(ILF H6)

Core Strategy Response

Response to North & Council Core Strategy DPD’s Issues & Options Document

Worth Meadows, Ilfracombe – Ilf H6

December 2007

Ilfracombe (ILF H6)

Core Strategy Response

Contents

Introduction

Section 1. Location 1.1 Site Locations 1.2 Site Analysis

Section 2. Background Issues 2.1 Planning 2.2 Other issues

Section 3. Assessment 3.1 Summary Landscape Assessment 3.2 Summary Ecological Assessment 3.4 Summary Highways Appraisal 3.5 Summary Sustainability Appraisal

Section 4. Development Options 4.1 Development Concepts 4.2 Access / Highways 4.3 Deliverability

Appendix 1 – David Wilson Partnership Landscape Assessment

Appendix 2 – Ambios Ecology Ecological assessment

Appendix 3 – Peter Brett Asscociates Highways appraisal

Appendix 4 – Tom Jones Sustainability appraisal

Ilfracombe (ILF H6)

Core Strategy Response i Introduction i.i This report has been prepared as a response to District Council & Torridge District Council’s joint core strategy issues and options DPD. i.ii It has been prepared on behalf of Midas Homes Ltd. i.iii Contributions to its content are from;

- David Wilson Partnership – Architects & Landscape Architects - Midas Homes Ltd – Developer - Ambios Ecology – Ecological Consultants - Peter Brett Associates – Highways, Drainage, Flood risk - Tom Jones – Sustainability Consultant i.iv The main body of the report contains the summary information all background and full report information is contained within the appendices. i.v All maps are reproduced by permission of Ordnance Survey on behalf of The Controller of Her Majesty’s Stationer y Office. Crown copyright. All rights reserved. ,Licence Number 100041893.

Ilfracombe (ILF H6)

Core Strategy Response

Section 1 1.1 Site Location 1.1.1 The potential site identified within the draft core strategy document and covered in this Potential to provide additional parking and bus turning area for the college report is site ILF H6. The site is some 8ha in area and is located to the east of the town east of Worth Rd Cons Steeply sloping with drainage issues* 1.2 Physical Site Analysis Visible from parts of the North Devon AONB 1.2.1 Summary of Analysis * denotes item raised within joint cores strategy document Pros Close to college and town centre- close to listed buildings and conservation area * 1.2.2 – The site area under consideration and denoted by the red line is 8 Hectares

Ilfracombe (ILF H6)

Core Strategy Response

Section 2 - Relevant Background Issues conservation area. Whilst this statement may be correct in plan view, in terms of direct links and inter visibility this statement is not correct. 2.1 Planning 2.2 Other issues The Roger Tym and Partners “Functional Analysis of Settlement” identifies Ilfracombe as an “Other Significant Town” with a high level of self containment and as such it fall within RSS Historically this land was within the settlement development boundary and planning permission Policy B which requires that the scale of development at towns should be dependent on their was granted in 1991 for a Bovis Homes scheme of 102 detached houses (this permission was function. never implemented and lapsed in 1996).

The North Devon Local Plan identified the town as an Area Centre, an important role which it At the last Local Plan review the Inspector considered that this green field site could needs to continue to fulfil. Opportunities to provide much needed additional housing in the accommodate approximately 250 dwellings (35 dwelling per hectare). However, at that time Ilfracombe area are extremely limited. At this point in time a detailed appraisal of all of the there was considered to be no need for the release of green field sites in North Devon. identified sites has not been undertaken. We would however wish to identify the undoubted potential of ILF H6 to provide much needed additional housing to serve the area. The site has This position has changed with emerging Government and Regional policy, in particular the draft Regional Spatial Strategy (RSS) that will require green field sites to come forward in North previously been the subject of an earlier planning consent and also Inspector’s consideration at Devon, with Ilfracombe required to provide approximately 50 new homes per annum. the last Local Plan Inquiry. The proposal will also provide an opportunity to look at the existing access/parking issue of the We believe that ILF H6 is sequentially preferable to H1, H2 and H7 because of impact on the adjacent collage site, to see if this current unsatisfactory situation can be addressed. For AONB. H2, H7 and H8 do not relate well to the existing settlement pattern whereas H6 may be example by providing some additional on-street staff parking as part of the proposed scheme. considered preferable because of its proximity to the town centre. We would however contest the apparent negative comment in respect of the site being close to listed buildings and the

Ilfracombe (ILF H6)

Core Strategy Response

Section 3 3.1 Summary Landscape Assessment (See appendix 1 for full report) 3.3 Summary Highways/drainage Assessment Opportunities A green corridor running through the site would provide a strong visual link between Ilfracombe Existing Drainage Assessment harbour and the countryside to the south, as well as an opportunity for informal recreational The proposed site lies in-between existing residential areas located to the East of Ilfracombe. space. There is an existing public foul sewer in Worth Road bounding the west side of the site and Footpaths through the site could help to strengthen the pedestrian/cycle network through the also existing public combined sewers in Combe Park and Channel View roads to the north / town and to provide links to the college from Hele and the east of Ilfracombe. east of the site. The nearest point for a surface water discharge is in a watercourse some 100m Development within this site could help to knit together the eastern and western parts of the to the north east of the site via Combe Park and New Road. The Environment town, while still providing a green link through the built up area of Ilfracombe. Agency flood mapping indicates that there is no reported flooding in the area of the site. However, there could be localised problems on site due to ground water as there are a number Constraints of springs in the area. There is the opportunity to provide surface water drainage via Combe Any development would have to respect the existing developed skyline,. Park and Upper Larston Field into an oversized sewer. The green link running through the site ought to be maintained. Development patterns will need to be sensitive to the steeply sloping nature of the site, Existing Highways/Access Assessment (see appendix 3 for full report) perhaps reflecting the pattern of terraced housing with road below and tree planting above that This review (appendix 3) has shown that the site has good access to the local highways can be seen in neighbouring developments. network, with two major A-roads serving the town, and is also ideally positioned for all day-to- The existing mature hedgebanks are a dominant landscape feature on the site and as such day requirements, with a school and the town centre in very close proximity. These factors ought to be maintained. make this site highly suitable for residential development.

Recommendations 3.5 Summary Sustainability Appraisal (see appendix 4 for sustainability matrices) • Retain a green corridor, visible from the AONB, forming a visual link between open countryside to the south and the wooded slopes above the harbour to the north. Key Strategic Sustainability • Retain and manage the existing hedgerows through the site. On the basis of our appraisal using the joint NDDC/TDC SA Framework and given the context • Replicate the dominant development pattern locally through use of landform and of the site options for Ilfracombe it is considered that site ILF H6, Worth Meadows should be vegetation. preferred sequentially to H1, H2, H7 and H8 on the basis of the likely adverse impact these • Development to sit below the existing skyline sites would have in terms of key strategic sustainability issues. H1, and H7 are in the AONB and H2, H7 and H8 do not relate well to the existing settlement pattern. 3.2 Summary Ecological Assessment (see appendix 2 for full report) All fields are semi-improved pasture of low ecological value. Hedges are relatively species- Project Level Sustainability poor, but may be used by dormice. Midas Homes estimates that 250 units could be delivered at an average density of 35 houses per hectare and that an appropriate level of affordable housing could be achieved. It is Two badger setts located on site boundary - see attached map for locations. Both setts could considered that the site offers good access to employment, service and leisure opportunities by be left in situ with protected corridors allowing movement to open farmland beyond. No walking, cycling or public transport and without putting critical pressure on the existing highway developemnt within 15m of each location. network.

ASSESSMENT : AS A MATTER OF BEST PRACTICE RECOMMEND BAT SURVEY DURING We would, however, contest the apparent negative comment in respect of the site being close 2008. Badger survey required between January and March 2008 to confirm presence and to listed buildings and the conservation area. Whilst this statement may be correct in plan status of setts. Dormouse survey of hedges required between April and October 2008 to view, in terms of direct links and inter visibility this statement is not correct. The sloping nature determine presence/absence of dormice. of the site is identified in the Issues and Options Paper as a potential problem for drainage and it is noted that this is also the case for H3, H4 and H5. It is recognised that this issue would The presence of bats, dormice and badgers will not prevent development, but may require on need to be addressed but does not represent a strategic sustainability reason for eliminating site mitigation measures - such as protection of site boundaries, additional planting along these the site at this stage. Equally, the potential visual and biodiversity impact would need to be boundaries, use of low wattage lighting along flight corridors. addressed through the protection of site boundaries, additional planting along these boundaries and sensitive lighting.

Ilfracombe (ILF H6)

Core Strategy Response

Section 4 4.1Development Options Summary of Proposal Site H1 Development to follow the contours of the land, with a visible green corridor retained through Area considered suitable for development: 7.14 Ha = 250 residential units, @ 35 per Hectare the site. Enhanced parking and turning areas for college incorporated

Ilfracombe (ILF H6)

Core Strategy Response

Section 4 4.2 Access/ Highways / Drainage Foul Sewer. South West Water have been consulted with regard to allowable discharge to the nearby public sewers and have indicated that permission to discharge foul flows into these would be granted. 4.3 Deliverability We are confident that there are no insurmountable drainage problems that prevent Midas Homes have an option on this land. This means that the land is available and development of this site. Prior to any application being submitted, mapping and modelling of deliverable for a residential led scheme as soon as planning permission is granted. the existing system by South West Water will be required to ascertain if capacity exists or if upgrading is required It therefore represents a significant growth option for Ilfracombe, which can be delivered in the Due to the steeply sloping site, a gravity sewer system could be provided for most or all of the short to medium term. site. Depending on the final discharge / connection point to the main sewer and existing depths of the sewer, a pump station and rising main may be required to provide the final discharge into For the reasons set out in this report it is considered to represent an excellent opportunity to the public sewer. help meet the growth requirements of Ilfracombe in a controlled and sustainable manner.

Surface Water Sewer. The site is surrounded by existing development on three sides (Ilfracombe College, a holiday We propose that surface water drainage is dealt with via Combe Park and Upper Larston Field park and residential), and it is a natural area where the development boundary can be ‘rounded into the oversized sewer , installed in this location during the Clean Sweep works. off’. The proposal is a natural addition to the Ilfracombe community, which can benefit and enhance the existing infrastructure provision, for example by providing much needed affordable Highways housing, enhancing the existing College parking arrangements and extending the footpath The proposed development site at Ilfracombe provides an excellent opportunity to rationalise and network. improve the existing facilities outside the school and make them work better in terms of safety and capacity. Whilst the access to the site and the potential layout is complicated by the existing It also has excellent accessibility to the existing town centre and community facilities due to it topography and limited access it is considered that working within the contours a fully structured location affectively within the existing settlement area. Therefore, increasing the likelihood of and integrated road network can be provided. Pedestrian and cycle connections can also be people living and working within the Ilfracombe area and thereby offering excellent accommodated at a number of points from the site in other directions in line with guidance set sustainability credentials. out in Manual for Streets. Off site impact of the development is not likely to be significant due to the relative self containment of the town. However initial observations indicate that there are The relatively steep nature of the site means that careful design is required to minimise the use options to improve areas where congestion may occur without adversely affecting the highway of visual retaining walls and maximise the benefits of views, while retaining the a green corridor safety and capacity of the specific junctions. though the site. Access to this site will be from two new junctions on Worth Road, one to the north of the road, and one to the south of the road. These junctions will be connected by an internal road, which As an award winning south west company Midas Homes are very familiar with the development will be directed eastward, away from Worth Road, before connecting within the site. of steep sites and how to produce high quality developments on them. Accordingly, this is not There are also plans for an enhanced staff parking and coach turning point area on Worth considered to be a constraint, but an opportunity to provide a sensitive and desirable solution. Road for the college, which will be located between the two access points. The development is likely to increase traffic flow around the town, but not significantly so. Off site It is therefore concluded that this proposal should be taken forward as a preferred option for the highway works may be required to mitigate the impact, but these are not anticipated to be growth of Ilfracombe in the short to medium term significant, and initial observations indicate that potential improvements can be achieved

Ilfracombe (ILF H6)

Core Strategy Response

Visual Analysis Appendix 1 Worth Meadows sits below the skyline of Ilfracombe and is backed by skyline development Landscape Assessment – Undertaken by David Wilson Partnership (John Fowler Holiday development, Ilfracombe College and housing on Worth road and Queens Avenue). Location The site is prominent when viewed from parts of the AONB to the east, although the site is The site covers an area of 8 Ha. Located on the east of the town. (location drawing). bounded by development on three sides. The site contains a visual green link between open countryside to the south and the wooded slopes above Ilfracombe harbour, effectively splitting Description the town when viewed from the AONB. The site is steeply sloping grassland, predominantly facing east and north. The site is However, the lower parts of the large southern field are effectively screened from the north by surrounded to the east and north by residential development and to the east by Ilfracombe mature hedgerows, the view of the upper part of the combe is foreshortened when viewed from Community College. To the south is open countryside. the AONB and the whole site is backed by skyline development.

Landscape Character Opportunities The area is within the North Devon High Coast landscape character area, as defined in the A green corridor running through the site would provide a strong visual link between Ilfracombe North Devon AONB Landscape Appraisal (1999). This landscape type encompasses dramatic harbour and the countryside to the south, as well as an opportunity for informal recreational cliff scenery, steep sided combes and open, coastal farmland, all of which are visible from the space. site. The site itself is coastal farmland, with grazing and mature hedgerows subdividing it into 4 Footpaths through the site could help to strengthen the pedestrian/cycle network through the small fields. town and to provide links to the college from Hele and the east of Ilfracombe. Development within this site could help to knit together the eastern and western parts of the Landscape Designations town, while still providing a green link through the built up area of Ilfracombe. Worth Meadows is in the North Devon Coastal Preservation Area. It is, however, highly visible (as is the rest of Ilfracombe) from the North Devon AONB, parts of the North Devon Heritage Constraints Coast, the and the Hillsborough Local Nature Reserve. Although the Any development would have to respect the existing developed skyline,. site is contiguous with the Ilfracombe Conservation Area, due to the topography of the town, The green link running through the site ought to be maintained. there is little visual relationship with the Conservation Area. Development patterns will need to be sensitive to the steeply sloping nature of the site, perhaps reflecting the pattern of terraced housing with road below and tree planting above that Land Use, Landform and Vegetation can be seen in neighbouring developments. The site is currently used for grazing. There is an informal path running across the site, used by The existing mature hedgebanks are a dominant landscape feature on the site and as such students from the community college through an arrangement with the landowner. ought to be maintained. The whole site slopes steeply away from Worth Road on the upslope boundary. The southern part comprises a steeply sloping combe, divide between 2 fields, that runs away to the north Recommendations east. The rest of the combe, outside the site boundary, is already developed for housing. The • Retain a green corridor, visible from the AONB, forming a visual link between open central field forms a narrow, east to north facing strip, protected bounded on the down slope countryside to the south and the wooded slopes above the harbour to the north. side by dense vegetation. The northern field is a north facing slope, with long views overlooking • Retain and manage the existing hedgerows through the site. the sea and the edge of Ilfracombe harbour. • Replicate the dominant development pattern locally through use of landform and The downslope boundary of the whole site comprises dense hedgerow with mature trees. vegetation. There are extensive areas of gorse and bramble scrub to the hedgerows on the north and • Development to sit below the existing skyline central sections of the site. Three mature hedgebanks run east to west, dissecting the site. These hedgebanks form the dominant landscape features within the site. The western boundary, along Worth Road, is bounded by post and wire fencing.

Ilfracombe (ILF H6)

Core Strategy Response

Ilfracombe (ILF H6)

Core Strategy Response

Landscape & Visual Analysis

Ilfracombe (ILF H6)

Core Strategy Response

Appendix 2 Ecological Assessment – Prepared By Ambios Ecology • An internal inspection of the building(s) is also undertaken. This starts on the ground floor and involves a careful examination of door and window frames and lintels, wall voids and 1.0 INTRODUCTION similar cavities. Floors and other surfaces are checked for bat droppings. The survey is then Ambios Ecology LLP was commissioned by Midas Homes to conduct a baseline ecological extended to the upper floor where the same checks are made - though in addition wall tops and assessment of land at Worth Meadows, Ilfracombe, Devon. An assessment was required to roof void structures (such as ridge boards and other timbers) are also examined. identify any ecological impacts that might arise as a result of development of the site for • If these inspections do not provide enough information to make a reasoned judgment on the housing. value of the building(s) to bats, an evening survey to identify bats leaving the building(s) may also be undertaken; though this work is limited to the breeding season only (between May and Dr David Fee, a Managing Partner of Ambios Ecology, undertook an initial site survey on the September in any year). 27th of November 2007. At this time all land was checked for the presence of species and habitats of significant ecological value. Badgers Badgers and their setts are protected under the Protection of Badgers Act 1992. The field 2.0 SURVEY RATIONALE AND METHODS survey is used to search for badger setts, using the following methods: The assessment rationale adopted for this survey is based upon the ‘Guidelines for Ecological Impact Assessment in the ’ (Institute of Ecology and Environmental • The development area is walked and the ground checked for the presence of badgers’ setts. Management, 2006). A baseline ecological assessment is used to identify, quantify and • If evidence of badgers (e.g. runs, hairs and dung pits) is found around the site boundary, and evaluate the potential impacts of defined actions on ecosystems or their components. Further access is possible, the survey is extended off site for a distance of at least 30 metres. information on the general survey rationale is provided in the appendices. • Any badger sets found within this search area are assessed for their likely ‘status’ (i.e. main sett or other). The method of assessment involves a field survey of the development area. The information obtained from the field survey allows an assessment of the likely impacts of the proposed work This level of survey is deemed adequate in relation to most development schemes, as it on the ecology of the following: identifies setts that may be directly affected by the works (i.e. setts located on the development site itself), as well as setts that might be prone to disturbance (i.e. within 30 metres of the Ecologically important habitats development boundary). These habitats are identified on the ground and, where necessary, may be confirmed by means of a data search with the local Biological Records Centre. They include Special Areas Invasive species of Conservation (SAC’s), Sites of Special Scientific Interest (SSSI), County Wildlife Sites The field survey includes a check for invasive species, particularly Japanese knotweed, (CWS), Potential County Wildlife Sites (pCWS), Regionally Important Geological and Himalayan balsam and giant hogweed, for which legislation and/or specific guidelines apply Geomorphological Sites (RIGS), Ancient Woodland Inventory Sites (AWI) and Culm Grassland prior to excavation of the soil in which they are found. Sites (CGS). The presence of plant species of significant nature conservation value Specially protected animal species Such plant species are most likely to be associated with the ecologically important habitats These include all species listed under Schedule 5 of the Wildlife and Countryside Act 1981, identified by the fieldwork. such as dormice, otters, and bats. Habitat features likely to be of value to these species are also identified during the field survey. Presence of nesting birds During the breeding season (generally agreed to be between the 1st of March and 31st of July Where an internal inspection of buildings is required to determine the presence/absence of for most species likely to be encountered in such habitats), information on nesting birds is bats, the following methods are used: gathered wherever possible.

• The building(s) are assessed externally for signs of bats. Cracks in walls are examined (N.B. Cirl buntings are found in some parts of Devon and Cornwall, especially along the with use of a torch, and potentially access points (such as gaps under fascias, around southern coastal strip between and Warren. This species is a high chimneys and ridge tiles) are viewed with binoculars. Any direct signs (such as droppings conservation priority in the UK, and can continue to breed into early September in any year. stuck to walls) as well as features of potential value to bats are noted. Particular attention is paid to identifying potential impacts on this species where work is planned in cirl bunting areas during the breeding season).

Ilfracombe (ILF H6)

Core Strategy Response

General habitat value Biological value of hedgerows Of the habitats present on site the hedgerows and few mature trees are likely to be of some The biological value of hedgerows are assessed as part of the survey (using criteria from the value to local wildlife; in particular, some trees are mature enough to be of potential value to Hedgerow Survey Handbook, Second Edition, DEFRA, 2007). General recommendations for roosting bats. With the exception of these features however, the site comprises intensively working through hedges are also provided in Section 3.3. farmed land that is relatively isolated from semi-natural habitats in the local area. As such it is unlikely to be of significant ecological value at either the National or County level. Ecological value of water features All rivers, streams and smaller watercourses are assessed for their overall ecological value (N.B. The potential presence of specially protected animal species cannot be discounted at the during the survey. time of reporting, and as a result the above assessment will need to be conformed by further appropriate survey work. This is described in the relevant sections below).

3.0 SURVEY FINDINGS Nesting birds It is almost certain that birds will use hedges and trees for nesting during the breeding season General description (i.e between the 1st of march and 31st August inclusive). The site comprises open farmland on the eastern edge of Ilfracombe, Devon (site centre SS524471), as shown in Figure 1 below. The location of the site means that no cirl buntings are likely to be found on site.

Schedule 5 animal species

Dormice The hedgerows on site may provide suitable habitat for dormice, as:

• A large area of broadleaved woodland is found c. 1km to the southeast of the site • This woodland has continuous links to hedges on the eastern side of the site • Internal hedges are continuous and appear to provide reasonably good-quality habitat for dormice

Bats Some of the mature trees on site may provide opportunities for roosting bats, and hedges may provide ‘flight-lines’ for commuting bats.

Reptiles No evidence of reptiles was found on site at the time of survey, though this would not be expected during November. The few areas of rough grassland found on site are however Figure 1 – Worth Meadows site, with survey area outlined in red unlikely to support reptile populations – they are limited in area (generally around some of the field margins) and are isolated from other semi-natural habitats such as scrub, heathland etc. The site consists of four fields of semi-improved pasture separated by mature hedges. A number of mature trees are found within these hedges, and all fields appear to be grazed by Hedgerows cattle. None of the hedgerows are botanically rich enough to currently be classed as ‘Biologically Important’ under the 1997 Hedgerows Regulations; though the possible presence of dormice Existing urban development is found to the north, east and west of the site, whilst other pasture means that all hedges may qualify due the presence of this specially protected animal. This fields lie to the south. can only be confirmed by further survey work.

The site is shown in photographs at the end of this report (see Appendix 4).

Ilfracombe (ILF H6)

Core Strategy Response

Trees A number of mature trees are found on site, though it is assumed that these will remain 4.0 MITIGATION RECOMMENDATIONS unaffected by any development. Many are likely to have cracks and other features that could be used by roosting bats and/or nesting birds. Habitats Of the habitats present on site the hedgerows and few mature trees are likely to be of most Tree Preservation Orders (T.P.O.’s) are likely to apply to many of these trees. value to local wildlife.

Water features These habitats may provide habitat suitable for bats (either for roosting in individual trees or as No water features are found on site. flight-lines between feeding areas and roosts). Any development on site has the potential to both directly damage presently unknown bat roosts (when trees are felled) and/or disrupt bat Badgers movements in the local area (by removal of hedges and/or the erection of street lighting). Two active badgers’ setts were found during the survey, as shown in Figure 2 below. Felling of mature trees and/or hedgerow removal must not be undertaken without due consideration of the potential impacts on roosting bats and/or nesting birds. Please refer to the relevant sections below for details of the mitigation required.

Nesting Birds A number of bird species are likely to breed in suitable habitats (trees and hedges) on site. It is an offence to damage or destroy the nest of any wild bird, and to disturb birds whilst nesting. Any clearance of vegetation or tree felling should therefore be undertaken between mid-August and late February, i.e. outside the main nesting season. If this is not possible Ambios Ecology should be contacted for further advice. (N.B. Please note that trees may be used by bats throughout the year, and so no tree felling should be undertaken until this potential has been assessed).

Schedule 5 animal species

Dormice The hedges on site appear to offer potentially suitable habitat for dormice. As such it should be assumed that dormice are present, unless this can be proved otherwise by further, appropriate survey work. (N.B. Recent changes to the Habitats Regulations 1994 have meant the removal Figure 2 – Location of badgers’ setts (shown by solid red and blue squares) of the ‘incidental result defence’, which covers acts which are an incidental result of a lawful activity and which could not reasonably have been avoided. This means that the strict liability • Sett 1 (red square) has at least 3 active entrance holes, though more are likely to be offence of damaging or destroying a breeding site or resting place for all European protected present (dense vegetation hindered an accurate count at the time of survey). species (EPS) will no longer be subject to a defence. As such, the level of proof required to confirm the absence of an EPS on site has been increased – i.e. the survey process cannot be • Sett 2 (blue square) has at least 2 active entrance holes, though more are likely to be eliminated solely on the grounds that the habitat appears to be generally unsuitable). present (dense vegetation hindered an accurate count at the time of survey). It is therefore recommended that a further dormouse survey be carried out on site during 2008. Invasive species This survey should use the standardised ‘tube’ methodology in all hedges, and will need to run No evidence of Japanese knotweed, Himalayan balsam or giant hogweed was found on site at from April 2008 onwards. (N.B. Please note that the survey may need to run until October the time of survey - though it should be noted that some forms of Japanese knotweed are 2008; as it is only once a full survey season has been completed, with no dormice being found, difficult to identify, particularly during winter months (when dormant) or when obscured by taller that the site can be deemed ‘clear’ of dormice). vegetation.

Ilfracombe (ILF H6)

Core Strategy Response

The survey results should be used to determine what (if any) mitigation is required as part of the proposed development. BIBLIOGRAPHY

Bats Batten, L. A., Bibby, C. J., Clement, P., Elliott, G. D. and Porter, R. F. (eds.) (1990) Red Data The exact nature of bat activity on site is not known at the time of reporting, though potential Birds in Britain. Poyser. impacts on bat populations may arise from tree felling and/or disruption of flight-lines. Institute of Environmental Assessment. (1995) Guidelines for Baseline Ecological It is recommended that a bat survey of the site be undertaken between April and June 2008 to Assessment. Chapman and Hall, London. assess general flight activity across the site, as well as identify the presence of roosts within trees. This survey should be undertaken following ‘best practice’ provided in Bat Conservation Nature Conservancy Council (1990) Handbook for Phase 1 Habitat Survey. Field Trust’s Bat Surveys – Good Practice Guidelines (BCT, 2007). Unit, NCC.

The survey results should be used to determine what (if any) mitigation is required as part of RSPB (1996) Birds of Conservation Concern in the UK, Channel Islands and Isle of Man. the proposed development. RSPB, Sandy.

Hedgerows Stace, C. (1997) New Flora of the British Isles (2nd. edition). Cambridge University Press, Whilst none of the hedges currently qualify as Biologically Important under the 1997 Cambridge. Hedgerows Regulations, the possible presence of dormice means that this can only be confirmed once a dormouse survey has been completed (see above for further information). Treweek, J. (1999) Ecological Impact Assessment. Blackwell, Oxford.

Trees No trees should be felled without due regard for the possible presence of bats and/or nesting birds. Please refer to relevant sections above for proposed mitigation.

As T.P.O.’s are likely to apply to the site, no trees should be felled without consultation with the relevant local Planning Authority.

Badgers Both of the badgers’ setts identified during the survey lie on the outer edges of any proposed development area. Whilst no direct impacts on the badgers’ setts are therefore likely to arise as a result of development, the setts will ultimately be enclosed by new housing on land that is currently pasture and is likely to be used by the badgers for foraging. Loss of foraging land and a modification of current badger movements in the area is therefore likely to have some impacts on the badgers; though this could not be quantified at the time of reporting.

Given the current lack of information on badger activity in the area, it is recommended that a badger survey be undertaken between January and March 2008. The survey results should be used to determine what (if any) mitigation is required as part of the proposed development.

Invasive species Whilst no evidence of Japanese knotweed was found during the survey, it is recommended that an additional search be made for this plant during the growing season (i.e. between June and September), when it is more easily seen amongst other vegetation.

Ilfracombe (ILF H6)

Core Strategy Response

Appendix 2 – ecological Assessment (continued)

APPENDIX 2.1 APPENDIX 2.3 Consultation Criteria warranting Phase 2 survey Further survey work may be necessary if the baseline Consultation with relevant nature conservation bodies helps to define the likely ecological assessment identifies impacts on the following: impacts of the proposed development. Reference is made to relevant published information, such as the Ancient Woodland Inventory and the Invertebrate Site Register. Both statutory and non-statutory sites of nature conservation interest likely to be directly or indirectly affected by Species and/or populations the development are also identified. Rare species/populations (at national, regional or local level). APPENDIX 2.2 Species/populations important in the functioning of an ecosystem. Field survey

A field survey is used to produce maps showing habitats likely to be affected by the or development.

The field surveyor will specifically identify: Sites

• The presence of plant species of significant nature conservation value. Sites of national, regional or local importance (as defined by Ratcliffe’s 1977 Nature • General habitat value. Conservation Review criteria). • Presence of nesting birds. Largely undisturbed semi-natural habitat (e.g. ancient woodland). • The presence of animal species listed under Schedule 5 of the Wildlife and Countryside Act 1981, or habitat features likely to be of value to such species. • The biological value of hedgerows and subsequent identification of those sections requiring and notification under the 1997 Hedgerows Regulations. • Ecological value of water features. • Badger (Meles meles) activity within the survey area. Aspects of biodiversity that cannot easily be replaced • The presence of invasive species, particularly Japanese knotweed, Himalayan balsam and giant hogweed, for which legislation and specific guidelines apply prior to site development. Ancient semi-natural habitats. Ancient trees.

Ilfracombe (ILF H6)

Core Strategy Response

Appendix 2 – ecological Assessment (continued) APPENDIX 2.4 – SITE PHOTOGRAPHS

View across site from southern boundary looking north View of typical hedge (across center of site)

Ilfracombe (ILF H6)

Core Strategy Response

Appendix 3 Highways Assessment (Peter Brett Associates) requirement for journeys within Ilfracombe, however if a journey needed to be made outside of Ilfracombe is the largest town on the North Devon coast, with a scenic coastline, and a small the town, then there is excellent access to the A361 and the A399 for cars. These roads harbour, just 950m north of the site. It has a good size town centre with plenty of shops, provide direct access to a significant section of north Devon, as well as the M5, additionally restaurants and facilities. The town is also steeped in history, with grand Victorian villas and there is a comprehensive bus schedule from the town centre as detailed below: centuries of heritage and style, combined with the obvious nautical and fishing background. Ilfracombe also boasts beautiful countryside, and is close to , accessible via the A399. Table 2: Bus services

The Roger Tym and Partners “Functional Analysis of Settlement” identifies Ilfracombe as an Ilfracombe Bus station, Broad St - 850m north “other Significant Town” with a high level of self containment and as such it falls within RSS Route Operator Days Frequency Destination Policy B which requires that the scale of development at towns should be dependent on their no. function. 3 First Mon - Sat Hourly Barnstaple (hospital) – Western only Combe Martin The site is located south east of Ilfracombe town centre, bounded to the west by Worth Road, National which is a local distributor road that provides excellent access to the town centre and the south 3A First Mon - Sat Half hourly Barnstaple – Ilfracombe of the town. Small residential roads Warfield Villas, and Combe Park bound the site to the Western only north, and to the east. The site is positioned adjacent to Ilfracombe College, and the town National centre, providing all essential day to day services and infrastructure, is just a short walk away, 3B First Mon - Sat Hourly Ilfracombe – Mullacot Cross – down the hill. Western only Lee Cross – Mortehoe - National Woolacombe There are a number of excellent facilities in Ilfracombe, and the new Landmark Theatre & 3C First Mon – Fri School run Combe Martin – Barnstaple Pavilion, and harbour development has complimented the existing attractions. Below is a list of Western only only (North Devon College) some of the more important, regular-use facilities, which are all within walking and cycling National distance of the site: 30 First Mon - Sat Half hourly Combe Martin – Barnstaple Western only Schools National - Nursery - Toad Hall day nursery, Apsley Terrace - 480m west 33 Filers, Mon - Sat 3 journeys Ilfracombe – Berrynarbor - Primary - Ilfracombe Church of England Junior School, Princess Avenue - 400m west Ilfracombe only - Secondary and tertiary education - Ilfracombe College, Worth Road – 50m west. 34 Filers, Mon – Fri 2 journeys Ilfracombe Town Centre – Leisure Ilfracombe only The Shields - Ilfracombe bowling club, Highfield Rd, - 400m west 35 Filers, Mon - Fri; 3 journeys Ilfracombe – Slade – - Southcombes leisure centre, High St - 680m north-west Ilfracombe Saturdays 2 journeys Lincombe cross – Lee- Lee - Ilfracombe Swimming Pool, Larkstone Gardens - 1050m north-east Bay 36 Filers, Fridays only 2 journeys Circular town route, Health Ilfracombe Ilfracombe service only - Ilfracombe & District Tyrrell Hospital, St. Brannocks Park Rd – 1010m west 300 Quantock, Summer – 3 journeys Lynmouth – – - The Dental Surgery, Marlborough Rd - 900m west Filers daily Barbrook – Blackmoor Gate – - The Warwick Practice Medical Centre, St. Brannocks Rd - 1.3km west Combe Martin – Watermouth Winter – 2 journeys – Hele – Ilfracombe - Retail, job centre and prospective employment on the high street - approx 650m north- Sat and Sun west. X12 Spearings, Mon – Fri School run Ilfracombe – Braunton – only only Barnstaple. – – Given Ilfracombe’s high level of self-containment, these facilities would provide the majority of Tiverton the residents needs, and are all easily accessible from the site. The use of a car would not be a T5 Turners Wednesdays 1 journey Ilfracombe – Berrynarbor – - Free tours, only Combe Martin – Shirwell –

Ilfracombe (ILF H6)

Core Strategy Response

Travel Chumleigh Barnstaple (Tesco)

This review has shown that the site has good access to the local highways network, with two major A-roads serving the town, and is also ideally positioned for all day-to-day requirements, with a school and the town centre in very close proximity. These factors make this site highly suitable for residential development.

Ilfracombe (ILF H6)

Core Strategy Response

Appendix 4 accessibility by walking and cycling to existing Sustainability Matrices – Prepared by Tom Jones residents. Worth Meadows (Land East of Worth Road), ILF H6 2.1d loss/gain of pedestrian No loss of facilities. See High Level Objective 1: Create communities that meet people’s needs and cycle routes and open 2.1c 1.1 Provide suitable 1.1a Number of dwellings 250 units could be delivered spaces housing that meets the completed annually during the Plan period High Level Objective 3: Promote sustainable economic growth needs of the population and 1.1b Number of affordable The appropriate level of 3.1 Reduce unemployment 3.1a Unemployment rates Would provide homes near maximise affordable dwellings completed affordable housing could be levels and income to employment, a key DPD housing annually delivered. inequality Objective. 1.2 Reduce crime and the 1.2a Overall crime rates No known problems. 3.1b Indices of deprivation No impact. fear of crime 3.1c GVA per head Would provide homes near 1.3 Create and sustain 1.3a % of development on Not pdl. to employment, a key DPD vibrant towns and villages previously developed land Objective. 1.3b % of completed retail, Housing offers the 3.2 Diversify the range of 3.2a Number of VAT Would provide homes office and leisure strongest option to balance local employment registered businesses adjacent to employment, a development or number of the need to travel. opportunities key DPD Objective. applications approved NDDC/TDC have indicated 3.2b New firms: registration Would provide homes potential for other sites to adjacent to employment, a meet needs. key DPD Objective. 1.4 Improve access to key 1.4a % of new development Residents could access 3.2c Number of applications Not relevant services, employment within 1km of main employment opportunities for the change of use of areas and facilities for all employment areas or good by walking, cycling or public buildings in the countryside sectors of the community public transport links transport and without 3.2d Number of Not relevant putting additional pressure applications for farm on the existing highway diversification schemes network. 3.3 Promote sustainable 3.3a Number of tourists and Not relevant 1.4b % of urban and rural Residents could access tourism value of expenditure residential population within services by walking, cycling 3.3b Number of Not relevant walking distance of key or public transport and applications granted for the services without exceeding the change of use of buildings carrying capacity of the to holiday units existing highway network. High Level Objective 4: Provide access and secure a shift toward more sustainable 1.5 Provide access to 1.5a Qualifications of Not relevant forms of transport learning, training, skills and working age population 4.1 Reduce the overall 4.1a % of new development Good knowledge for everyone 1.5b % of people aged 16- Not relevant need to travel by car within walking and cycling 74 with no qualifications distance of retail and leisure 1.6 Reduce poverty and 1.6a % of households with Not relevant facilities deprivation <£15,000 income 4.1b % of new development Ilfracombe Town Centre High Level Objective 2: Health and Well-Being within 30 minutes public accessible within 30 2.1 Improve health of 2.1a Life expectancy Good access to leisure and transport (including walking minutes using the existing population and reduce open space. and cycling) time of a GP, public transport system. health inequalities 2.1b % of people who Good access to leisure and hospital, primary and Development could describe their health as open space. secondary school, enhance the viability of good or not good employment and a major public transport. 2.1c loss/gain of sports and Development could health centre recreational facilities enhance recreation 4.2 Make public transport, 4.2a % travel to work by Walking, cycling and public provision and improve mode transport would be options.

Ilfracombe (ILF H6)

Core Strategy Response

used to recover heat, power or other energy sources 4.2c Number of applications Could be delivered. 5.6 Minimise light and noise 5.6a % principal road Subject to the detailed including improvements to pollution network covered by low project plan and design. walking and /or cycle route noise surfaces network 5.6b New developments Subject to the detailed High Level Objective 5: Safeguard environmental quality and assets conforming to Institute of project plan. 5.1 Protect and enhance 5.1a Number, area and No harm. Opportunity to Light Engineers Dark Skies biodiversity and important condition of designated provide new or enhance Guidance wildlife habitats areas existing habitat. High Level Objective 6: Use of natural resources 5.1b Change in priority No harm. Some hedgerows 6.1 Reduce non-renewable 6.1a Energy consumption Subject to the detailed habitats and species (by may require protection. energy consumption and project plan. type) and change in areas greenhouse gas emissions 6.1b Emissions of Subject to the detailed designated for their intrinsic district wide greenhouse gases by project plan. environmental value sector and per capita including sites of (tonnes per year) international, national, 6.1c Mix of RE installed by Subject to the detailed regional, subregional or type (%) project plan. local significance 6.1d District wide installed Subject to the detailed 5.2 Protect and enhance 5.2a Extent of ‘good’ quality No loss of 1, 2 or 3a. RE capacity (MWe) project plan. the countryside, natural agricultural land used for 6.1e Number of applications Subject to the detailed landscape and townscape development for RE installations project plan. 5.2b % of new development Not pdl. 6.2 Improve energy 6.2a New buildings using Subject to the detailed and converted buildings on efficiency and use of sustainably sourced project plan. previously developed land sustainable construction materials (total number of 5.2c Area of Greenfield land The site is not within a materials %) allocated for new landscape designation. 6.3 Maintain and enhance 6.3a Levels of main air The site is not within an development air quality pollutants AQMA and there are no 5.3 Maintain and enhance 5.3a Number of listed Close to listed buildings, but predicted incidences of heritage assets and their buildings at risk adverse impact not likely. exceedance during the plan settings 5.3b Number of Close to conservation area, period. conservation areas but adverse impact not 6.4 Protect the quality of 6.4a Watercourses See 5.4b likely. local water resources classified as good or fair 5.4 Reduce the impact of 5.4a Number of planning Not a flood risk zone, but biological quality flooding and avoid applications granted steeply sloping with 6.4b Watercourses See 5.4b additional risk of flooding contrary to advice from the drainage issues. classified as good or fair Environment Agency on chemical quality either flood defence 6.5 Protect high grade soils 6.5a Area of BMV No loss of 1, 2 or 3a. grounds or water quality agricultural land lost to 5.4b % of new development Some sustainable water development with sustainable drainage management features will installed be possible. 5.5 Reduce the amount of 5.5a % of municipal waste Subject to the detailed landfill waste and promote generated disposed to project plan and design. recycling and the use of landfill recycled goods 5.5b kg of household waste Subject to the detailed collected project plan and design. 5.5c amount of waste Subject to the detailed recycled, composted or project plan and design.