the urban setting of Wimbledon Common SAC (lack of ease of access to the SAC from a wider area) will reduce the catchment of the site further. As such, due to the distances involved, it can be concluded that this is not a realistic impact pathway/

In support of this conclusion, the HRA for part of Merton’s Submission Local Plan30 identified that, although vulnerable to increases in recreational pressure, the management of Wimbledon Common by the Wimbledon Common and Putney Heath Conservators with the use of bylaws such as dog

28 Liley, D. et al. 2005. Visitor access patterns on the Thames Basin Heaths. English Nature Research Report, English Nature, Peterborough 29 This comes from two separate studies – the Whitehill & Bordon visitor surveys undertaken by UE Associates and a separate piece of work undertaken by Footprint Ecology for The National Trust in relation to the Hindhead Common/Devil’s Punchbowl section of the SPA 30 Merton Sites and Policies and Policies Map (Part of Merton’s local plan) Submission (September 2013) http://www.merton.gov.uk/sp4.10_hra.pdf [Accessed 15/11/2016]

Prepared for: London Borough of Bromley AECOM 31

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

control orders, mitigate against the potential impacts from increased recreational use, thus resulting in no likely significant effects upon the SAC. The emerging Wandsworth Local Plan Habitats Regulations Assessment (2015)31 screened out any impacts from the emerging Wandsworth Local Plan. Correspondence with Natural England confirmed that they agreed with this determination based on the fact that ‘other suitable open/green spaces are available, there are new open/green spaces due to be provided in the area and that alternative methods of transport, such as walking and cycling, are to be promoted as far as possible’32. Based on the fact that that the authorities containing Wimbledon Common SAC were able to screen out any likely significant effects upon the SAC from increases in recreational pressure resulting from increases in housing numbers within their authority boundaries and in-combination with other project or plans, and the fact that the SAC is considered to have a core catchment of 5km or less, it is determined that the Draft Local Plan will not result in any likely significant effects upon Wimbledon Common SAC resulting from an increase in recreational pressure.

5.1.5.2 Atmospheric pollution

Table 9 illustrates that levels of atmospheric pollutants such as nitrogen deposition within the SAC are either within or in exceedance of their Critical Load limits.

Table 9: Critical Loads of Wimbledon Common SAC and existing Nitrogen deposition rates upon SAC features If hi-lighted in red, the feature is already in exceedance of its Critical Load. If hi-lighted in orange, the feature is within its Critical Load limits. Site Feature Critical Load33 Current levels of N deposition34

Northern Atlantic wet heaths with Erica tetralix• 10-20kg N/ha/yr 14.28kg N/ha/yr European dry heaths 10-20kg N/ha/yr 14.28kg N/ha/yr Stag beetle 10-20kg N/ha/yr 24.64kg N/ha/yr

5.1.5.3 Due to the distances involved from the London Borough of Bromley to the SAC (9.8km in a straight line), it can be considered that traffic resulting from the Draft Local Plan will have sufficiently dispersed and it is highly unlikely that roads within 200m of Wimbledon Common SAC would result in increased traffic above 1000 AADT as a result of the Draft Local Plan. It is considered that the Draft Local Plan does not provide any realistic impact pathway to the SAC via atmospheric pollution and this impact pathway can be screened out from further consideration. Hydrology

The site is partially designated for wet heathland which has potential to be vulnerable to changes in hydrology as a result of any potential need for increased water abstraction or changes in groundwater flows resulting from the Draft Local Plan. The HRA for Wandsworth Local Plan35 does not identify hydrology as an impact pathway for consideration. This approach is echoed by the HRA supporting Merton’s Local Plan36. Further to this, any changes in water abstraction as a result of increased demand will require to be approved by the Environmental Agency. Consents would not be permitted if likely significant effect upon European designated sites such as Wimbledon Common were to result. As such, this impact pathway impacting upon Wimbledon Common SAC can be screened out from further consideration.

31 Wandsworth LDF/ Local Plan Document Habitats Regulations Assessment (2015) http://www.wandsworth.gov.uk/download/downloads/id/10743/lpr422_habitats_regulations_assessment_2015.pdf [Accessed 15/11/2016] 32 Natural England Correspondence (2015) http://www.wandsworth.gov.uk/download/downloads/id/10745/lpr424_natural_england_comments_on_wandswort h_hra_29-5-15.pdf [Accessed 15/11/2016] 33 www. APIS.co.uk [accessed 15/11/2016] 34 www.APIS.co.uk [accessed 15/11/2016] 35 Wandsworth LDF/ Local Plan Document Habitats Regulations Assessment (2015) http://www.wandsworth.gov.uk/download/downloads/id/10743/lpr422_habitats_regulations_assessment_2015.pdf [Accessed 15/11/2016] 36 http://www.merton.gov.uk/sp4.10_hra.pdf [accessed 15/11/2016

Prepared for: London Borough of Bromley AECOM 32

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

5.2 Richmond Park SAC

5.2.1 Introduction

Richmond Park SAC is a parkland site covering 847ha. It has been managed as a royal deer park since the 17th century and continues to be managed as one of London's Royal Parks. It is significant for its dry acid grassland and neutral unimproved grassland mosaic, extensive wooded areas and an impressive population of veteran trees. These habitats support a rich invertebrate assemblage; in the case of the woodland and veteran trees this relates to saproxylic invertebrates, particularly Stag Beetles Lucanus cervus.

5.2.2 Qualifying Features37

Designated as an SAC for its Annex II species:

• Stag beetle Lucanus cervus

5.2.3 Conservation Objectives38

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

• The extent and distribution of the habitats of qualifying species • The structure and function of the habitats of qualifying species • The supporting processes on which the habitats of qualifying species rely • The populations of qualifying species, and, • The distribution of qualifying species within the site

5.2.4 Environmental Vulnerabilities

• Lack of deadwood

5.2.5 Likely Significant Effects of the Draft Local Plan

This SAC is located 12.2km west of the London Borough of Bromley. A lack of dead wood is not an environmental vulnerability that could be linked to a Plan document. It is related to site management. As such there are no impact pathways present and the SAC can be screened out from further consideration both alone and in combination with other projects or plans.

5.3 Epping Forest SAC

5.3.1 Introduction

Epping Forest is one of only a few remaining large-scale examples of ancient wood-pasture in lowland Britain and has retained habitats of high nature conservation value including ancient semi- natural woodland, old grassland plains and scattered wetland. The semi-natural woodland is particularly extensive, forming one of the largest coherent blocks in the country. Most is characterised by groves of over-mature pollards and these exemplify all three of the main wood-pasture types found in Britain: beech-oak, hornbeam-oak and mixed oak. The Forest plains are also a major feature and contain a variety of unimproved acid grasslands which have become uncommon elsewhere in Essex and the London area. In addition, Epping Forest supports a nationally outstanding assemblage of invertebrates, a major amphibian interest and an exceptional breeding bird community.

37 JNCC (2016). Natura 2000 Standard data Form. Richmond Park SAC http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0030246.pdf [accessed 11/11/2016] 38 Natural England (2014). European Site Conservation Objectives for Richmond Park Special Area of Conservation Site code: UK0030246 http://publications.naturalengland.org.uk/file/6608768628424704 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 33

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

5.3.2 Qualifying Features39

The site is designated as an SAC for the following features:

Annex I habitats:

• Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils • Northern Atlantic wet heaths with Erica tetralix • European dry heaths Annex II species:

• Stag beetle Lucanus cervus

5.3.3 Conservation Objectives40

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

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

5.3.4 Environmental Vulnerabilities

• Habitat management: After neglect of the pollard cycle for over 100 years, re-pollarding of ancient beech trees was started in the early 1990s, and creation of maiden pollards was begun in 1995. • Atmospheric pollution • Lack of deadwood • Recreational pressure

5.3.5 Likely Significant Effects of the Draft Local Plan

Epping Forest SAC is located 14.5km north of the London Borough of Bromley.

5.3.5.1 Air pollution

Table 10 illustrates that levels of atmospheric pollutants such as nitrogen deposition within the SAC are already in exceedance of their Critical Load limits (identified in red).

Due to the distances involved from the London Borough of Bromley to the SAC (more than 10km in a straight line), it can be considered that traffic resulting from the Draft Local Plan will have sufficiently dispersed and it is highly unlikely that roads within 200m of Epping Forest SAC would result in increased traffic above 1000 AADT as a result of the Draft Local Plan. It is considered that the Draft

39 JNCC (2012). Natura 2000 – Standard Data Form Epping Forest. http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0012720.pdf [accessed 11/11/2016] 40 Natural England (2014). European Site Conservation Objectives for Epping Forest Special Area of Conservation Site Code: UK0012720 http://publications.naturalengland.org.uk/file/4926121657237504 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 34

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Local Plan does not provide any realistic impact pathway to the SAC via atmospheric pollution and this impact pathway can be screened out from further consideration.

5.3.5.2 Recreational pressure

Epping Forest SAC receives a great many visits per year (estimated at over 4 million) and discussions with the Corporation of London have identified long-standing concerns about increasing recreational use of the forest resulting in damage to its interest features. A 2011 visitor survey report41 identified that those living within 2km of the edge of the Forest comprise at least 95% of all visitors. However, further analysis of these data was undertaken by Footprint Ecology in September 201642. This further analysis identified that, although the scale of the data was substantial (in 2014 alone almost 900 questionnaires were returned) the catchment appeared to be larger than suggested by previous reports. Based on 2014 data it appeared that 89% of survey respondents originating from within 5km of the SAC and 76% originating from within 4km. Due to the distances involved, an increase in recreational pressure as a result of the Bromley Local Plan is considered to be highly unlikely, and as such there is no realistic impact pathway present linking recreational pressure from the Plan to the SAC. As such, this impact pathway can be screened out from further consideration.

5.4 Lee Valley SPA and Ramsar

5.4.1 Introduction

The Lee Valley SPA and Ramsar site is located to the north-east of London, where a series of wetlands and reservoirs occupy about 20 km of the valley. The site comprises embanked water supply reservoirs, sewage treatment lagoons and former gravel pits that support a range of man-made, semi- natural and valley bottom habitats. These wetland habitats support wintering wildfowl, in particular Gadwall Anas strepera and Shoveler Anas clypeata, which occur in numbers of European importance. Areas of reedbed within the site also support significant numbers of wintering Bittern Botaurus stellaris. Lee Valley SPA is split into two sections, a northern and a southern. The southern section is located adjacent to the eastern boundary of the London Borough of Haringey. It contains Walthamstow Reservoir SSSI and Walthamstow Marshes SSSI. The northern section is located approximately 9.5km north of the Borough which contains Turnford and Chestnut Pits SSSI.

5.4.2 Qualifying Features

The site qualifies as an SPA for the following Annex I species43:

• Wintering bittern Botaurus stellaris. 6 individuals representing at least 6.0% of the wintering population in Great Britain (5 year peak mean, 1992/3-1995/6) • Migratory gadwall Anas strepera. 515 individuals representing at least 1.7% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Migratory shoveler Anas clypeata. 748 individuals representing at least 1.9% of the wintering Northwestern/Central Europe population (5 year peak mean 1991/2 - 1995/6) The site qualifies under the following Ramsar criterion:

Criterion 2: The site supports the nationally scarce plant species44:

• whorled water-milfoil Myriophyllum verticillatum and the rare or vulnerable invertebrate Micronecta minutissima (a water-boatman). Criterion 6: Species/populations occurring at levels of international importance.

41 Alison Millward Associates. 2011. Epping Forest Visitor Survey 2011: Results Summary 42 Footprint Ecology (2016). Initial review of current visitor data for Epping Forest 43 JNCC (2015). Natura 2000 – Standard data Form Lee Valley. http://jncc.defra.gov.uk/pdf/SPA/UK9012111.pdf [accessed 11/11/2016] 44 JNCC (2000) Information Sheet on Ramsar Wetlands. Lee Valley http://jncc.defra.gov.uk/pdf/RIS/UK11034.pdf [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 35

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Species with peak counts in spring/autumn:

• Northern shoveler, Anas clypeata, (NW & C Europe) 287 individuals, representing an average of 1.9% of the GB population (5 year peak mean 1998/9- 2002/3) Species with peak counts in winter:

• Gadwall, Anas strepera strepera, (NW Europe) 445 individuals, representing an average of 2.6% of the GB population (5 year peak mean 1998/9-2002/3)

5.4.3 Conservation Objectives for the SPA45

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; the extent and distribution of the habitats of the qualifying features.

• The structure and function of the habitats of the qualifying features • The supporting processes on which the habitats of the qualifying features rely • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site.

5.4.4 Environmental Vulnerabilities

• Water quality: eutrophication from waste water. This is being addressed by AMP3 funding under the urban Waste Water Treatment Directive • Water quantity: over extraction of surface water for public consumption, notably during drought periods. This is managed via Environment Agency Review of Consents. • Recreational pressure: this is managed by zoning of waterbodies within the Lee Valley Regional Park.

5.4.5 Likely Significant Effects of the Draft Local Plan

The Lee Valley SPA and Ramsar site is located 15.9km north of the London Borough of Bromley. Due to the due to the distances involved there are no realistic impact pathways present between the European designated site and recreational pressure.

5.4.5.1 Hydrology

Almost all settlements within Epping Forest receive their potable water supply through Affinity Water. Within its catchment Affinity Water abstracts water from tributaries of Lee Valley SPA/Ramsar site.

The Lee Valley SPA/Ramsar site consists of four Sites of Special Scientific Interest, of which Turnford and Cheshunt Pits SSSI, Rye Meads SSSI and Amwell Quarry SSSI all lie on the Hertfordshire/Essex border. Walthamstow Reservoirs SSSI lies within London Borough of Waltham Forest and is part of Thames Water’s supply infrastructure. Walthamstow Reservoirs is a sealed storage reservoir and part of the public water supply infrastructure for London. Its ecological interest has established because of its use as a storage reservoir and therefore continued use for this purpose to supply London will not result in a likely significant effect.

5.5 Mole Gap to Reigate Escarpment SAC

5.5.1 Introduction

This site contains the largest part of the North Downs in Surrey which has remained relatively undisturbed by the pressures of modern farming and building. It stretches for 8 miles (12 km) between Leatherhead and Reigate, and includes a range of outstanding wildlife habitats representative of the

45 Natural England (2014)European Site Conservation Objectives for Lee Valley Special Protection Area Site Code: UK9012111 http://publications.naturalengland.org.uk/file/5168095937167360 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 36

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

best of those found on the North Downs. Woodland, chalk grassland, chalk scrub and heathland form an interrelated mosaic which supports a wide diversity of characteristic plants and animals, of which many are local or rare.

5.5.2 Qualifying Features46

Designated as an SAC for the following Annex I habitats:

• European dry heaths • Stable xerothermophilous formations with Buxus sempervirens on rock slopes (Berberidion p.p.) • Juniperus communis formations on heaths or calcareous grasslands • Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia) (* important orchid sites) • Asperulo-Fagetum beech forests • Taxus baccata woods of the British Isles Designated as an SAC for the following Annex II species:

• Bechstein’s bat Myotis bechsteinii • Great crested newt Triturus cristatus

5.5.3 Conservation Objectives47

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

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

5.5.4 Environmental Vulnerabilities

• Disease • Inappropriate scrub management • Change in land management • Recreational pressure • Atmospheric pollution • Loss of supporting habitat (bat flight lines)

5.5.5 Likely Significant Effects of the Draft Local Plan

Mole Gap to Reigate Escarpment SAC is located 16.1km south west of the London Borough of Bromley. Whilst the environmental vulnerabilities of disease, recreational pressure, atmospheric pollution and loss of supporting habitats as identified in section 5.5.4 have potential to be linked to a

46 JNCC (2015) Standard Data Form. Mole Gap to Reigate Escarpment. http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0012804.pdf [accessed 11/11/2016] 47 Natural England (2014) European Site Conservation Objectives for Mole Gap to Reigate Escarpment Special Area of Conservation Site Code: UK0012804 http://publications.naturalengland.org.uk/file/5374121487630336 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 37

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Plan document such as the Draft Local Plan, due to the distances involved there are no realistic impact pathways present. As such, no likely significant effects will result and this SAC can be screened out from further consideration both alone and in combination with other projects or plans.

5.6 North Downs Woodlands SAC

5.6.1 Introduction

This site consists of mature Beech forests and Yew woods on steep slopes. The stands lie within a mosaic of scrub and other woodland types and are the most easterly of the Beech woodland sites selected some of which were affected by the storm of 1987. Small areas of unimproved chalk grassland are also present.

5.6.2 Qualifying Features48

The SAC is designated for the following Annex I habitats:

• Taxus baccata woods of the British Isles. (Yew-dominated woodland)* • Asperulo-Fagetum beech forests. (Beech forests on neutral to rich soils) • Semi-natural dry grasslands and scrubland facies: on calcareous substrates (FestucoBrometalia). (Dry grasslands and scrublands on chalk or limestone)

5.6.3 Conservation Objectives49

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

• The extent and distribution of the qualifying natural habitats • The structure and function (including typical species) of the qualifying natural habitats, and, • The supporting processes on which the qualifying natural habitats rely

5.6.4 Environmental Vulnerabilities

• Invasive non-native species • Atmospheric pollution • Recreational pressure • Forestry and woodland management

5.6.5 Likely Significant Effects of the Draft Local Plan

The North Downs Woodlands SAC is located 17.1km east of the London Borough of Bromley. Whilst the environmental vulnerabilities identified in section 5.6.4 have potential to be linked to a Plan document such as the Draft Local Plan, due to the distances involved there are no realistic impact pathways present. As such, no likely significant effects will result and this SAC can be screened out from further consideration both alone and in combination with other projects or plans.

48 JNCC (2016). Natura 2000 – Standard Data Form North Downs Woodlands SAC http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0030225.pdf [accessed 11/11/2016] 49 Natural England (2014). European Site Conservation Objectives for North Downs Woodlands Special Area of Conservation Site code: UK0030225 http://publications.naturalengland.org.uk/file/5154051591241728 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 38

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

5.7 Thames Estuary and Marshes SPA and Ramsar

5.7.1 Introduction

The SPA and Ramsar site extends from Gravesend to the eastern end of the Isle of Grain. It forms a major component of the Greater Thames Estuary. The site consists of an extensive mosaic of grazing marsh, saltmarsh, mudflats and shingle characteristic of the estuarine habitats of the north Kent marshes. Freshwater pools and some areas of woodland provide additional variety and complement the estuarine habitats. The site supports outstanding numbers of waterfowl with total counts regularly exceeding 20,000. Many species regularly occur in nationally important1 numbers and some species regularly use the site in internationally important numbers. The breeding bird community is also of particular interest. The diverse habitats within the site support a number of nationally rare and scarce invertebrate species and an assemblage of nationally scarce plants.

5.7.2 Qualifying Features

The SPA is designated for the following Annex II Species50:

• Dunlin Calidris alpina alpina • Knot Calidris canutus • Ringed plover Charadrius hiaticula • Hen harrier Circus cyaneus • Black-tailed godwit Limosa limosa islandica • Grey plover Pluvialis squatarola • Avocet Recurvirostra avosetta • Redshank Tringa totanus The Ramsar site is designated under the following criterion51:

• Ramsar criterion 2: The site supports one endangered plant species and at least 14 nationally scarce plants of wetland habitats. The site also supports more than 20 British Red Data Book invertebrates. • Ramsar criterion 5: Assemblages of international importance: Species with peak counts in winter: 45118 waterfowl (5 year peak mean 1998/99-2002/2003) • Ramsar criterion 6: Species/populations occurring at levels of international importance. ─ Species with peak counts in spring/autumn: . Ringed plover, Charadrius hiaticula . Black-tailed godwit, Limosa limosa islandica ─ Species with peak counts in winter: . Grey plover, Pluvialis squatarola . Red knot, Calidris canutus islandica . Dunlin, Calidris alpina alpina . Common redshank, Tringa totanus totanus

5.7.3 Conservation Objectives for the SPA52

50 JNCC (2016) Natura 2000 – Standard Data Form Thames Estuary and Marshes SPA http://jncc.defra.gov.uk/pdf/SPA/UK9012021.pdf [accessed 11/11/2016] 51JNCC (2008) Information Sheet on Ramsar Wetlands (RIS) Thames Estuary and Marshes http://jncc.defra.gov.uk/pdf/RIS/UK11069.pdf [accessed 11/11/2016] 52 Natural England (2014) European Site Conservation Objectives for Thames Estuary and Marshes Special Protection Area Site Code: UK9012021 http://publications.naturalengland.org.uk/file/5268280864407552 [accessed 11/11/2016]

Prepared for: London Borough of Bromley AECOM 39

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring;

• The extent and distribution of the habitats of the qualifying features • The structure and function of the habitats of the qualifying features • The supporting processes on which the habitats of the qualifying features rely • The population of each of the qualifying features, and, • The distribution of the qualifying features within the site.

5.7.4 Environmental Vulnerabilities

• Invasive non-native species • Recreational pressure (including illicit vehicle use) • Coastal squeeze • Fisheries activities • Atmospheric pollution

5.7.5 Likely Significant Effects of the Draft Local Plan

The Thames Estuary and Marshes SPA and Ramsar site is located 17.6km east of the London Borough of Bromley. Whilst the environmental vulnerabilities of invasive non-native species, recreational pressure, coastal squeeze and atmospheric pollution as identified in section 5.7.4 have potential to be linked to a Plan document such as the Draft Local Plan, due to the distances involved there are no realistic impact pathways present. As such, no likely significant effects will result and this SAC can be screened out from further consideration both alone and in combination with other projects or plans.

Prepared for: London Borough of Bromley AECOM 40

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

6. Screening Conclusions

The Draft Local Plan has potential to provide the following impact pathways that could link to a European designated site:

• Recreational pressure • Atmospheric pollution • Water quality and water quantity. The following European designated sites were considered to be within a suitable sphere of influence from the Draft Local Plan and as such were assessed:

• Wimbledon Common SAC • Richmond Park SAC • Epping Forest SAC • Lee Valley SPA and Ramsar • Mole Gap to Reigate Escarpment SAC • North Downs Woodlands SAC • Thames Estuary and Marshes SPA and Ramsar The closest European designated site to the London Borough of Bromley is Wimbledon Common SAC located 9.8km from the borough. Following a likely significant effect test, it was concluded that due to the distances involves and the vulnerabilities of each European designated site there were no realistic impact pathways present linking European designated sites to the Draft Local Plan either alone or in combination with other projects or plans. The Draft Local Plan can be screened out from further consideration.

Prepared for: London Borough of Bromley AECOM 41

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Appendix A : Figure A1: Location of European Designated Sites in Relation to the London Borough of Bromley.

Prepared for: London Borough of Bromley AECOM 42

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Prepared for: London Borough of Bromley AECOM 43

Habitats Regulations Assessment for the London Borough of Bromley's Proposed Submission Draft Local Plan

Isla Hoffmann-Heap Consultant Ecologist T: 01256 310 486 M: 07920 789 719 E: [email protected]

AECOM Limited Midpoint Alencon Link Basingstoke Hampshire RG21 7PP UK

T: +44(0)1256 310200 aecom.com

Prepared for: London Borough of Bromley AECOM 44