SCOTT WILSON
Habitat Regulations Assessment of the St. Helens
Submission Stage Core Strategy
Final report
April 2009
Scott Wilson Ltd. We work with clients to develop, implement and evaluate projects, programmes and change initiatives to improve performance and reduce risk.
Habitat Regulations Assessment (HRA) of the St. Helens Submission Stage Core Strategy
Final Report
Prepared by: Dr. James Riley Scott D. Johnson Senior Ecological Consultant Environmental Specialist
Updated by: Dr. Graeme Down Ecological Consultant
Checked and Dr. James Riley Reviewed by: Senior Ecological Consultant Approved by: Dr. Jo Hughes Associate Director (Ecology)
Scott Wilson Scott House Alencon Link Basingstoke RG21 7PP
Tel: +44 (0)1256 310200 Fax: +44 (0)1256 310201 Email: [email protected]
HRA of the St. Helens Submission Stage Core Strategy Final Report
TABLE OF CONTENTS
1TU UT INTRODUCTIONTU UT ...... 3
1.1TU UT BACKGROUNDTU UT...... 3
1.2TU UT AATU AND THE ST. HELENS COUNCIL LDFUT ...... 4
1.3TU UT THISTU REPORTUT ...... 5
METHODOLOGYTU UT ...... 6
1.4TU UT KEYTU PRINCIPLESUT ...... 6
1.5TU UT LIKELYTU SIGNIFICANT EFFECTSUT ...... 8
1.6TU UT APPROPRIATETU ASSESSMENT (TASKS 2 AND 3)UT ...... 14
1.7TU UT CONSULTATIONTU ON THE PREFERRED OPTIONS AA REPORTUT ...... 14
2TU UT SCREENINGTU OF SUBMISSION CORE STRATEGY POLICIESUT ...... 15
3TU UT EUROPEANTU SITES AND PATHWAYS COVERED BY THIS HRAUT ...... 38
3.2TU UT LIVERPOOLTU BAY PSPA / PRAMSAR SITEUT ...... 39
3.3TU UT MANCHESTERTU MOSSES SACUT ...... 42
3.4TU UT MARTINTU MERE SPA / RAMSAR SITEUT ...... 43
3.5TU UT MERSEYTU ESTUARY SPA / RAMSAR SITEUT ...... 45
3.6TU UT MERSEYTU NARROWS & NORTH WIRRAL FORESHORE PSPA / PRAMSAR SITEUT 48
3.7TU UT RIBBLETU AND ALT ESTUARIES SPA / RAMSAR SITEUT ...... 51
3.8TU UT RIXTONTU CLAY PITS SACUT ...... 53
3.9TU UT SEFTONTU COAST SACUT ...... 55
3.10TU UT RIVERTU DEE AND BALA LAKE SACUT ...... 57
3.11TU UT THETU DEE ESTUARY SAC, SPA & RAMSAR SITEUT ...... 58
3.12TU UT RECREATIONALTU DISTURBANCE AS A PATHWAYUT ...... 61
3.13TU UT WATERTU FLOWS AND QUALITY AS A PATHWAYUT ...... 64
3.14TU UT WATERTU ABSTRACTION AS A PATHWAYUT ...... 66
3.15TU UT AIRTU QUALITY AS A PATHWAYUT ...... 67
3.16TU UT PATHWAYSTU LINKING MINERALS DEVELOPMENT WITH EUROPEAN SITESUT ...... 71
4TU UT APPROPRIATETU ASSESSMENT OF SUBMISSION CORE STRATEGYUT ...... 73
4.2TU UT LIVERPOOLTU BAY PSPA / PRAMSAR SITEUT ...... 73
4.3TU UT MANCHESTERTU MOSSES SACUT ...... 77
4.4TU UT MERSEYTU ESTUARY SPA / RAMSAR SITEUT ...... 82
4.5TU UT MERSEYTU NARROWS & NORTH WIRRAL FORESHORE PSPA / PRAMSAR SITEUT 87
4.6TU UT RIBBLETU AND ALT ESTUARIES SPA / RAMSAR SITEUT ...... 88
4.7TU UT RIVERTU DEE & LAKE BALA SAC / DEE ESTUARY SAC SPA & RAMSAR SITEUT ..... 90
4.8TU UT CONCLUSIONTU UT ...... 93
APPENDIXTU 1 – REFERENCESUT ...... 95
APPENDIXTU 2 – ‘TIERING’ IN APPROPRIATE ASSESSMENTUT ...... 99
APPENDIXTU 3 – MAP OF ST. HELENS AND THE EUROPEAN SITES
CONSIDEREDUT ...... 100
APPENDIXTU 4 – QUALIFYING SPECIES WITHIN ST. HELENS AS A POTENTIAL
PATHWAYUT ...... 102
APPENDIXTU 5 – THE CATCHMENTS OF THE SANKEY BROOK AND MERSEY
ESTUARIESUT ...... 107
APPENDIXTU 6 – SCREENING SUMMARY TABLEUT ...... 110
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APPENDIXTU 7 – EC ADVICE ON AA MITIGATION MEASURESUT ...... 120
APPENDIXTU 8 - NATURAL ENGLAND CONSULTATION RESPONSE REGARDING
THE HRA OF THE PREFERRED OPTIONS CORE STRATEGYUT 121
LIST OF TABLES AND FIGURES
TABLETU 1. KEY PRINCIPLES UNDERPINNING THE PROPOSED METHODOLOGYUT ...... 6
TABLETU 2. HOUSING TO BE DELIVERED WITHIN MERSEYSIDE UNDER THE NORTH
WEST RSSUT ...... 10
TABLETU 3:UT OTHERTU KEY PLANS AND PROJECTSUT ...... 11
TABLETU 4:UT POLICIESTU WITHIN THE SUBMISSION STAGE CORE STRATEGYUT ...... 16
TABLETU 5:UT ATMOSPHERICTU NITROGEN DEPOSITION FOR 1999/2000 COMPARED
WITH CRITICAL LOAD AT HOLCROFT MOSS*UT ...... 69
TABLETU 6:UT ATMOSPHERICTU SULPHUR DIOXIDE CONCENTRATIONS FOR 1999/2000
COMPARED WITH CRITICAL LOAD AT HOLCROFT MOSS*UT ...... 69
FIGURETU 1:UT FOUR-STAGETU APPROACH TO APPROPRIATE ASSESSMENTUT...... 8
FIGURETU 2:UT WATERTU QUALITY IMPROVEMENTS ACROSS THE MERSEY CATCHMENT
FROM 1985 TO 2001UT ...... 46
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1 INTRODUCTION 1.1 Background
1.1.1 Scott Wilson was appointed by St. Helens Council in 2007 to assist the Council in undertaking a Habitat Regulations Assessment (HRA) of the potential effects of the Core Strategy on European sites (i.e. Natura 2000 sites) as required by the Conservation (Natural Habitats &c) Regulations 1994 (as amended 2007). Planning Policy Statement 9 (PPS9), entitled Biodiversity and Geological Conservation (ODPM, 2005) advises that potential SPAs (pSPAs), candidate SACs (cSACs) and Ramsar sites should be treated in the same way as approved SPAs and SACs. It should therefore be noted that for the purposes of this assessment, the term “European sites” has been employed, which includes cSACs, pSPAs and Ramsar sites (including potential Ramsar – pRamsar – sites).
1.1.2 The Habitats Directive applies the precautionary principle to protected areas; 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. This is in stark contrast to the SEA Directive which does not prescribe how plan or programme proponents should respond to the findings of an environmental assessment; it simply says that the assessment findings (as documented in the ‘environmental report’) should be ‘taken into account’ during preparation of the plan or programme. In the case of the Habitats Directive, plans and projects 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 will be necessary to ensure the overall integrity of the site network.
1.1.3 The need for Habitat Regulations Assessment is set out within Article 6 of the EC Habitats Directive 1992, and interpreted into British law by Regulation 48 of the Conservation (Natural Habitats &c) Regulations 1994 (as amended in 2007) (Box 1). The ultimate aim of HRA 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.
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Box 1. The legislative basis for Habitat Regulations Assessment
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 (Natural Habitats &c. Regulations) 1994 (as amended)
Regulation 48 states 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”.
1.2 AA and the St. Helens Council LDF
2 1.2.1 Draft UK guidance on Appropriate AssessmentP P identifies Regional Spatial Strategies (RSSs), Local Development Documents (LDDs), and alterations or replacement of ‘old style’ plans as requiring HRA (to be taken at least through the screening stage). The St. Helens LDF is currently proposing 10 LDDs – 3 Development Plan Documents (DPDs) and 9 Supplementary Planning Documents 1 (SPD)TPF F.PT The purpose of HRA is to first identify any European sites upon which any of the LDDs is considered likely to have a significant impact (called ‘screening’), whether alone or in combination with other plans or projects, and then to ensure that the implementation of policy within those LDDs will not lead to adverse effects on those European sites.
1.2.2 While there are no European sites actually within St. Helens, the Borough is situated amongst European sites of far-ranging size to the north, south, east and west.
1.2.3 The Core Strategy Development Plan Document (DPD) is the principal planning document of the LDF, providing a policy framework by which future planning applications within St. Helens will be considered (up to 2025), and including a clear spatial vision and strategy for St. Helens.
1.2.4 Scott Wilson has undertaken several iterations of HRA covering both screening (Likely Significant Effects) and Appropriate Assessment stages relating to the Core Strategy Preferred Options. Natural England was consulted on both of these reports and confirmed that they were satisfied with the assessment (Natural England’s response to the Preferred Options HRA is contained in Appendix 8 for reference). As part of their consultation response they asked for water resource
1 TP PT CLG (2006) Planning for the Protection of European Sites, Consultation Paper
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issues relating to Wales to be included, and that topic is therefore included within the scope of this document.
1.2.5 Numerous changes have been made to the Core Strategy between Preferred Options and Submission stage and in order to ensure that the HRA remains relevant to the Core Strategy these changes must themselves be subject to HRA. In order to maintain clarity with reporting it has been decided that rather than insert the assessment of the changes as an addendum to the previous HRA report the entire report should be recast to cover the Submission stage Core Strategy. 1.3 This Report
1.3.1 This report documents the Appropriate Assessment of the St. Helens Submission stage Core Strategy, providing the information and conclusions regarding the Nature 2000 sites that were subject to assessment, the detailed assessment of the relevant Core Strategy policies and any associated recommendations.
1.3.2 The methodology that was adopted for the study is described in Section 2. The principal changes to create the Submission Stage Core Strategy are then listed and each policy subject to brief screening in Section 3. Section 4 discusses the interest features and vulnerabilities of each European site covered by this report. Section 5 then presents the Appropriate Assessment of the Submission Stage Core Strategy, including a consideration of the extent to which mitigation and avoidance measures recommended at the Preferred Options stage have been incorporated into the Core Strategy or otherwise acted upon by the Council.
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METHODOLOGY 1.4 Key Principles
1.4.1 This section sets out the basis of the methodology for the Habitat Regulations Assessment
1.4.2 Scott Wilson has adhered to several key principles in developing the methodology – see Table 1.
Table 1. Key principles underpinning the proposed methodology Principle Rationale Use existing information We used existing information to inform the assessment. This included information gathered as part of the SA of the emerging LDF and information held by Natural England, the Environment Agency and others. Consult with Natural We ensured continued consultation with both Natural England and England and the the Environment Agency during the course of the HRA process that Environment Agency has informed this ultimate report. We have ensured that we utilise information held by them and others and take on board their comments on the assessment process and findings. Ensure a proportionate We have ensured that the level of detail addressed in the assessment assessment reflects the level of detail in the Core Strategy (i.e. that the assessment is proportionate). With this in mind, the assessment focuses on information and impacts considered appropriate to the local level. Keep the process simple We have endeavoured to keep the process as simple as possible as possible while ensuring an objective and rigorous assessment in compliance with the Habitats Directive and emerging best practice. Ensure a clear audit trail We have ensured that the HRA process and findings are clearly documented in order to ensure a clearly discernible audit trail.
1.4.3 It should be noted that the practice of applying HRA to the Local Development Framework is still developing and this HRA is being carried out in the absence of formal Government guidance. We understand from discussions with the Department for Communities and Local Government (CLG) that the forthcoming official Government guidance is likely to be an elaboration of the CLG consultation 2 paper on AATPF FPT. The approach that has been followed therefore reflects a combination of current HRA practice, the draft guidance as provided by CLG and emerging ideas and experience as to how HRA should best be applied to plans.
1.4.4 The essential elements of the methodology follow those adopted for the HRA of other land use plans, including the North West RSS. The level of detail of the assessment, whilst meeting the relevant requirements of the Habitats Regulations, should be ‘appropriate’ to the level of plan or project that it addresses (see Appendix 2 for a summary of this ‘tiering’ of assessment).
1.4.5 Two methodological aspects have considerable bearing on HRA results: firstly, the conclusions that HRAs reach about likely impacts on European sites and, secondly,
2 TP PT CLG (2006) Planning for the Protection of European Sites, Consultation Paper.
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the avoidance / mitigation measures they suggest. A key issue is whether the HRA has a plan focus or a European site focus. The former approach disregards those elements of a plan that are unlikely to affect European site integrity and then considers any remaining impacts ‘in combination’ with other plans, projects etc. The latter first identifies the environmental conditions or factors necessary to maintain the integrity of European sites and then considers whether the plan ‘in combination’ could affect these. The former approach is typically more restrictive in its scope and less likely to cover indirect impacts; the latter approach would cover such impacts.
1.4.6 Second is whether the focus of HRA avoidance / mitigation measures is on the environmental conditions needed to maintain site integrity (e.g. the water levels necessary to ensure the site’s viability) or on adding caveats to plan policies (e.g. ‘...unless the policy would have a significant effect on the integrity of a European site’). The former approach is more precautionary, and aims to deal with potential problems at the highest plan-making stage possible. The latter approach is much easier to apply, but essentially devolves the potentially problematic decision to lower levels, when more information (e.g. about development location and design) is available.
1.4.7 Early experience with HRA of LDFs and RSS’s suggests that 1) a European site based approach, and 2) avoidance / mitigation measures focused on the environmental conditions needed to maintain site integrity are probably more in keeping with the spirit of the Habitats Directive and less likely to lead to legal challenge. This has been the broad approach taken for the North East, South West and East Midlands RSSs, the HRA assessment of the South East RSS and various HRA’s for Local Development Frameworks.
1.4.8 Figure 1 below outlines the stages of Appropriate Assessment 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 likelihood of significant adverse effects is demonstrated to remain.
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Evidence Gathering – collecting information on relevant European sites, their conservation objectives and characteristics and other plans or projects.
AA Task 1: Likely significant effects (‘screening’) – identifying whether a plan is ‘likely to have a significant effect’ on a European site
AA 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 AA Task 1
AA Task 3: Mitigation measures and alternative solutions – where adverse effects are identified at AA Task 2, the plan should be altered until adverse effects are cancelled out fully
Figure 1: Four-Stage Approach to Appropriate Assessment Source: DCLG, 2006
1.5 Likely Significant Effects
Develop a ‘long list’ of European sites
1.5.1 One of the first necessary steps for Evidence Gathering is to develop a ‘long list’ of European sites potentially affected by the plan. Current guidance suggests that the following European sites be included in the long list:
• sites within the authority’s boundary; • sites shown to be linked to development within the authority’s boundary through a known ‘pathway’ (discussed below); and • sites recommended by a formal screening opinion by Natural England (Scott Wilson et al., 2006).
1.5.2 Briefly defined, pathways are routes by which a change in activity within St. Helens could result in an effect upon a European site. In terms of this third category of European site listed above, CLG guidance states that the AA should be ‘proportionate to the geographical scope of the [plan policy]’ (DCLG, 2006, p.6).
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Establishing the evidence base
1.5.3 The purpose of this initial stage is to set out details of European interest features within the context of the conservation objectives for sites. In order to be able to determine whether the DPD may possibly impact upon European sites, it is essential to understand the environmental process that, if altered in some way, could potentially result in a significant adverse effect on the interest features of the European site and thereby, the achievement of a site’s conservation objectives.
1.5.4 Information available from the websites of Natural England, Joint Nature Conservation Committee and Countryside Council for Wales provides a good introduction to the reasons for the designation of the European sites.
1.5.5 This is supplemented by information gained during direct telephone/email consultation with the relevant agencies, notably Natural England and the Council, but also including the Environment Agency. Natural England and the Environment Agency hold information on the condition of European sites and are able to provide an indication of any environmental or existing activities that are influencing the condition of the site.
Gain an appropriate understanding of the Core Strategy
1.5.6 Relevant activities from within the Core Strategy have been extracted in order to establish the changes potentially caused by the Core Strategy that need to be assessed. All policies have been considered both on their individual merit (i.e. what they are trying to achieve) and with relation to the other policies that are to be material considerations for all planning applications. It has been considered how achievement of policy objectives might alter the natural environment in order to determine which policies are relevant to the potential pathways for effects upon European sites identified.
Identify any potential pathways by which impacts associated with the LDF might affect European sites
1.5.7 Without European sites within the boundaries of St. Helens Borough, AA Task 1 has been focused upon the way in which policies governing development in St. Helens could indirectly affect European sites. Any relevant pathways by which potential impacts of the LDF might affect European sites have been identified. Briefly defined, pathways are routes by which a change in activity within St. Helens could result in an effect upon a European site. For example, a pathway could be air (e.g. transmission of gaseous or particulate pollution) or watercourses (e.g. waterborne pollution).
1.5.8 In terms of relevance, the approach has been realistic and practical, and therefore ecological expertise has been employed in order to focus only on pathways that are verifiable as important links between land use and development in St. Helens and European sites.
Confirming other plans and projects that may act in combination
1.5.9 It is neither practical nor necessary to assess the ‘in combination’ effects of the Core Strategy within the context of all other plans and projects within Merseyside or
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the North West. In practice, in combination assessment is of greatest relevance when the plan would otherwise be screened out because its individual contribution is inconsequential. For the purposes of this assessment, we have determined that, due to the nature of the identified impacts, the key other plans and projects relate to the additional housing and commercial/industrial allocations proposed for other Merseyside authorities over the lifetime of the Core Strategy. The North West RSS provides a good introduction to proposals for areas surrounding St Helens.
Table 2. Housing to be delivered within Merseyside under the North West RSS Local Authority Annual housing Total housing from 2003 to 2021 average Merseyside 4,470 80,460 Liverpool 1,950 35,100 Knowsley 450 8,100 Halton 500 9,000 St Helens 570 10,260 Wirral 500 9,000 Sefton 500 9,000
1.5.10 With regard to the specific issue of water resources, the long distance transfer pathways that exist for the supply of water to the Merseyside area and the fact that these same pathways or water sources also supply parts of North Wales, the West Midlands, Manchester, Cumbria and Cheshire, means that development across a much broader area is required for the consideration of water resource impacts ‘in combination’, as follows:
• North East Wales – specific housing levels to be delivered are not mentioned in the Wales Spatial Plan or its 2008 update but a significant increase is likely; • Greater Manchester area – 185,800 homes to be delivered across Manchester, Salford, Oldham, Rochdale, Tameside, Stockport, Trafford, Congleton, Macclesfield, Bolton, Bury and Wigan between 2003 and 2021 • West Midlands – potentially up to 445,600 additional homes across the region until 2026 • West Cumbria – 11,640 homes to be delivered across Allderdale, Barrow-in- Furness and Copeland between 2003 and 2021; and • Cheshire – 31,800 homes to be delivered across Crewe & Nantwich, Chester, Ellesmere Port & Neston and Vale Royal between 2003 and 2021.
1.5.11 Table 3 below outlines the plans and projects that have been identified as relevant to the pathways that may cause effects upon European sites from the St. Helens Core Strategy and that have been reviewed to inform this assessment. Where necessary the development identified within these documents is referred to later in the HRA. These documents include those that are considered likely to influence surface water dynamics or quality within the Sankey Brook catchment, those considered likely to influence traffic along the M62 east of St. Helens, and those considered likely to influence the overall increase in population and thus recreational pressure on surrounding European sites.
1.5.12 This list has been updated to include projects and plans that have emerged since the original HRA. It should be noted that many of these plans and projects (such as most of the relevant LDF Core Strategies) are only at early stages of development and therefore have been of limited practical use in assessment.
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Table 3: Other Key Plans and Projects Plan / Project Relevance The North West Plan: Submitted Draft Regional Spatial Strategy (RSS) Sets out the regional housing, employment and other (2009) and associated Habitats development allocations for the entire North West Regulations Assessments The West Midlands RSS (2008; Sets out the regional housing, employment and other changes relating to Phase 2 are development allocations for the entire West Midlands – since currently undergoing Examination in the West Midlands obtains some of its potable water from Public) and associated Habitat the same sources as St Helens, this information is therefore Regulations Assessments relevant Sets out the regional housing, employment and other The Wales Spatial Plan (2008 development allocations for Wales – since parts of north update) east Wales obtain some of its potable water from the same sources as St Helens, this information is therefore relevant Draft West Cheshire and North East Sets out the sub-regional strategy to support the delivery of Wales Sub-Regional Spatial Strategy the four strategic centres of Chester, Wrexham, the Deeside (2007) conurbation and Ellesmere Port. Great Ormes Head to Formby Point Details the flood defence strategy relating to part of the Shoreline Management Plan Merseyside coast. Potentially relevant in terms of the effects of coastal squeeze on internationally designated sites Formby Point to River Wyre Shoreline Details the flood defence strategy relating to part of the Management Plan Merseyside coast. Potentially relevant in terms of the effects of coastal squeeze on internationally designated sites Gwynt Y Mor Offshore Windfarm Details of a major windfarm project that will be situated Project within Liverpool Bay and could result in adverse effects on the interest features of the pSPA on its own account Liverpool LDF Core Strategy Sets out the housing strategy for Liverpool; relevant in that it (Preferred Options, 2008) provides more detail to the RSS allocations Knowsley LDF Core Strategy (Plan Sets out the housing strategy for Knowsley; relevant in that it Knowsley stakeholder & community provides more detail to the RSS allocations workshops, 2008) Sefton LDF Core Strategy (Preferred Sets out the housing strategy for Sefton; relevant in that it Options emerging 2009) provides more detail to the RSS allocations Halton LDF Core Strategy (Issues & Sets out the housing strategy for Halton; relevant in that it Options 2006) provides more detail to the RSS allocations Wirral LDF Core Strategy (Initial Sets out the housing strategy for Wirral; relevant in that it Consultation, 2007) provides more detail to the RSS allocations Sets out the waste development strategy for Merseyside. Merseyside Joint Waste Development Would be relevant in terms of any cumulative impact arising Framework (Preferred Options due from waste development and LDF development arising on 2009) the same European sites Greater Manchester Joint Waste Sets out the waste development strategy for Greater Development Framework (initial work, Manchester. Would be relevant in terms of any cumulative the Stage 2 Issues & Options is not impact arising from waste development and LDF publically available at time of writing) development arising on the same European sites Blackbrook Diversion (A58 in St. Details a road scheme that will alter traffic patterns in St Helens) Helens Details a road scheme that has been submitted to the Secretary of State, with a Public Inquiry in May 2009 and The Mersey Gateway: Proposed 2nd could alter traffic patterns in Merseyside. However, the Mersey Crossing (Halton) Environmental Statement for the project has concluded that there will be no residual adverse effects of this project on the interest features of the Mersey Estuary SPA & Ramsar site.
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Plan / Project Relevance United Utilities revised draft Water Provides information concerning the future water supply Resource Management Plan (April strategy that United Utilities need to adopt for future supply 2009) of housing within their area Dee Catchment Abstraction Sets out the Environment Agency policy on abstraction and Management Strategy water resource management within the CAMS area
Sankey Glaze Catchment Abstraction Sets out the Environment Agency policy on abstraction and Management Strategy water resource management within the CAMS area
Dee Draft River Basin Management Sets out river management required to meet the needs of Plan (2008) the Water Framework Directive
North West River Basin Management Sets out river management required to meet the needs of Plan (2008) the Water Framework Directive
1.5.13 The Warrington Local Transport Plan (LTP) 2006 – 2011 was reviewed, and no policies were identified that would propose significant changes to the built environment in the western area of Warrington relevant to the Sankey Catchment, and thus to this Appropriate Assessment.
Evaluating Likely Significant Effects (Screening)
1.5.14 The first stage of any Habitat Regulations Assessment is a Likely Significant Effect test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:
1.5.15 ”Is the project, either alone or in combination with other relevant projects and plans, likely to result in a significant adverse effect upon European sites?”
1.5.16 If it can be demonstrated that significant effects are unlikely, no further assessment is required.
1.5.17 The objective of the screening assessment is to determine whether the impacts of the Core Strategy DPD upon the European site are likely to have a significant adverse effect upon that European site, or not. Individual policies/measures within the DPD are evaluated in detail against the sites conservation objectives, using the environmental conditions necessary to maintain the integrity of the European site in line with Habitats Directive requirements. We have utilised the precautionary principle in this assessment. In practice it means that the plan is never given the benefit of the doubt; it must be assumed that a policy/measure is likely to have an impact leading to a significant adverse effect upon a European site unless it can be clearly established otherwise.
1.5.18 ‘In combination’ is taken to refer to the sum of influences acting on sites from all plans and projects in the context of prevailing environmental conditions. The assessment process therefore takes account of reasonably foreseeable impacts arising from both plans and projects and ‘background’ environmental changes or trends (e.g. sea-level rise as a result of climate change).
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1.5.19 In evaluating significance, Scott Wilson have relied on our professional judgement as well as stakeholder consultation. We believe that we are in an excellent position to provide such expert judgement given our previous experience in undertaking AA.
1.5.20 The steps involved in screening are outlined below:
1. Gain a full understanding of the Core Strategy (including site allocations) and its Preferred Options.
2. Consider each policy/site allocation within the context of the environmental processes that support each European site – could the policy lead to an impact on any identified process? Could the site allocations influence whether a given policy will be likely to result in a significant adverse effect?
3. Consider the current trends in these environmental processes. For example, if a site is currently suffering from poor water quality this could increase the likelihood of a significant effect as a result of the DPD. If however, the interest features of the site are flourishing despite the poor water quality, this implies that water quality is not fundamental to the integrity of the site.
4. Decide if the identified impact is likely to lead to a significant effect.
5. Repeat for each policy and site allocation on each European site.
6. Identify other plans and projects that might affect these sites in combination with the Plan and decide whether there is likely to be a significant effect “in combination”.
Consultation
1.5.21 Information has been revised and refined as a result of liaison with the Council, Merseyside Environmental Advisory Service (MEAS) and Natural England. The Environment Agency has also been consulted during Evidence Gathering.
1.5.22 Consultation with the Environment Agency and Natural England has identified the desire to extend the existing Mersey Estuary SPA boundary upstream to the confluence of the Sankey Brook with the Mersey Estuary. This has not been formally proposed but should this arise in the lifespan of the LDDs, then the nearest point that this SPA will have with St. Helens will be approximately 2.6km as opposed to the current approximate 5.5km.
1.5.23 Natural England and the Environment Agency were consulted at earlier stages of the project on the conclusions of the screening exercise and our approach to the Appropriate Assessment, including all pathways considered appropriate to the St. Helens LDF. Since a screening exercise has already been undertaken in full on the Preferred Options Core Strategy it was considered unnecessary to repeat this exercise in full for the Submission Stage document. However, new policies or material changes to existing policies were of course subject to a short screening exercise in order to determine which required consideration in the Submission Stage Appropriate Assessment.
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1.6 Appropriate Assessment (Tasks 2 and 3)
1.6.1 Project-related Appropriate Assessment often requires bespoke survey work and novel data generation in order to accurately determine the significance of adverse effects. In other words, to look beyond the risk of an effect to a justified prediction of the actual likely effect and to the development of avoidance or mitigation measures.
1.6.2 With the majority of land-use plans, the level of detail concerning developments that will be permitted under the plan (and in some cases the sensitivities and vulnerabilities of the European site) is usually insufficient to make a detailed assessment of significance of effects practical or reasonable. For example, precise determination of the impacts and significant effects of an Energy from Waste Facility will require details concerning the design of the facility (e.g. the thermal treatment technology used, the exhaust stack height) as these will influence the chemical composition and dynamics of the emission plume and therefore the scale of pollutant deposition on a European site. Yet these data will often not be decided until the project stage.
1.6.3 Therefore, the “Appropriate Assessment” stage in practice requires a blurring of the distinction between the stages of screening and ‘full’ Appropriate Assessment as they exist for projects. As such we find it most productive to focus on the development of avoidance and mitigation measures at this stage, based on the 'risk' of a significant effect using existing data collated for the screening report.
1.6.4 The approach to AA Tasks 2 and 3 has been to take forward the results of AA Task 1 (‘screening’) in order to:
• identify any further information required regarding European sites, relevant policy or identified pathways in order to adequately assess Core Strategy policy; • assess in detail the potential significant adverse effects of policies within the Core Strategy DPD in accordance with expert knowledge and/or available guidance and legislation; and • where significant adverse effects are thought to remain as a result of policy in the Core Strategy (including in combination), identify any changes to policy (which may include amendment to, addition of or removal of policy) until no significant adverse effects are considered to remain.
1.6.5 Our approach towards recommending mitigation accords with guidance by the European Commission, which has outlined the tasks to be completed regarding mitigation measures at this point in the process (see Appendix 7). 1.7 Consultation on the Preferred Options AA Report
1.7.1 Natural England was consulted on the Preferred Options stage HRA report and confirmed that they were satisfied with the assessment (Appendix 8), although they asked for water resource issues relating to Wales to be included. This version of the report therefore includes the consideration of water resource issues relating to Wales.
Scott Wilson Ltd. 14 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
2 SCREENING OF SUBMISSION CORE STRATEGY POLICIES
2.1.1 In order to evaluate most potential impacts of the St. Helens Core Strategy upon European sites, even at the screening stage, a degree of quantitative and spatial specificity is required. Although a Site Allocations DPD and Development Control DPD are being developed they are not yet available and their assessment was not part of this commission.
2.1.2 The principal changes between the Preferred Options Core Strategy and Submission Stage Core Strategy are a shift in the quantum of housing to be delivered from 12,817 (between 2001 and 2024) to 14,528 dwellings (between 2003 and 2025), an increase in the quantum of employment land to be delivered from 71.5 ha to 88.5 ha and the insertion of explicit policies covering minerals and waste.
2.1.3 Table 4 lists the Core Strategy DPD policies. As can be seen from the below summary table, 11 draft policies have been scoped out altogether at initial appraisal as having no potential for adversely affecting European sites or because their impact of European sites would be likely to be positive. The remaining 11 policies were scoped in for further consideration within the context of the European sites around St Helens, largely due to their contribution to increasing the overall quantum of development. It should be noted that only policies that could result in an adverse effect are screened in for Appropriate Assessment. However, those policies that could have a beneficial effect are referred to at the relevant stages of the remainder of this document.
Scott Wilson Ltd. 15 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Table 4: Policies within the Submission Stage Core Strategy Policy Policies Summary Potential for adverse impact on European Reference sites? CSS1 Overall Spatial The regeneration of St. Helens to 2025 will be delivered Yes – since this policy sets out the overall spatial Strategy and supported through a Borough wide distribution of distribution of development development. Certain areas of the Borough will be the focus for delivery of the individual elements as follows:
I. over the plan period to 2025 the majority of new development will be directed towards the regional town of St.Helens. The remaining development requirements will be directed towards Newton-le-Willows and Earlestown, and Haydock and Blackbrook. II. three quarters (76%) of new residential development, including that element required for Growth Point, will be directed towards the regional town of St.Helens. The remainder will be directed towards Newton-le-Willows and Earlestown (15%), Haydock and Blackbrook (6%) and Rural St.Helens (3%) III. St.Helens Town Centre will maintain and protect its market share within the region by securing further retail and leisure development opportunities. IV. Earlestown will remain the second town centre within the Borough, whilst Rainhill and Thatto Heath will be classed as District Centres. The following will serve as local centres: Billinge; Chain Lane; Chancery Lane; Clipsey Lane; Eccleston; Fingerpost; Marshall’s Cross; Newton-le-Willows; Newtown; Rainford; Sutton; and Denton’s Green V. focusing economic development to the Southern Corridor in St.Helens and to the Industrial Estate in Haydock VI. maximising the reuse of previously developed land VII. supporting improvement programmes in the most deprived areas of the Borough, including Parr, Gerard's Lane, Peasley Cross, Four Acre,
Scott Wilson Ltd. 16 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Fingerpost, Portico and Wargrave VIII. the general extent of the Green Belt as indicated on the Core Strategy key diagram will be maintained in the short to medium term, however, the Green Belt will be subject to a sub-regional review in Merseyside to accommodate new development requirements arising through a review to Regional Spatial Strategy. IX. Within the Green Belt area, development will be restricted to within existing settlement boundaries or major developed sites in the Green Belt. X. An area based on the former Parkside Colliery to be removed from the Green Belt and allocated for a Strategic Rail Freight Interchange XI. Reserving an area of land to serve future economic development after 2012 CAS 1.1 St Helens Core Within the St. Helens Core Area new residential Yes – since this policy sets out the overall spatial Area Strategy development will be focused towards: distribution of development I. The two urban villages of Lea Green Colliery and Moss Nook; II. areas of deprivation, and, in particular, the neighbourhood renewal areas of Parr, Portico, Fingerpost, Four Acre, Gerards Lane and Peasley Cross; and III. elsewhere within the core area on suitable previously developed land. Economic development in St Helens Core Area will be concentrated on the Southern Corridor and will: IV. bring forward the early development of land with planning permission such as Lea Green Farm East and West; V. remove constraints to bring forward industrial sites for development, with initial attention focused on the Sutton area and Gerard's Bridge; and VI. improve the accessibility of economic areas from deprived communities.
Scott Wilson Ltd. 17 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? The Council will support service providers in St. Helens Core Area to: VII. improve accessibility to the redeveloped St.Helens Hospital and Whiston Hospital; VIII. facilitate the allocation and development of sites in accessible locations for improved health facilities in Eccleston, Sutton, Parr and Thatto Heath; and IX. implement the Building Schools for the Future programme, including the redevelopment of the Cowley School Campus. Green infrastructure, biodiversity, trees, and woodlands will be protected and enhanced. Furthermore opportunities will be pursued to: X. enhance the Sutton Brook; Ravenhead, Eccleston and Sankey Valley Park Greenways and linkages to them; XI. secure improvements to open spaces, provide children and youth play facilities, and attain Green Flag Status at Queens Park, Sherdley Park, Hardshaw Park and Victoria Park; and XII. restore and enhance Brickfield Quarries. Development will not prejudice and, where appropriate, will support objectives to protect and enhance the accessibility of the Borough through: XIII. protecting the route of a St. Helens Central to St. Helens Junction Rail Link; XIV. provision of a new station and park and ride facilities at Carr Mill; XV. provision of park and ride facilities at Lea Green and St. Helens Junction; and XVI. maintaining the effectiveness of the A570 Linkway and M62 J7 at Rainhill Stoops XVII. The District Centre of Thatto Heath and existing local centres will be protected and opportunities for the clustering of activities will be encouraged. CAS2 Town Centre The town centre is a distinct spatial area of St.Helens but Yes – since this policy sets out the overall spatial Scott Wilson Ltd. 18 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Strategy serves a wider sub regional role. Within St.Helens town distribution of development centre: i. The Council will work with the town centre partnership to enhance the town centre as an accessible and welcoming destination for shopping, leisure, culture, tourism, employment and housing with a high quality built environment and maintain its position in he regional hierarchy: 2 ii. 17000mP P (net) of additional comparison retail floorspace will be developed by: The redevelopment of the existing Tesco Superstore site at Chalon Way. The enhancement of the existing Church Square Shopping Centre. iii. Encouraging the development of previously developed land for mixed uses including high density residential and office development in and around the Town Centre. iv. Pursuing the regeneration of the town centre in partnership with the PCT to deliver new health facilities and housing v. Monitoring its vitality and viability though undertaking regular Town Centre Health Checks and appraisals of the Town Centre Conservation areas. vi. Defining the Town Centre functional boundary in accordance with PPS 6 following Linkway West and East, Atlas Street, Standish Street, Crab Street and between Kirkland Street and Lowe Street. viii. Defining the Primary Shopping area in accordance with PPS 6 covering the town centre from North of Chalon Way, South of Claughton St and East of King Street. ix. Securing opportunities to improve the town centres public realm by retaining and enhancing St Helens Canal and securing improvements to the town centres green infrastructure. x. Managing pedestrian and vehicular accessibility to meet the varying demands of the town centre by: Maintaining pedestrian priority within the Town Centre and extending links to adjacent growth areas. Scott Wilson Ltd. 19 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Supporting the Town Centre as the hub of the public transport network in St.Helens Reducing congestion and maintaining access by Managing the demand for long-stay car parking in accordance with the Proposed St.Helens Car Parking Strategy (Ref TP32 Appendix 2 ‘Bibliography’) CAS 3 Newton-Le- Newton-Le-Willows and Earlestown is a distinct spatial Yes – since this policy sets out the overall spatial Willows and area to the east of St Helens. Within Newton and distribution of development Earlestown: - Earlestown I. Residential development will be: Strategy Focused on the development of the Vulcan Urban Village; Elsewhere, it will take advantage of the availability of previously developed land. II. The main focus for industrial activity will continue to be the Sankey Valley and Deacon Trading Estates which will be safeguarded for this purpose. III. The function and role of Earlestown Centre as the second largest retail centre in the Borough will be safeguarded. IV. Planning policies will support the PCT and Education Authority in facilitating the allocation and development of a site in an accessible location for an improved health facility and supporting the Building Schools for the Future programme at the Newton Academy. V. Support will be maintained for the following accessibility objectives and development will be prevented from prejudicing the outcome wherever possible: Provision of park and ride, bus/rail facilities and station improvements at Newton-le-Willows Station, and the enhancement of Earlestown Station. Maintaining the effectiveness of the Freight Route Network including J23/M6 and ensuring access to local facilities by protecting and enhancing links to Earlestown Station, and developing initiatives to improve access to employment opportunities, such as those at Parkside.
Scott Wilson Ltd. 20 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? CAS 4 Haydock & Haydock and Blackbrook is a distinct linear spatial area tot Yes – since this policy sets out the overall spatial Blackbrook of St.Helens. Within Haydock and Blackbrook: distribution of development I. Residential development will take advantage of the Strategy supply of previously developed land within the urban area. II. Industrial development will continue to be focused on Haydock Industrial Estate, particularly on remaining sites, which are safeguarded for industrial and commercial purposes. III. The continued function of Clipsley Lane as a Local Centre will be supported and enhanced via appropriate development. Further analysis of this centre and its potential future role as a District Centre will be addressed though the Allocations DPD. IV. Support will be given to the PCT in facilitating the allocation and development of a site in an accessible location for an improved health facility. V. Support will be maintained for the following accessibility objectives and development will be prevented from prejudicing the outcome wherever possible: Maintaining the effectiveness of the Freight Route Network including J23/M6; and Initiatives to improve access to employment opportunities, such as those at Haydock Industrial Estate and Old Boston Trading Estate. VI. Green infrastructure, biodiversity and trees and woodlands will be protected and enhanced and opportunities will be pursued to upgrade Sankey Valley Park and other existing areas of open space. CAS 5 Rural St Helens The rural area of St. Helens is a distinct spatial area where Yes – since this policy sets out the overall spatial development and restriction need to happen alongside distribution of development each other to achieve its visions and objectives. Within Rural St.Helens: I. Development will be restricted to within existing rural settlement boundaries and within existing identified major
Scott Wilson Ltd. 21 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? developed sites. Outside of these areas development will comply with National, Regional and Local Green Belt and rural policies II. Housing growth will be sensitive to the local character and require a threshold for affordable housing of 3 dwellings in rural areas III. Positive opportunities for access, recreation and nature conservation will be maximised IV. Existing agricultural and forestry uses will be protected and supported V. Attractive rural landscapes will be protected and enhanced VI. Opportunities for economic regeneration and rural tourism through farm diversification where there is no significant impact upon the character of the area will be identified and encouraged. Industrial activity will be focused on existing industrial estates VII. Local services, shops and community facilities will be safeguarded and supported where they are providing a need. Opportunities to cluster services, shops and community facilities will be encouraged wherever possible VIII. Support will be maintained for the following accessibility objectives and development will be prevented from prejudicing the outcome wherever possible: Park and Ride at Garswood Improving access to employment areas in rural locations IX. Green infrastructure, biodiversity, trees, and woodlands will be protected and enhanced and opportunities will be pursued to: Improve the St Helens Forest Park on the southern edge of the Borough Improve the Stanley Bank, Carr Mill Dam and Billinge Hill Corridor Restore the former Lyme and Wood Pits between Haydock and Newton-le-Willows Scott Wilson Ltd. 22 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? CP1 Ensuring Quality All proposals for development within the Borough will be No - this policy controls and restricts development Development in expected, where appropriate, to meet the following rather than promoting it standards as a minimum. Development will: St Helens Quality of the Built Environment I. Maintain or enhance the overall character and appearance of the local environment (with regard to siting, layout, massing, scale, design, materials, building to plot ratio and landscaping). II. Safeguard and enhance the built environment, Listed Buildings and Conservation Areas. III. Be sympathetic to surrounding land uses and occupiers, avoiding detrimental impact on the amenities of the local area, in particular residential amenities. IV. Ensure that the amenities of occupiers of the new development will not be adversely affected by neighbouring uses. V. Link in with surrounding movement patterns and is not prejudicial to the development of neighbouring land, including the creation of landlocked sites. VI. Minimise opportunity for crime, ensuring, where possible, natural surveillance. VII. Provide landscaping as an integral part of the development, protecting existing landscape features, providing open space and enhancing the public realm. VIII. Include public art in appropriate circumstances. IX. Demonstrate, through the Design and Access Statement, the appropriateness of the proposal. X. Make provision for the needs of special groups in the community such as the elderly and those with disabilities. XI. Buildings for Life Protection of the Natural Environment XII. Safeguard and enhance green infrastructure, biodiversity and geodiversity. XIII. Avoid unnecessary tree loss and makes provision for new and replacement planting. Scott Wilson Ltd. 23 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? XIV. Take full account of archaeological remains and, where it is demonstrated preservation is not feasible, that adequate provision is made for their excavation and recording. XV. Safeguard or enhance landscape character. XVI. Minimise irreversible loss or damage to high quality soil resources. Environmental Quality XVII. Minimise and mitigate against the effects of air and water pollution, (including contamination of groundwater resources), noise, smells and fumes. XVIII. Ensure protection from and avoids any worsening of the risk of flooding, through the use of flood defences, SUDs and other appropriate measures. XIX. Ensure that the site of the proposed development is not contaminated or that provision can be made for its remediation to an appropriate standard taking into account its intended use and making use of sustainable remediation technologies XX. Include satisfactory arrangements for the disposal of foul sewage, liquid waste, trade effluent and contaminated surface water.
Resource Management XXI. Reduce waste production and promotes reuse and recycling. XXII. Minimise consumption of energy and incorporates renewable energy generation. XXIII. Use local and recycled building materials. XXIV. Adopt sustainable construction techniques (include Code for Sustainable Homes/eco-standards/lifetime standards), reducing energy consumption. XXV. Make efficient use of existing infrastructure and services and where practicable, avoids the need for new service investment. Scott Wilson Ltd. 24 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? XXVI. Avoid sterilisation of known mineral resources through development. XXVI. Does not prejudice the delivery/improvement of utility networks CP2 Creating an In order to provide a realistic choice of travel, including No – since this policy promotes sustainable Accessible St access for people with mobility difficulties, all proposals for transport which could have a beneficial effect on development within St. Helens will be expected to meet European sites Helens the following principles (1): Ensuring a choice in mode of travel by: I. Locating to sites where there is potential for users to walk or cycle to or from the site and/or the provision of cycle and walking facilities within the site, and/or the improvement of routes or facilities which serve the site; II. Locating to sites where there is good access to the public transport network and/or the provision of public transport facilities within the site and/or the improvement of public transport and facilities which serve the site; Ensuring access to local facilities by: III. protecting and enhancing safe and convenient pedestrian routes, including Safer Routes to School IV. protecting and enhancing links to, and growth of, the identified cycle network, including the extensions of the SUSTRANS National Cycle Network V. Public transport facilities Safe and adequate access to and from the public highway by: VI. the provision of adequate circulation within a site VII. The provision of on-site parking, which should not exceed the Council’s adopted maximum standards, unless it is proven to be essential to avoid highway danger; VIII. Parking for those of limited mobility, service vehicles, cycles and other motor vehicles, which should meet the Council’s minimum guidelines. IX. Allowing direct access onto the primary route network
Scott Wilson Ltd. 25 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? only where it does not restrict the capacity of the road or its intended purpose. Where a reasonable alternative exists, direct access will not be permitted. Any junction or capacity improvements shall be completed before the occupation of the development; Sustainable location of significant generators of journeys by: X. Locating within 800m of safe and convenient walking distances of stations on the passenger rail network; XI. Locating within 400m of safe and convenient walking distance of stops and interchanges on high-frequency bus service networks. XII. Ensuring development which generates significant movement of freight, is located on sites which are served by rail or where rail facilities can be provided as part of the development, or where these options are not available, locating where there is good access to a road designated as a Freight Priority Route. XIII. Submission of a Transport Assessment in accordance with the Transport SPD XIV. Preparation of a travel plan in accordance with the Transport SPD Reduce the adverse impacts of traffic on the community by: XV. improving safety and protecting the efficiency of routes by paying regard to the route and road user hierarchies adopted within the LTP XVI. supporting initiatives to reduce congestion, air pollution and noise on key routes. Support Local Transport Plan Priorities by ensuring development will not prejudice XVII. improved rail links to Manchester XVIII. improved rail capacity to Liverpool XIX. improved station accessibility CH1 Meeting St The housing requirement for the period 2003 to 2025 Yes – since this policy sets out the quantum of Scott Wilson Ltd. 26 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Helens Housing comprises 14,528 new dwellings. This will be achieved housing development in the borough Requirements through: I. Implementing the Mid Mersey New Growth Point and its Programme of Development II. Allocating land to meet the outstanding residual requirement for the period 2003-2020, and identifying land for the period 2020-2025. III. Delivering at least 80% of new dwellings on previously developed land. IV. Supporting the reuse and conversion of appropriate buildings for housing. V. Requiring developments to achieve densities in line with those set out in the North West Regional Spatial Strategy and encouraging higher densities in appropriate locations such as within and adjacent to St.Helens and Earlestown Town Centres and where well served by public transport. VI. Safeguarding the character of established residential areas from over-intensive new development. VII. Prioritising the development of previously developed land. However, where the development relates to a Greenfield site, development will be permitted where: - VIII. It forms a minor part of a larger development site and is essential to its successful delivery; or IX. It delivers an overriding significant social, economic and environmental benefit, and it complies with policies for the protection of green space; or X. The application is for a barn conversion and it can be demonstrated that the site has been marketed for economic use for 2 years and is not viable for these purposes. CH2 Meeting St A suitable mix of high quality housing will be provided to No – since this policy concerns the quality and type Helens Housing deliver sustainable communities in accordance with of housing rather than its quantum or location identified local needs. This will be delivered by: Need I. Meeting an overall affordable housing target of 30% of
Scott Wilson Ltd. 27 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? the total of all new residential developments. Each site accommodating 15 or more units in St Helens, Haydock, Newton and Earlestown, or 5 or more units in rural areas will be assessed individually and a flexible approach will be adopted to site negotiation taking account of economic viability and local housing mix. The starting point for negotiations will, however, be 30%. II. The provision of smaller units, including apartments and bungalows to meet the needs of an ageing population and smaller households. III. Planning for extra care and supported housing appropriate to local needs. IV. Higher value market housing to support economic development within the Housing Market Area. CH3 Gypsies, In order to meet the needs of Gypsies, Travellers and No – there is no mechanism by which this could Travellers & Travelling Showpeople identified in the North West RSS, lead to an adverse impact on European sites since planning applications for the development of sites for such this policy is concerned with providing appropriate Travelling accomodation in sustainable locations within the urban facilities for the existing gypsy and traveller Showpeople area will be granted provided that the following criteria are population rather than a net increase in the satisfied: population in the borough The development will: I. Have an acceptable impact on the environment or character of the area or existing surrounding uses, including maintenance and testing of equipment; II. Provide safe and convenient access to the road network and have an acceptable impact on road safety III. Make on site provision for parking, turning and servicing IV. Include adequate landscaping including screening to minimise the impact on surrounding uses; V. Be within a reasonable distance from schools, shops and other facilities and can be accessed by foot, cycle or public transport; VI. Not compromise the objectives of nationally designated sites.
Scott Wilson Ltd. 28 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Conditions and/or section 106 obligations will be used limiting the hours equipment can be tested and ensuring the long-term maintenance of landscaping. CE1A Economic Sufficient land and premises will be provided to strengthen Yes – since this policy sets out the quantum of Development and diversify the Boroughs economic base and support the economic development in the borough City Growth Strategy and other forms of development initiatives: -
I. The identification and allocation of at least 88.5 hectares of land for economic development for the period 2008 – 2025 (excluding Parkside) II. Supporting sites in the economic land supply being brought forward for development. Though marketing, securing of public funding and the production of development briefs. III. Resisting the loss of existing allocated employment land and premises to non B1, B2 or B8 uses unless the site: is vacant; has been adequately marketed for a minimum of 2 years; The site can be proven to be unviable; be demonstrated that there are no other alternative suitable sites in the Borough. IV. Encouraging the development of B1 office uses within and adjacent to St Helens Town Centre through the implementation of the East Side Masterplan and the development of site specific Development Briefs. V. Supporting the reuse of suitable buildings in rural areas for appropriate employment uses by favourably considering planning applications proposing rural economic development. VI. Supporting the protection, creation, enhancement and expansion of tourism resources and facilities. By favourably considering planning applications which, support the tourism strategy, Destination St Helens. CE1B Economic Sufficient land and premises will be provided to strengthen Yes – since this policy sets out the quantum of Development and diversify the Boroughs economic base and support the economic development in the borough Scott Wilson Ltd. 29 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? City Growth Strategy and other forms of development initiatives: - I. The identification and allocation of at least 88.5 hectares of land for economic development for the period 2008 – 2025 (excluding Parkside) II. Reserving an area of Green Belt land adjacent to a major employment area to meet the future needs of local economic development after 2012. III. Supporting sites in the economic land supply being brought forward for development. Though marketing, securing of public funding and the production of development briefs. IV. Resisting the loss of existing allocated employment land and premises to non B1, B2 or B8 uses unless the site: is vacant; has been adequately marketed for a minimum of 2 years; The site can be proven to be unviable; be demonstrated that there are no other alternative suitable sites in the Borough. V. Encouraging the development of B1 office uses within and adjacent to St Helens Town Centre through the implementation of the East Side Masterplan and the development of site specific Development Briefs. VI. Supporting the reuse of suitable buildings in rural areas for appropriate employment uses by favourably considering planning applications proposing rural economic development. VII. Supporting the protection, creation, enhancement and expansion of tourism resources and facilities. By favourably considering planning applications which, support the tourism strategy, Destination St Helens. Issue CAS Development of An area based on the former Parkside Colliery including Yes – since while the development under this 3.7A an Inter-Modal land to the west and east of the M6 Motorway with access policy could result in a reduction in freight transport to the West Coast main line and Trans Pennine rail route by road and therefore an improvement in air quality Freight Terminal will be shown diagrammatically on the Core Strategy it may also result in a net increase in traffic diagram for development as an inter-modal freight movement as it draws road freight into the site.
Scott Wilson Ltd. 30 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? terminal. The precise boundaries will be determined following consideration of a detailed scheme which will need to satisfy the requirements set out below. Subject to meeting these requirements the site will be removed from the green belt with the proviso that the site will only be developed as an inter-modal freight terminal and for no other forms of development: i. Compliance with criteria set out in Appendix RT5.1 of the Draft RSS. ii. Direct access to the site from the M6 for HGVs can be obtained avoiding use of the A49 and A573. iii. The ability of the local road network to accommodate traffic generated by the development without unacceptable impact on residential amenity and traffic flows. iv. That the character and amenity of the Newton High Street Conservation Area is safeguarded. v. No unacceptable noise impact on local residents from the development itself or associated road and rail access routes. vi. All uses within the site are served by rail or are ancillary to rail-based uses. vii. Impact on Green Belt and landscape character is mitigated by significant landscape enhancement including tree planting. viii. Measures for the remediation of contaminated land, minimisation of environmental impacts and contributions to sustainable development including waste management; energy generation by renewable means; energy efficiency; archaeology; agricultural land; air quality; biodiversity; water conservation and sustainable drainage; reuse of materials; access by public transport, cycle and foot. ix. Provision for the positive management of existing environmental assets. x. measures are in place to safeguard or relocate the Newton Park Farm Listed Buildings within the vicinity of Scott Wilson Ltd. 31 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Newton and preferably within the St Helens local authority area. xi. Training schemes will be put in place to increase the opportunity for the local population to obtain employment at the complex. CQL1 Green The Council will protect, develop, enhance and manage No – as there is no mechanism by which this policy Infrastructure the Green Infrastructure resource network within the could adversely affect European sites Borough by: I. Identifying and allocating sites as part of the Green Infrastructure network and categorizing different types II. Identifying and assessing Green Infrastructure sites requiring improvement III. Protecting existing green infrastructure sites from development and requiring new development, where appropriate to provide acceptable mitigation measures and/or compensatory extension to the Green Infrastructure network IV. Protecting sites that are identified within the St Helens Ecological Framework and encourage the extension of the identified spatial network V. Enhancing and utilising green infrastructure networks for biodiversity, geological conservation and as a recreational resource VI. Requiring new development to contribute to enhancing and/or creating new Green Infrastructure through planning obligations VII. Improving accessibility to existing green infrastructure and requiring new development, to contribute to the accessibility of additional Green Infrastructure VIII. Utilising Green Infrastructure for opportunities to mitigate against the impacts of extreme weather IX. Encouraging the intensification and diversification of appropriate functions of Green Infrastructure where applicable CQL2 Trees and The multi-purpose value of trees, woodlands and No – as there is no mechanism by which this policy Scott Wilson Ltd. 32 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? Woodlands hedgerows will be protected and enhanced by: could adversely affect European sites I. Requiring the planting of new trees, woodlands and hedgerows on appropriate development sites and elsewhere support new planting II. Conserving, enhancing and managing existing trees, woodlands and hedgerows through managing Tree Preservation Orders, Planning Conditions and Planning Obligations III. Ensuring that development does not damage or destroy any tree subjected to a Tree Preservation Order, any other protected tree, or any other tree of value, hedgerow unless it can be justified for good arboricultural reasons or there is a clearly demonstrated public benefit, which outweighs the value of the tree(s) and/or hedgerow(s) IV. Supporting proposals, which assist in the positive use of woodlands for green infrastructure purposes including recreation, education, health, biodiversity, geological conservation, tourism and economic regeneration V. Implementing the Town in the Forest Initiative and Mersey Forest CQL3 Biodiversity & The Council will protect and manage species and habitats, No – as there is no mechanism by which this policy Geological as well as enhancing and creating habitats and linkages could adversely affect European sites between them by: Conservation I. Identifying the location of sites of importance for biodiversity and geological conservation distinguishing between SSSIs, Local Nature Reserves, Ancient Woodlands, Local Wildlife Sites and Local Geology Sites on the Proposals Map II. Requiring that, where harm to protected species or habitats is unavoidable, suitable mitigation measures are implemented to enhance or recreate the features, either on or off site and bring sites into positive management III. Ensuring that any development affecting nationally and locally important sites and protected species will only be
Scott Wilson Ltd. 33 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? acceptable if there is clear evidence that the development outweighs the nature conservation interest IV. Reducing that habitat and species fragmentation by developing a functioning ecological framework for the Borough. V. Requiring all development proposals to be based on ecological site appraisals including where sites are derelict, vacant or previously developed land. Surveys must be undertaken at appropriate times of year for the relevant habitats, species, flora and fauna VI. Requiring developers, where appropriate, to incorporate habitat features, which will contribute to the Borough’s ecological and geological resource. VII. Ensuring the creation, extension and better management of Biodiversity Action Plan priority habitats, including the further designation of Local Nature Reserves. CQL4 Heritage & The Council will protect, conserve, preserve and enhance No – as there is no mechanism by which this policy Landscape St. Helens historic built environment and landscape could adversely affect European sites character by: I. Protecting landscape character as well as important urban open space from development which would harm these assets II. Enhancing the value of St Helens built environment and landscape character by implementing Conservation Area Action Plans and education, interpretation and public access measures III. Ensuring all new development respects the distinctive quality of the built environment and landscape character and is of a high standard of design, reinforcing St. Helens local distinctiveness IV. Ensuring that all development is located and designed in a way that is sensitive to its landscape setting and retains or enhances the landscape character CQL5 Social Social Infrastructure including health, education, local No – as this policy is concerned with providing Infrastructure retail, cultural and community facilities will be protected, services to residents rather than drawing people Scott Wilson Ltd. 34 April 2009
HRA of the St. Helens Submission Stage Core Strategy Final Report
Policy Policies Summary Potential for adverse impact on European Reference sites? provided and enhanced to support sustainable into the borough communities by: I. Protecting existing facilities from their loss, where there is an identified need II. Supporting improvements to primary and secondary school provision III. Safeguarding and allocating sites where there is an identified, planned provision IV. Where appropriate, secure developer contributions to enhance provision of social infrastructure V. Requiring new social infrastructure to be located in sustainable locations, and where possible be clustered with other facilities CR1 Minerals The Council will seek to achieve a steady and adequate Yes –minerals development can lead to adverse supply of minerals to ensure that the Borough contributes effects on European sites towards meeting the region’s identified needs. Proposals for extraction of minerals will be considered against national and regional guidance, together with criteria set out in the Development Management DPD, to ensure it would not be unacceptable in terms of impact on:
i. Dwellings or other environmentally sensitive uses; ii. The built or natural environment; or iii. The highway network.
Within the Mineral Safeguarding Areas (MSAs) at Bold Heath and Garswood, identified on the key diagram, planning permission will not be granted for any form of development that is incompatible with safeguarding the minerals, unless it can be demonstrated to the satisfaction of the LPA that: i. The mineral concerned is no longer of any value, potential value, or has already been fully extracted; or ii. The full extent of the mineral can be extracted satisfactorily prior to the incompatible development taking
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Policy Policies Summary Potential for adverse impact on European Reference sites? place; or iii. The incompatible development is of a temporary nature and can be completed, and the site restored to a condition that does not inhibit extraction, within the timescale that the mineral is likely to be needed; or iv. There is an overriding need for the incompatible development, that outweighs the need to avoid sterilisation of the mineral resources present; or v. That prior extraction of minerals is not feasible due to the depth of deposits or because mineral extraction would lead to, or exacerbate, ground stability problems; CR2 Waste The Council will promote sustainable waste management No – while waste development can lead to adverse in accordance with the waste hierarchy, work with other effects on European sites, there is a separate Joint Merseyside and Halton authorities (through the Merseyside Waste Development Framework and preparation of the Merseyside and Halton Joint Waste impacts of waste policy are therefore best Development Plan Document) to: addressed within the Habitat Regulations I. identify and safeguard (where appropriate) waste Assessment of that document. The St Helens management sites in appropriate locations; policy essentially merely indicates that the Council II. ensure that the Borough makes its contribution towards will work with other Merseyside authorities in meeting the identified sub-regional waste management developing the Waste Development Framework. needs; III. encourage good design in new development in order to minimise waste and promote the use of recycled materials, and to facilitate the collection and recycling of waste; IV. encourage the sustainable transport of waste and promote use of site waste management plans; and V. ensure that waste management facilities are developed whilst minimising the impacts on the environment and communities of the borough. CIN1 Meeting St The necessary Infrastructure required to meet St. Helens No – this policy is concerned with ensuring that Helens needs and to facilitate development will be met through the infrastructure is in place which will be integral to following: ensuring minimization of the risk of adverse effects Infrastructure i. Development being directed to locations that are already on European sites. Needs well served by infrastructure ii. The Council working jointly with infrastructure providers
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Policy Policies Summary Potential for adverse impact on European Reference sites? to continually identify and meet needs iii. Requiring developers to provide the necessary infrastructure that their development will require through: a. Providing on or off site provision of infrastructure; or b. Making payments through a tariff based system or through the Community Infrastructure Levy; iv. Ensuring that the LDF process and Infrastructure Providers service planning is aligned; v. Delivering the items in the Programme of Development for the Mid Mersey Growth Point; and vi. Supporting various development programmes for service providers in the Borough such as Building Schools for the Future, implementation of the Primary Capital Strategy and the Primary Care Trust Strategic Services Development Plan.
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3 EUROPEAN SITES AND PATHWAYS COVERED BY THIS HRA
3.1.1 The purpose of this chapter is to set out the details concerning interest features, current status and trends and vulnerabilities of the European sites covered in the Appropriate Assessment. Once each European site has been discussed, some of the most relevant pathways of impact are then discussed.
3.1.2 The designation of SPAs is legislated for by Article 4 of the Birds Directive (EC, 1979) in order to contribute towards ‘a framework for the conservation and management of, and human interactions with, wild birds in Europe’ (JNCC, 2006b). The designation of SACs is legislated for by Article 3 of the Habitats Directive (EC, 1992) in order to contribute towards a similar framework applying to the conservation and management of habitats and species of ‘European importance,’ accounting for ‘economic, social and cultural requirements and regional and local characteristics’ (JNCC, 2006c). Finally, Ramsar sites (as included in AA pursuant to PPS9 – see paragraph 1.2.2) are designated in conformance with Article 2 of the ‘Ramsar Convention’ (UN, 1975), the framework being for protecting wetlands, ‘the world’s most threatened ecosystems ‘ (JNCC, 2006a).
3.1.3 Conservation objectives attached to these European sites typically concern the preservation of those species and habitats for which they are designated, but may include other factors directly linked with their sustainability. This is particularly the case for SPAs and the Annex I birds for which they are designated through Article 4, as the conservation of the habitats of these birds is essential for the conservation of the species.
3.1.4 There are no European sites that fall within the St. Helens boundary. Ten European sites (including proposed sites and Ramsar sites) were considered within the scope of the HRA during screening. The English sites are:
• Liverpool Bay pSPA and pRamsar site, • Manchester Mosses SAC (including Astley & Bedford Mosses, Holcroft Moss and Risley Moss), • Martin Mere SPA and Ramsar site, • Mersey Estuary SPA and Ramsar site, • Mersey Narrows & North Wirral Foreshore pSPA and pRamsar site, • Ribble & Alt Estuaries SPA and Ramsar site, • Rixton Clay Pits SAC, and • Sefton Coast SAC.
3.1.5 In addition, the following Welsh sites have been scoped into the long list because, although St Helens is approximately 30km from the Welsh border, these sites are utilised by United Utilities to supply St Helens Borough with much of its current potable water supply or are otherwise connected:
• River Dee & Bala Lake SAC, as the River Dee is the current source of 75% of the water supplied to St Helens; and
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• The Dee Estuary SAC, since abstraction from the River Dee may have an 3 impact on flows into the estuaryTPF F PT
3.1.6 The map in Appendix 3 shows the St. Helens boundary and European sites considered in the original screening exercise for context. Note that the long list of European sites was reduced for the Appropriate Assessment of the Preferred Options Core Strategy. Specifically, the following sites were scoped out of further consideration for the reasons stated:
• Martin Mere SPA/Ramsar site - Despite the hydrological sensitivity of the site, there is no pathway by which water resource requirements of the Borough could lead to adverse effects upon the hydrology of the site. The only possible pathway for impacts upon this site from the St Helens LDF would therefore be as a result of the increased recreational pressure. However, recreational pressure at Martin Mere is controlled, as the site is a Wildfowl and Wetland Trust Reserve. The site is geared towards attracting visitors, with a number of hides from which the Mere and its birds may be viewed. As such, it was concluded that this particular site was not vulnerable. This view was confirmed by Natural England who stated that “Natural England does not consider increased recreational pressure on Martin Mere to be a current relevant environmental pressure for consideration by the AA for 4 St Helens LDF”TPF F.PT
• Rixton Clay Pits SAC - The Core Strategy was screened out as being unlikely to result in significant adverse effects on this site, as no pathways connecting the Core Strategy to this site have been identified.
5 • Sefton Coast SAC - Natural England’s viewTPF F PT was that recreational pressure is not a severe ecological issue with this site and that it is not likely to become one as a result of the St Helen’s LDF. No other pathways connecting Core Strategy preferred policy options to this site were identified.
3.1.7 The Summary Table in Appendix 6 provides a summary of the reasons for the designation of each European site that was scoped into assessment, its sensitivities, its management and environmental pressures or other relevant history, and its nature conservation objectives. The below subsections provide a more thorough description of these characteristics, concluded with a general description of the pathways for effects upon these sites from St. Helens, and a more thorough description of the Sankey catchment. The pathways are assessed for potential to lead to significant effects upon European sites in Chapter 5. 3.2 Liverpool Bay pSPA / pRamsar site
3.2.1 The Liverpool Bay pSPA and pRamsar site is proposed to be an approximately 198,000ha maritime site located in the Irish Sea, straddling the English and Welsh
3 TP PT Although a significant proportion (25%) of St Helens water supply comes from Lake Vyrnwy, this site is not identified on the Joint Nature Conservation Committee lists (as of 2008) as a Special Protection Area or Ramsar site. Although the Tanat & Vyrnwy Bat Sites SAC is contained within the JNCC lists, that site was designated for its greater horseshoe bat interest and there is no evidence of any pathway linking abstraction from Lake Vyrnwy to the bat populations of the SAC. 4 TP PT Mandy North, Natural England, letter of 24/01/07 to Scott Johnson, Scott Wilson Ltd 5 TP PT Mandy North, Natural England, letter of 24/01/07 to Scott Johnson, Scott Wilson Ltd
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borders. The site has exposed mudflats and sandbanks in places, although the site extends up to approximately 20km from the shoreline and thus most of the area of the pSPA/pRamsar site is relatively shallow water up to 20m deep. It is contiguous with a number of other European sites, including the Ribble and Alt Estuaries SPA and Ramsar site, Mersey Narrows and North Wirral Foreshore pSPA and pRamsar site, and Mersey Estuary SPA and Ramsar site.
Reasons for Designation and Nature Conservation Objectives
3.2.2 In 2004, a study team of the Joint Nature Conservation Committee (JNCC) (referred to in citation as ‘Webb et al.’) produced two reports on a potential Liverpool Bay SPA, the first on the recommendation for designation, and the second on boundary options. The former reported that ‘Liverpool Bay hosted populations of red-throated divers Gavia stellata and common scoter Melanitta nigra in numbers that exceeded thresholds that would qualify the site for SPA status’ (Webb et al., 2004b, p.2).
3.2.3 The report also mentions its potential qualification as a Ramsar site due to the large numbers of waterfowl supported (Criterion 5 regarding Article 2 of the Ramsar Convention).
3.2.4 Since the site is not yet an SPA, there are no nature conservation objectives provided at this stage, but they would likely be similar to those of other maritime and estuarine SPAs, particularly nearby sites such as the Mersey Estuary SPA. Such objectives are thus assumed to include:
• to prevent a significant reduction in numbers or displacement of all qualifying species of over-wintering birds from a reference level – these are:
– red-throated diver Gavia stellata: 1,405 wintering individuals = 28.7% of the GB population, – common scoter Melanitta nigra: 53,454 wintering individuals = 3.3% of the GB population, Other species that might be judged for inclusion: – great-crested grebe Podiceps cristatus, – common eider Somateria mollissima, – red-breasted merganser Mergus serrator, and – little gull Larus minutes (Webb et al., 2004b);
• to prevent significant damage to or decrease in extent of habitat, vegetation characteristics or landscape features from a reference level; and
• to maintain the presence and abundance of prey species, primarily aquatic invertebrates but also aquatic vegetation (including algae), whereby the populations do not deviate significantly from a reference level.
Historic Trends and Current Pressures
3.2.5 With the proposed site encompassing approximately 198,000 hectares and a range of estuarine and maritime habitat, the Liverpool Bay pSPA and pRamsar site is subject to a wide range of pressures of varying spatial scope and human activity. Perhaps the most direct way to establish the proposed site’s recent changes in
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health / ecological status is through the changing environmental pressures upon the Irish Sea.
th 3.2.6 The industrial revolution of the 19P P century led to the Irish Sea being used to dispose liquid waste, including sewage and unwanted by-products of industrial processes (including mining, manufacturing, nuclear waste reprocessing and th energy generation). This improved in the latter half of the 20P P century, and sewage and other waste are no longer dumped offshore in an uncontrolled manner. While Liverpool Bay is hypernutrified, there is no evidence of harmful algal blooms or de- oxygenation of seawater (Environment Agency, pers. comm.).
3.2.7 Some of the main environmental pressures on the Irish Sea relevant to the nature conservation objectives of the Liverpool Bay pSPA and pRamsar site are:
• disturbance of sediment releasing legacy heavy metal pollution (lead, cadmium, arsenic and other poisons) that is bound into the sediment; • pollution via rivers by agricultural effluent flowing off fields, ‘leading to increased fertility of inshore waters and associated algal blooms and de- oxygenation of seawater, particularly in enclosed bays and estuaries’; • pollution via rivers and drains by both treated sewerage and untreated runoff containing inorganic chemicals and organic compounds from everyday domestic products, which ‘may combine together in ways that make it difficult to predict their ultimate effect of the marine environment… Some may remain indefinitely in the seawater, the seabed, or the flesh, fat and oil of sea creatures’; • pollution via commercial shipping by chemical or noise pollution and the dumping of litter at sea; • damage of marine benthic habitat directly from fishing methods; • damage of marine benthic habitat directly or indirectly from aggregate extraction; • ‘coastal squeeze’ (a type of coastal habitat loss) from land reclamation and coastal flood defences and drainage used in order to farm or develop coastal land, and from erosion and sea level rise; • loss or damage of marine benthic habitat directly and indirectly (through changed sedimentation/deposition patterns) as a result of navigational dredging in order to accommodate large vessels – e.g. into the ports of Liverpool; • harm to wildlife (especially birds) or habitat loss due to increasing proposals/demand for offshore wind turbines; and • pollution, direct kills, litter or loss of habitat as a result of water-based recreation and related development along the foreshore (Wildlife Trust, 2006).
Pathways linking St. Helens with Potential Effects upon the Site
3.2.8 There are three ways in which development within St. Helens could lead to effects on the Liverpool Bay pSPA/pRamsar site. These are:
• direct or indirect harm to any Birds Directive Annex I species that, for any reason such as breeding or feeding, spends time both within the Liverpool Bay pSPA and St. Helens (or otherwise separate populations that interbreed);
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• harm to benthic communities via waterborne pollution entering the Mersey Estuary, in turn from the Sankey Brook catchment (e.g. increase in heavy metals from sewage and/or industry); and • disturbance to birds from increased recreational pressure within the pSPA/Ramsar site.
3.3 Manchester Mosses SAC
3.3.1 Manchester Mosses SAC comprises Astley and Bedford Mosses, Holcroft Moss and Risley Moss, totalling approximately 173ha. The site is significant for mossland that ‘formerly covered a very large part of low-lying Greater Manchester, Merseyside and southern Lancashire, and provided a severe obstacle to industrial and agricultural expansion’ (JNCC, 2006d). These sites are examples that have survived as degraded raised bog on the Mersey floodplain, with their surfaces elevated above surrounding land due to shrinkage of the surrounding tilled land, and ‘all except Holcroft Moss have been cut for peat at some time in the past’ (JNCC, 2006d).
Reasons for Designation and Nature Conservation Objectives
3.3.2 Manchester Mosses SAC is designated for its Habitats Directive Annex I habitat of ‘degraded raised bogs still capable of natural regeneration’ (EC, 1992).
3.3.3 The main nature conservation objectives are:
• to re-establish peat-forming vegetation with at least 30% comprising Sphagnum mosses, and the remainder primarily cotton grasses; • to maintain stagnant and shallow bog water, indicative of anaerobic conditions; • to maintain a water table within approximately 25 cm of the surface; • to prevent invasion by dominant scrub or bracken over more than 10% of the mire expanse, unless tree/scrub is essential for other interest features such as nightjar; • to re-instate an undrained area around the raised bog with appropriate habitat such as fen, for such a distance as hydrological studies recommend.
Historic Trends and Current Pressures
3.3.4 As discussed above, the Manchester Mosses SAC is a direct result of historical loss of mossland (i.e. bog) habitat due to drainage for agriculture and built development. Mossland is reported to have been a significant obstacle to industrialisation of the area around Manchester, and its drainage and landfilling th th was intensified during the 19P P and 20P P centuries. However, recent rehabilitation management over the past 15-20 years has increased peat-producing Sphagnum species.
3.3.5 The environmental pressures upon the mossland habitat for which this site is designated are mainly:
• increased agricultural drainage in the surrounding land, which causes the habitat to dry out and begin succession towards scrubland and woodland
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(including drainage of peat that gradually increases a downward gradient away from the mosslands); • changes to the maintenance regime of nearby agricultural drainage, which can cause either drying out through unsympathetic dredging, or waterlogging through complete lack of dredging; • increased water abstraction for irrigation, which can contribute towards the drying out of mossland habitat through reduced flows and/or a lowered water table; • afforestation as a result of natural succession; • fly-tipping; • loss of neighbouring mossland habitat as a result of agricultural drainage or drainage and landfill for development; • loss of neighbouring peat and mossland habitat as a result of peat harvesting, both legally and illegally; • damage to mossland habitat due to increased recreational pressure (e.g. paintball); and • loss of Sphagnum species as a result of drying out and increased air pollution.
Pathways linking St. Helens with Potential Effects upon the Site
3.3.6 Two pathways have therefore been identified through which development within St. Helens could lead to significant effects upon the Manchester Mosses SAC:
• Increased deposition of atmospheric nitrogen. Since St Helens is situated approximately 8 km from the site, this will mainly be due to the increased population and increased travel by car along routes within 200 m of the SAC, of which by far the most significant is the M62; and • Increased recreational pressure (e.g. paintballing) associated with the increased population of the Borough.
3.4 Martin Mere SPA / Ramsar site
3.4.1 Martin Mere SPA and Ramsar site occupies approximately 120ha of a former lake th and mire that extended over approximately 1,300ha in the 17P P century. It currently comprises open water, seasonally flooded marsh (reedbed), and damp, neutral hay meadows overlying deep peat. It includes a wildfowl refuge of international importance with a large and diverse wintering, passage (migrating) and breeding bird community. There is considerable movement of wintering birds between this site and the nearby Ribble and Alt Estuaries SPA and Ramsar site (JNCC, 2006e).
Reasons for Designation and Nature Conservation Objectives
3.4.2 Martin Mere is designated as an SPA for its Birds Directive Annex I species, all of which are over-wintering birds, and these are:
• Bewick’s swan Cygnus columbianus ssp. bewickii: 449 individuals = 6.2% of GB population; • Whooper swan Cygnus cygnus: 621 individuals = 11.3% of GB population; • Pink-footed goose Anser brachyrhynchus: 25,779 individuals = 11.5% of Icelandic/Greenland & UK populations; and
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• Pintail Anas acuta: 978 individuals = 1.6% of NW European population.
3.4.3 It is additionally designated as a Ramsar site in accordance with Criterion 5 (UN, 2005) for supporting up to 25,306 waterfowl (5-year peak mean 1998/99 – 2002/03) in winter, and in accordance with Criterion 6 for supporting internationally important populations of pink-footed goose Anser brachyrhynchus, Bewick’s swan Cygnus columbianus ssp. bewickii, whooper swan Cygnus cygnus, Eurasian wigeon Anas penelope and northern pintail Anas acuta.
3.4.4 The main nature conservation objectives are:
• to prevent a significant reduction in numbers of all qualifying species of over- wintering birds from a reference level; • to prevent significant damage to (or decrease in the extent) of habitat, the hydrology or the landscape features from a reference level; and • to maintain the presence and abundance of aquatic plants and freshwater invertebrates, whereby the populations do not deviate significantly from a reference level.
Historic Trends and Current Pressures
3.4.5 The site is geared towards attracting visitors, with a number of hides from which the Mere and its birds may be viewed. In addition to the wild species for which it is designated, the site holds a collection of about 1,500 captive birds of 125 species from around the world, as well as a number of other visitor attractions. This is because the site is a Wildfowl and Wetlands Trust reserve.
3.4.6 The environmental pressures experienced by Martin Mere in terms of its bird community are likely to be those common to all reedbed habitat. The main concerns are:
• direct loss of characteristic species as a result of nutrient enrichment from agricultural fertilisers and run-off; • loss of reedbed due to weakening of stems through poor growth conditions; • natural succession to woodland through lack of active management; • reduced water level by surface and ground water abstractions or agricultural drainage, which causes the habitat to dry out and begin succession towards ‘alder/willow carr woodland, hastening the overall process of succession towards broadleaved woodland’ (Lancashire Biodiversity Partnership, 2001); • removal of reeds and other vegetation from whole stretches of watercourses (e.g. neighbouring the site) through routine management of ditches and riverbanks (in some instances); • erosion of reedbeds due to increased recreational use of waterbodies and waterways (notably canals); and • habitat loss or degradation due to the isolation of reedbeds as a result of losses elsewhere, in turn due to the above or other factors (Lancashire Biodiversity Partnership, 2001).
Pathways linking St. Helens with Potential Effects upon the Site
3.4.7 There are two ways in which development within St. Helens could lead to effects on Martin Mere SPA and Ramsar site. These are:
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• direct or indirect harm to any Birds Directive Annex I species that, for any reason such as breeding or feeding, spends time both within Martin Mere and St. Helens (or otherwise separate populations that interbreed); and • disturbance to birds from increased recreational pressure (e.g. recreational use of associated waterways).
3.4.8 However, the view of Natural England is that “increased recreational pressure on Martin Mere [is not] a current relevant environmental pressure for consideration by the AA for St Helens LDF”. Impacts on Martin Mere have therefore been screened out of the assessment. 3.5 Mersey Estuary SPA / Ramsar site
3.5.1 The Mersey Estuary is a large sheltered estuary that receives drainage from a 2 catchment area of approximately 5,000kmP P (Marine Biological Association, 2006), and the SPA and Ramsar site comprises approximately 5,030ha of saltmarsh and inter-tidal mudflats. Additionally, there are limited areas of brackish marsh, rocky shoreline and boulder clay. The inter-tidal flats and saltmarshes provide feeding and roosting sites for large populations of waterbirds and during the winter, the site is of major importance for ducks and waders. The site is also important during the spring and autumn migration periods, particularly for wader populations moving along the west coast of Britain.
3.5.2 Appendix 5 includes an illustration of the Mersey catchment; this includes the conurbations of Manchester and Liverpool, the latter of which includes St. Helens.
Reasons for Designation and Nature Conservation Objectives
3.5.3 The Mersey Estuary is designated as an SPA for its Birds Directive Annex I species, all of which are over-wintering birds, and these are:
• Golden plover Pluvialis apricaria: 3,070 individuals = 1.2% of GB population; • Redshank Tringa totanus: 3,516 individuals = 2.0% of Eastern Atlantic population; • Ringed plover Charadrius hiaticula: 1,453 individuals = 2.9% of Europe/North African population; • Dunlin Calidris alpina alpina: 44,300 individuals = 3.2% of Northern Siberian/Europe/West African population; • Pintail Anas acuta: 2,744 individuals = 4.6% of NW European population; • Redshank Tringa totanus: 4,689 individuals = 3.1% of Eastern Atlantic population; • Shelduck Tadorna tadorna: 5,039 individuals = 1.7% of wintering NW European population; and • Teal Anas crecca: 11,667 individuals = 2.9% of NW European population.
3.5.4 It is additionally designated as a Ramsar site in accordance with Criterion 5 (UN, 2005) for supporting up 89,576 waterfowl (5-year peak mean 1998/99 – 2002/03), and in accordance with Criterion 6 for supporting internationally important populations of common shelduck Tadorna tadorna, black-tailed godwit Limosa limosa ssp. limosa, redshank Tringa totanus, Eurasian teal Anas crecca, northern pintail Anas acuta and dunlin Calidris alpina alpina.
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3.5.5 The main nature conservation objectives are:
• to prevent a significant reduction in numbers or displacement of all qualifying species of over-wintering birds from a reference level; • to prevent significant damage to or decrease in the extent of habitat, the vegetation characteristics or the landscape features from a reference level; and • to maintain the presence and abundance of aquatic plants and invertebrates, whereby the populations do not deviate significantly from a reference level.
Historic Trends and Current Pressures
th 3.5.6 Water pollution has been an issue for the estuary since at least the 18P P century, with ‘increased wastes from [the] textile, tanning, metal processing, chemical… and petrochemical industries…, discharge of domestic waster water, sewage and surface runoff from a large populated area’ (Marine Biological Association, 2006, p.13). The problem of water pollution ‘was probably at its worst in the 1960’s,’ and major improvements to water quality have been realised since the formation of the Mersey Basin Campaign in 1985, which aims to ‘revitalise the River Mersey and its waterfront’ (Marine Biological Association, 2006, p.13). Figure 2 below illustrates water quality improvements in River Mersey reported by the Mersey Basin Campaign. The table is taken from a Mersey Basin Campaign report, and is assumed to refer to chemical water quality, and the vertical column to river length.
3,000
2,500
2,000 Poor / Bad
1,500 Good / Fair
1,000
500
0 ‘Classified River Length Quality’ Quality’ Length River ‘Classified 1985 1990 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001
Figure 2: Water Quality Improvements Across the Mersey Catchment from 1985 to 2001 Source: Mersey Basin Campaign, 2004, p.4
3.5.7 The major projects that brought about the improvements to water quality were a primary sewage treatment works for Liverpool, fine sewage screening plants on the Wirral peninsula, secondary sewage treatment and petrochemical effluent treatment plants at Ellesmere Port, secondary sewage treatment plants at Widnes and Warrington, modification of the Davyhulme sewage treatment plan in Manchester to treat ammonia, and later secondary sewage treatment plants at Birkenhead/Bromborough.
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3.5.8 Other improvements have been made, including reducing industrial inputs of mercury, lead, cadmium, pentachlorophenol and chlorinated hydrocarbons into the estuary.
3.5.9 However, certain inputs remain, including:
• pesticides and herbicides from agriculture (largely dairy farming) into the upper river system, • phthalate esters thought to come from wastewater discharges in the upper Mersey, • hydrocarbon contamination from oil spillage/spills from Tranmere Oil Dock/Terminal, Stanlow (Shell) Oil Refinery and oil tanks along the southern bank of the estuary, from pipelines that run between these sites along the southern bank of the estuary, and from oil shipping spills in the Irish Sea, • polychlorinated biphenyls from the River Mersey (possibly also dredge spoils), and • PCBs from contaminated land in the catchment area (Marine Biological Association, 2006).
3.5.10 A report from the Mersey Basin Campaign (2005) shows river sampling sites in the Mersey catchment that report low (Grades D, E and F, or ‘fair’ to ‘bad’) biological and chemical river water quality. Such sampling sites of fair to bad biological and chemical water quality are particularly concentrated in the area between Knowsley and Manchester, including St. Helens and Wigan. (Only those within the Mersey catchment – see Appendix 5 – are described.)
3.5.11 The main current environmental pressures upon the Mersey Estuary SPA and Ramsar site are considered to be:
• disturbance of sediment releasing legacy heavy metal pollution (mercury, lead, cadmium and other poisons) that is bound into the sediment, or other introduction of these metals; • pollution via rivers and drains by both treated sewerage and untreated runoff containing inorganic chemicals and organic compounds from everyday domestic products, which ‘may combine together in ways that make it difficult to predict their ultimate effect of the marine environment… Some may remain indefinitely in the seawater, the seabed, or the flesh, fat and oil of sea creatures’; • pollution via commercial shipping by chemical pollution and the dumping of litter at sea; • ‘coastal squeeze’ from land reclamation and coastal flood defences and drainage used in order to develop coastal land, and from sea level rise; • loss or damage of marine benthic habitat directly and indirectly (through changed sedimentation/deposition patterns) as a result of navigational or aggregate dredging; • disturbance to birds from increased recreational pressure (e.g. boat or other recreational activity); • introduction of non-native species and translocation; and • selective removal of species (e.g. bait digging, wildfowl, fishing) (Wildlife Trust, 2006 and Marine Biological Association, 2006).
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Pathways linking St. Helens with Potential Effects upon the Site
3.5.12 There are four ways in which development within St. Helens could lead to effects on the Mersey Estuary SPA and Ramsar site. These are:
• direct or indirect harm to any Birds Directive Annex I species that, for any reason such as breeding or feeding, spends time both within the Estuary and St. Helens (or otherwise separate populations that interbreed); • harm to benthic communities via waterborne pollution entering the Mersey Estuary, in turn from the Sankey Brook catchment (e.g. increase in heavy metals from sewage and/or industry); • alteration to flows resulting from increased modification of watercourses; and • disturbance to birds from increased recreational pressure.
3.6 Mersey Narrows & North Wirral Foreshore pSPA / pRamsar site
3.6.1 The Mersey Narrows and North Wirral Foreshore pSPA and pRamsar site is approximately 2,078ha, located at the mouths of the Mersey and Dee estuaries. The site comprises intertidal habitats at Egremont foreshore (feeding habitat for waders at low tide), man-made lagoons at Seaforth Nature Reserve (high tide roost and nesting site for terns) and the extensive intertidal flats at North Wirral Foreshore (supports large numbers of feeding waders at low tide and also includes important high-tide roost sites). The most notable feature of the site is the exceptionally high density of wintering Turnstone. The Mersey Narrows and North Wirral Foreshore has clear links in terms of bird movements with the nearby Dee Estuary SPA and Ramsar site, Ribble and Alt Estuaries SPA and Ramsar site, and (to a lesser extent) the Mersey Estuary SPA and Ramsar site (Wirral MBC, 2001).
Reasons for Designation and Nature Conservation Objectives
3.6.2 The Mersey Narrows and North Wirral Foreshore pSPA and pRamsar site is proposed on the grounds of its feeding and roosting habitat for non-breeding wading birds, and as a breeding site for terns (Wirral MBC, 2001). The Birds Directive Annex I species (qualifying the site under Article 4.1), which can be found in any season, are:
• Common Tern Sterna hirundo: 124 pairs breeding = 1.0% of the GB population; and • Bar-tailed Godwit Limosa lapponica: 537 individuals wintering = 1.0% of the GB population.
3.6.3 The site also qualifies under Article 4.2 of the Birds Directive, as it is used regularly by 1% or more of the biogeographical populations of the following migratory species:
• Knot Calidris canutus: 10,661 individuals = 3.0% of NW European, NE Canadian, Greenland & Icelandic populations; • Redshank Tringa totanus: 1,606 individuals = 1.1% Eastern Atlantic population; and
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• Turnstone Arenaria interpres: 1,593, individuals = 2.3% Western Palearctic population.
3.6.4 Additionally, in qualifying under Article 4.2 of the Birds Directive, the site regularly supports over 20,000 individuals of a wider range of species, including dunlin, knot Calidris canutus, grey plover Pluvialis squatarola, oystercatcher Haematopus ostralegus and cormorant Phalacrocorax carbo.
3.6.5 The site qualifies under the Ramsar Convention under Criterion 5, regularly supporting over 20,000 waterbirds (non-breeding season, 28,841 individual waterbirds), and Criterion 6, regularly supporting 1% of the species or subspecies of waterbird in any season listed above.
3.6.6 Since the site is not yet an SPA or Ramsar site, there are no nature conservation objectives provided at this stage, but they would likely be similar to those of other maritime and estuarine SPAs, particularly nearby sites such as the Mersey Estuary SPA. Such objectives are thus assumed to include:
• to prevent a significant reduction in numbers of all qualifying species from a reference level; • to prevent significant damage to or decrease in the extent of habitat, vegetation characteristics or the landscape features from a reference level; and • to maintain the presence and abundance of aquatic plants (including algae) and invertebrates, whereby the populations do not deviate significantly from a reference level.
Historic Trends and Current Pressures
3.6.7 Due to its location at the mouth of the Mersey Estuary and in the Liverpool Bay, this site has been subject to the same changes as described for the Liverpool Bay pSPA and pRamsar site and the Mersey Estuary SPA and Ramsar site, in particular water quality improvements since the 1960s (especially since 1985), and increases in agricultural effluent pollution during this same period.
3.6.8 Some of the main environmental pressures relevant to the nature conservation objectives of the Mersey Narrows and North Wirral Foreshore pSPA / pRamsar site are:
• disturbance of sediment releasing legacy heavy metal pollution (lead, cadmium, arsenic and other poisons) that is bound into the sediment; • pollution via rivers and drains by both treated sewerage and untreated runoff containing inorganic chemicals and organic compounds from everyday domestic products, which ‘may combine together in ways that make it difficult to predict their ultimate effect of the marine environment… Some may remain indefinitely in the seawater, the seabed, or the flesh, fat and oil of sea creatures’; • pollution via commercial shipping by chemical or noise pollution and the dumping of litter at sea; • damage of marine benthic habitat directly from fishing methods;
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• damage of marine benthic habitat along the North Wirral Foreshore directly or indirectly from aggregate extraction, particularly anywhere that dredging may 6 be altering erosion/deposition patternsTPF FPT; • ‘coastal squeeze’ (a type of coastal habitat loss) from land reclamation and coastal flood defences and drainage used in order to farm or develop coastal land, and from sea level rise; • loss or damage of marine benthic habitat directly and indirectly (through changed sedimentation/deposition patterns) as a result of navigational dredging in order to accommodate large vessels – e.g. into the ports of Liverpool; • harm to wildlife (especially birds) or habitat loss due to increasing proposals/demand for offshore wind turbines; and • pollution, direct kills, litter, disturbance or loss of habitat as a result of water- based recreation or other recreation activity and related development along the foreshore (Wildlife Trust, 2006); • introduction of non-native species and translocation; and • selective removal of species (e.g. bait digging, wildfowl, fishing) (Wildlife Trust, 2006 and Marine Biological Association, 2006).
3.6.9 The Mersey estuary does have a high load of nutrients mainly from diffuse sources, with levels for phosphate and nitrogen decreasing from point sources. However, recent modelling has shown that due to the natural turbidity of the water, there is only a low risk of excessive algal growth. Therefore Natural England do not consider nutrients to be a pressure on Mersey Narrows and Wirral Foreshore (Mandy North, Natural England, pers. comm.).
Pathways linking St. Helens with Potential Effects upon the Site
3.6.10 There are three ways in which development within St. Helens could possibly lead to effects on the Mersey Narrows and North Wirral Foreshore pSPA/pRamsar site. These are:
• direct or indirect harm to any Birds Directive Annex I species that, for any reason such as breeding or feeding, spends time both within the Mersey Narrows and North Wirral Foreshore pSPA/pRamsar site and St. Helens (or otherwise separate populations that interbreed); • harm to benthic communities via waterborne pollution entering the Mersey Estuary, in turn from the Sankey Brook catchment (e.g. increase in heavy metals from sewage and/or industry); and • disturbance to birds from increased recreational pressure.
6 TP PT Natural England is of the opinion that offshore aggregate extraction is potentially a relevant and current pressure on coastal and maritime Natura 2000 sites. They are, however, statutory consultees on all such proposals and will make representations as appropriate based on individual cases, because depending on the scale of extraction, not all proposals will necessarily have a significant effect on the features of interest for which the sites are notified, and some extraction will therefore be permitted (Mandy North, Natural England, pers. comm.). There are no expectations of an increase in aggregate extraction as a result of policies within the St Helens LDF.
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3.7 Ribble and Alt Estuaries SPA / Ramsar site
3.7.1 The Ribble and Alt Estuaries SPA and Ramsar site is approximately 12,360ha, and consists of extensive sand- and mud-flats and, particularly in the Ribble Estuary, large areas of saltmarsh. There are also areas of coastal grazing marsh located behind the sea embankments. The saltmarshes and coastal grazing marshes support high densities of grazing and seed-eating wildfowl, and these, together with the intertidal sand- and mud-flats, are used as high-tide roosts. Important populations of waterbirds occur in winter, including swans, geese, ducks and waders. The highest densities of feeding birds are on the muddier substrates of the Ribble.
3.7.2 The SPA is also of major importance during the spring and autumn migration periods, especially for wader populations moving along the west coast of Britain. The larger expanses of saltmarsh and areas of coastal grazing marsh support breeding birds during the summer, including large concentrations of gulls and terns. These seabirds feed both offshore and inland, outside of the SPA. Several species of waterbird (notably pink-footed goose Anser brachyrhynchus) utilise feeding areas on agricultural land outside of the SPA boundary. There is considerable interchange in the movements of wintering birds between this site and Morecambe Bay, the Mersey Estuary, the Dee Estuary and Martin Mere.
Reasons for Designation and Nature Conservation Objectives
3.7.3 The Ribble and Alt Estuaries site is designated as an SPA for its Birds Directive Annex I species, both breeding and over-wintering, and these are:
During the breeding season: • common tern Sterna hirundo: 182 pairs = 1.5% of the breeding poulation in Great Britain; • ruff Philomachus pugnax: 1 pair = 9.1% of the breeding population in Great Britain; Over winter: • bar-tailed godwit Limosa lapponica: 18,958 individuals = 35.8% of the population in Great Britain; • Bewick’s swan Cygnus columbianus ssp. bewickii: 229 individuals = 3.3% of the population in Great Britain; • golden plover Pluvialis apricaria: 4,277 individuals = 1.7% of the population in Great Britain • whooper swan Cygnus cygnus: 159 individuals = 2.9% of the population in Great Britain.
3.7.4 It also meets the criteria for SPA designation under Article 2 of the Birds Directive, supporting internationally important populations of lesser black-backed gull Larus fuscus, ringed plover Charadrius hiaticula, sanderling Calidris alba, black-tailed godwit Limosa limosa ssp. limosa, dunlin Calidris alpina alpina, grey plover Pluvialis squatarola, knot Calidris canutus, oystercatcher Haematopus ostralegus, pink-footed goose Anser brachyrhynchus, pintail Anas acuta, redshank Tringa totanus, sanderling Calidris alba, shelduck Tadorna tadorna, teal Anas crecca and wigeon Anas penelope. It also qualifies by regularly supporting up to 29,236 individual seabirds, and, over winter, 301,449 individual waterfowl.
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3.7.5 It is additionally designated as a Ramsar site in accordance with Criterion 5 (UN, 2005) for supporting up 89,576 waterfowl (5-year peak mean 1998/99 – 2002/03), and in accordance with Criterion 6 for supporting internationally important populations of common shelduck Tadorna tadorna, black-tailed godwit Limosa limosa ssp. limosa, redshank Tringa totanus, Eurasian teal Anas crecca, northern pintail Anas acuta and dunlin Calidris alpina alpina.
3.7.6 The main nature conservation objectives are:
• to prevent a significant reduction in numbers or displacement of all qualifying species of over-wintering birds from a reference level; • to prevent significant damage to or decrease in the extent of habitat, the vegetation characteristics or the landscape features from a reference level; and • to maintain the presence and abundance of aquatic plants and invertebrates, whereby the populations do not deviate significantly from a reference level.
Historic Trends and Current Pressures
3.7.7 As an estuarine site linked with the Liverpool Bay, this site has been subject to the same changes as described for the Liverpool Bay pSPA but additionally its own unique pressures (some similar to those experienced in the Mersey Estuary). The th estuaries were largely undisturbed until the 19P P century, at which point there was extensive modification and dredging of the river channel for the Port of Preston, as well as landfill and drainage along the shoreline in order to increase agricultural usage of the land. The Ribble Estuary has over the past century experienced ‘a general pattern of sediment accretion in the inner Estuary and erosion in outer areas,’ but the estuary has begun ‘to revert to its natural state… since maintenance of the Ribble Channel for shipping ceased in 1980. There have been dramatic changes in the course of channels in the outer Estuary, and these are expected to continue. Anticipated climatic and sea level changes are likely to exaggerate existing patterns of erosion and accretion, although sea level rise is not expected to cause significant loss of intertidal land in the Ribble’ (Ribble Estuary Strategy Steering Group, 1997, p.15).
3.7.8 The Ribble and Alt Estuaries are among ‘the most popular holiday destinations in Britain,’ with Blackpool as the largest resort and Southport increasing in visitors. Leisure activities include ‘watersports such as sailing and windsurfing; fishing and shooting; bird watching; land yachting; and generally relaxing at the coast… enjoyed by both local people and visitors’ (Ribble Estuary Strategy Steering Group, 1997, p.10).
3.7.9 Some of the main environmental pressures relevant to the nature conservation objectives of the Ribble and Alt Estuaries SPA / Ramsar site are:
• loss or damage of habitat as a result of increasing off-shore exploration and production activity associated with oil and natural gas; • over-grazing of the saltmarshes by cattle-farming; • heavy metal pollution (lead, cadmium, arsenic and other poisons) from either industry or disturbance of sediment (legacy pollution bound into the sediment);
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• pollution via rivers by agricultural effluent flowing off fields, ‘leading to increased fertility of inshore waters and associated algal blooms and de- oxygenation of seawater, particularly in enclosed bays and estuaries’; • pollution via rivers and drains by both treated sewerage and untreated runoff containing inorganic chemicals and organic compounds from everyday domestic products, which ‘may combine together in ways that make it difficult to predict their ultimate effect of the marine environment… Some may remain indefinitely in the seawater, the seabed, or the flesh, fat and oil of sea creatures’; • damage of marine benthic habitat directly from fishing methods; • damage of marine benthic habitat directly or indirectly from aggregate 7 extractionTPF FPT; • ‘coastal squeeze’ (a type of coastal habitat loss) from land reclamation and coastal flood defences and drainage used in order to farm or develop coastal land, and from sea level rise; • harm to wildlife (especially birds) or habitat loss due to increasing proposals/demand for offshore wind turbines; • pollution, direct kills, litter, disturbance or loss of habitat as a result of water- based recreation or other recreation activity and related development along the foreshore (Wildlife Trust, 2006); • introduction of non-native species and translocation; and • selective removal of species (e.g. bait digging, wildfowl, fishing) (Wildlife Trust, 2006 and Ribble Estuary Strategy Steering Group, 1997).
Pathways linking St. Helens with Potential Effects upon the Site
3.7.10 There are three ways in which development within St. Helens could possibly lead to effects on the Ribble and Alt Estuaries SPA/Ramsar site. These are:
• direct or indirect harm to any Birds Directive Annex I species that, for any reason such as breeding or feeding, spends time both within the Ribble and Alt Estuaries SPA/Ramsar site and St. Helens (or otherwise separate populations that interbreed); • harm to benthic communities via waterborne pollution entering the Alt Estuary where development may occur in the very small section of St. Helens that lies within its catchment; and • disturbance to birds from increased recreational pressure.
3.8 Rixton Clay Pits SAC
3.8.1 Situated to the east of Warrington, the Rixton Clay Pits SAC is an approximately 14ha site comprising parts of an extensive disused brickworks excavated in glacial boulder clay. The excavation has left a series of hollows that have filled with water
7 TP PT Natural England is of the opinion that offshore aggregate extraction is potentially a relevant and current pressure on coastal and maritime Natura 2000 sites. They are, however, statutory consultees on all such proposals and will make representations as appropriate based on individual cases, because depending on the scale of extraction, not all proposals will necessarily have a significant effect on the features of interest for which the sites are notified, and some extraction will therefore be permitted (Mandy North, Natural England, pers. comm.). There are no expectations of an increase in aggregate extraction as a result of policies within the St Helens LDF.
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since workings ceased in the 1960s, leading to a variety of pond sizes. New ponds have also been created more recently for wildlife and amenity purposes. Great- crested newts are known to occur in at least 20 ponds across the site. The site also supports species-rich grassland, scrub and mature secondary woodland.
Reasons for Designation and Nature Conservation Objectives
3.8.2 Rixton Clay Pits SAC is designated for its Habitats Directive Annex II species of great-crested newt Triturus cristatus.
3.8.3 The main nature conservation objectives are:
• to prevent loss of area from or fragmentation of site; • to prevent barriers to newt movement between ponds; • to maintain the number of waterbodies at the site (currently 33); and • to prevent levels of pollution that would reduce the viability of the pond as a breeding site (e.g. causes major macrophyte losses) • to ensure that 75% of the waterbodies hold water throughout the breeding and tadpole development season (February to mid-August).
Historic Trends and Current Pressures
3.8.4 The Rixton Clay Pits SAC is a direct result of dwindling numbers of great-crested newts nationally, at a rate reported at 2% of colonies per year (or 360 populations) (Wildlife Trusts, 2000). Major causes have been the loss of breeding ponds and surrounding terrestrial habitat by built development and waterborne pollution from industry and roads. Overall, pond habitat is suffering a decline nationally, as they are less favoured to other modes of landscaping (e.g. amenity mowing regimes) and intensive landscape management.
3.8.5 The environmental pressures upon great-crested newts for which this site is designated are mainly:
• loss habitat due to built development, and habitats being further fragmented by distance; • barriers to movement due to built development, and habitats being further fragmented by obstacles; • loss of habitat as a result of natural succession; • significant pollution of habitat from industry and roads; • ‘park-style’ maintenance of terrestrial habitat (e.g. mowing regimes); • fish stocking of ponds; and • landscaping and reclamation of derelict land.
Pathways linking St. Helens with Potential Effects upon the Site
3.8.6 No significant pathways for effects on the site as a result of development within St. Helens have been identified. This site is therefore screened out of the assessment.
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3.9 Sefton Coast SAC
3.9.1 Located to the north of Liverpool, the Sefton Coast SAC (approximately 4,560ha) consists of a mosaic of sand dune communities comprising a range of ages from embryonic (i.e. dune formation) to more established communities. A number of other habitats are also present, including lagoons, estuaries and riverine environments, but also scrub, heath and coniferous woodland.
Reasons for Designation and Nature Conservation Objectives
3.9.2 The Sefton Coast qualifies as an SAC for both habitats and species. Firstly, the site contains the Habitats Directive Annex I habitats of:
• embryonic shifting sand dunes: considered rare, as its total extent in the United Kingdom is estimated to be less than 1,000 hectares – the Sefton Coast SAC is considered to be one of the best areas in the United Kingdom; • shifting dunes along the shoreline with marram Ammophila arenaria (“white dunes”): the Sefton Coast SAC is considered to be one of the best areas in the United Kingdom; • fixed dunes with herbaceous vegetation (“grey dunes”): the Sefton Coast SAC is considered to be one of the best areas in the United Kingdom; • dunes with creeping willow Salix repens ssp. argentea (Salicion arenariae): considered rare, as its total extent in the United Kingdom is estimated to be less than 1,000 hectares – the Sefton Coast SAC is considered to support a significant presence of the species; • humid dune slacks: the Sefton Coast SAC is considered to be one of the best areas in the United Kingdom; and • Atlantic decalcified fixed dunes (Calluno-Ulicetea): considered rare, as its total extent in the United Kingdom is estimated to be less than 1,000 hectares – the Sefton Coast SAC is considered to support a significant presence.
3.9.3 Secondly, the site contains the Habitats Directive Annex II species Petalwort Petalophyllum ralfsii, for which it is one of the best areas in the United Kingdom, and great-crested newt Triturus cristatus, for which the area is considered to support a significant presence.
3.9.4 The main nature conservation objectives are:
Habitats: • to maintain the extent of sand dunes (although this extent must take account of natural variation of this habitat as a result of succession to, and interaction with, other dune habitats); • to maintain less than 25% cover by bare sand; • to maintain the range and mosaic of sand dune communities, vegetation structure and species present (although prevent increase of existing coniferous woodland or scrub cover at the expense of fixed dune vegetation); Petalwort: • to maintain the existing 47 populations, and the general extent of the area 2 (approximately 600mP ,P within relatively young frontal dune slacks of the Ainsdale and Birkdale Hills Local Nature Reserve (LNR)); • to maintain favourable vegetation structure (< 1cm bare substrate: 20 – 90%, most abundant populations occurring at 30% bare substrate);
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Great Crested Newts • to maintain the area of terrestrial habitat: prevent reduction of waterbodies present that currently support great crested newts; and • to prevent fragmentation of the terrestrial habitat: prevent barriers to newt movement between suitable ponds.
Historic Trends and Current Pressures
3.9.5 The dune habitats of the Sefton Coast SAC are dependent upon natural erosive processes. Various human activities that interrupt natural sedimentation and deposition patterns within the Liverpool Bay have had an effect on the wildlife value th of these dunes and their very existence. Since as early as the 18P P century, ‘dredging, river training and coastline hardening have imposed a pattern of accretion and erosion on the shoreline where previous conditions were much more variable’ (Liverpool Hope University College, 2006). More recently, the dunes have been partially stabilised through maintaining their natural vegetation, the planting of pine trees, and artificial sea defences for protecting the developed shorelines. Another compounding influence is that the inland lakes and mosses behind the belt of coastal dunes have been drained and claimed for agricultural production (Liverpool Hope University College, 2006).
3.9.6 Although the presence of great-crested newt on the site is considered secondary to the presence of petalwort, the pressures facing this species (as described for the Rixton Clay Pits SAC) remain relevant to the site. However, quite uniquely, a previous warden of the Sefton Coast SAC purposely introduced this population of great-crested newt, and it has generally thrived.
3.9.7 The environmental pressures upon the Sefton Coast SAC are mainly:
• lack of habitat management and/or poor management, including unmanaged spread of pine woodland and lack of grazing or otherwise too little recreational use of the site; • loss or damage to habitat due to unsustainable and/or unmanaged coastal recreation; • interruption of natural erosion/deposition patterns as a result of aggregate extraction, navigational dredging or coastal defences or other forms of dredging or hard-standing; • loss of great-crested newt habitat, and habitats being further fragmented by distance or barriers; and • fish stocking of ponds with great-crested newts.
Pathways linking St. Helens with Potential Effects upon the Site
3.9.8 The only way in which development within St. Helens could lead to significant effects upon the Sefton Coast SAC is through increased recreational pressure, including in combination with other plans. However Natural England “does not consider unsustainable recreational pressure on Sefton Coast SAC to be a current relevant environmental pressure for consideration by the AA for St Helens LDF. Apart from aggregate extraction, covered by point 3 above, we do not consider that the list of potential current environmental pressures is relevant for consideration by the AA for St Helens LDF.” This site is therefore screened out of the assessment.
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3.10 River Dee and Bala Lake SAC
Reasons for Designation and Nature Conservation Objectives
3.10.1 The River Dee and Bala Lake qualifies as an SAC for both habitats and species. Firstly, the site contains the following Habitats Directive Annex I habitats:
• Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation
3.10.2 Secondly, the site contains the following Habitats Directive Annex II species:
• Atlantic salmon Salmo salar • Floating water-plantain Luronium natans • Sea lamprey Petromyzon marinus • Brook lamprey Lampetra planeri • River lamprey Lampetra fluviatilis • Bullhead Cottus gobio • Otter Lutra lutra
3.10.3 The historic trends and current pressures on the site are summarised below.
Historic Trends and Current Pressures
3.10.4 The habitats and species for which the site is designated are dependent on the maintenance of good water quality and suitable flow conditions. Fish species require suitable in-stream habitat and an unobstructed migration route. Otters also require suitable terrestrial habitat to provide cover and adequate populations of prey species. The site and its features have been historically threatened by practices which had an adverse effect on the quality, quantity and pattern of water flows, such as inappropriate flow regulation, excessive abstraction, deteriorating water quality from direct and diffuse pollution, eutrophication and siltation. Degradation of riparian habitats due to engineering works, agricultural practices and invasive plant species have also had localised adverse effects in the past. The Atlantic salmon population has been threatened by excessive exploitation by high sea, estuarine and recreational fisheries. Introduction of non-indigenous species has also been a risk to both fish and plant species.
3.10.5 The environmental pressures upon the River Dee & Bala Lake SAC are mainly:
• Deterioration in water quality and changes in flow rates due to ex-industrial runoff, discharge of treated sewage effluent (which contains elevated nitrates) and agricultural runoff; • Risk of excessive abstraction resulting in a decrease in freshwater flows and an increase in sediment loading of water such that dehydration of interest features may occur; • Overfishing of Atlantic salmon; and • Introduction of invasive species.
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Pathways linking St. Helens with Potential Effects upon the Site
3.10.6 The River Dee currently provides St Helens with approximately 75% of its water supply. Excessive abstraction from the Dee associated with the increased population of St Helens could therefore result in sufficient drawdown of water to damage the interest features of the River Dee and Bala Lake SAC through desiccation or a deterioration in water quality due to the lower proportion of freshwater to sediment. 3.11 The Dee Estuary SAC, SPA & Ramsar site
Reasons for Designation and Nature Conservation Objectives
3.11.1 The Dee Estuary qualifies as an SAC for both habitats and species. Firstly, the site contains the following Habitats Directive Annex I habitats:
• Water courses of plain to montane levels with the Ranunculion fluitantis and Callitricho-Batrachion vegetation • Mudflats and sandflats not covered by seawater at low tide • Salicornia and other annuals colonising mud and sand - The Dee Estuary is representative of pioneer glasswort Salicornia spp. saltmarsh in the north- west of the UK. Salicornia spp. saltmarsh forms extensive stands in the Dee, especially on the more sandy muds where there is reduced tidal scour. It mainly occurs on the seaward fringes as a pioneer community, and moving landwards usually forms a transition to common saltmarsh-grass Puccinellia maritima saltmarsh (SM10). There is also a low frequency of Salicornia spp. extending well inland. Associated species often include annual sea-blite Suaeda maritima and hybrid scurvy grass Cochlearia x hollandica. • Atlantic salt meadows (Glauco-Puccinellietalia maritimae) - The Dee Estuary is representative of H1330 Atlantic salt meadows in the north-west of the UK. It forms the most extensive type of saltmarsh in the Dee, and since the 1980s it has probably displaced very large quantities of the non-native common cord-grass Spartina anglica. The high accretion rates found in the estuary are likely to favour further development of this type of vegetation. The saltmarsh is regularly inundated by the sea; characteristic salt-tolerant perennial flowering plant species include common saltmarsh-grass Puccinellia maritima, sea aster Aster tripolium, and sea arrowgrass Triglochin maritima. In a few areas there are unusual transitions to wet woodland habitats.
3.11.2 Secondly, the site contains the following Habitats Directive Annex II habitats and species:
• Estuaries • Annual vegetation of drift lines • Vegetated sea cliffs of the Atlantic and Baltic coasts • Embryonic shifting dunes • Shifting dunes along the shoreline with Ammophila arenaria (`white dunes`) • Fixed dunes with herbaceous vegetation (`grey dunes`) • Humid dune slacks • Sea lamprey Petromyzon marinus • River lamprey Lampetra fluviatilis
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• Petalwort Petalophyllum ralfsii
3.11.3 The Dee Estuary also qualifies as a Special Protection Area supporting:
3.11.4 During the breeding season;
• Common Tern Sterna hirundo, 277 pairs representing at least 2.3% of the breeding population in Great Britain (5 year mean 1991-95) • Little Tern Sterna albifrons, 56 pairs representing at least 2.3% of the breeding population in Great Britain (RSPB, 5 year mean 1991-95)
3.11.5 On passage;
• Sandwich Tern Sterna sandvicensis, 818 individuals representing at least 5.8% of the population in Great Britain (5 year mean 1991-95) • Redshank Tringa totanus, 8,451 individuals representing at least 4.8% of the Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6)
3.11.6 Over winter;
• Bar-tailed Godwit Limosa lapponica, 1,013 individuals representing at least 1.9% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6)
3.11.7 This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European importance of the following migratory species:
• Black-tailed Godwit Limosa limosa islandica, 1,739 individuals representing at least 2.5% of the wintering Iceland - breeding population (5 year peak mean 1991/2 - 1995/6) • Curlew Numenius arquata, 4,028 individuals representing at least 1.2% of the wintering Europe - breeding population (5 year peak mean 1991/2 - 1995/6) • Dunlin Calidris alpina alpina, 22,479 individuals representing at least 1.6% of the wintering Northern Siberia/Europe/Western Africa population (5 year peak mean 1991/2 - 1995/6) • Grey Plover Pluvialis squatarola, 2,193 individuals representing at least 1.5% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6) • Knot Calidris canutus, 21,553 individuals representing at least 6.2% of the wintering Northeastern Canada/Greenland/Iceland/Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Oystercatcher Haematopus ostralegus, 28,434 individuals representing at least 3.2% of the wintering Europe & Northern/Western Africa population (5 year peak mean 1991/2 - 1995/6) • Pintail Anas acuta, 6,498 individuals representing at least 10.8% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Redshank Tringa totanus, 6,382 individuals representing at least 4.3% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6)
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• Shelduck Tadorna tadorna, 6,827 individuals representing at least 2.3% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Teal Anas crecca, 5,918 individuals representing at least 1.5% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6)
3.11.8 The Dee Estuary is also designated as an SPA for regularly supporting 130,408 8 individual waterfowl (5 year peak mean 1991/2 - 1995/6)TPF FPT. In addition to the SPA designation the Dee Estuary is also designated as a Ramsar site by meeting Ramsar criteria 1, 5 and 6 as follows:
• Extensive intertidal mud and sand flats (20 km by 9 km) with large expanses of saltmarsh towards the head of the estuary. • Supporting an overall bird assemblage of international importance; and • Supporting the following species at levels of international importance: shelduck, oystercatcher, curlew, redshank, teal, pintail, grey plover, red knot, dunlin, bar-tailed godwit, black-tailed godwit and turnstone
3.11.9 The historic trends and current pressures on the site are summarised below.
Historic Trends and Current Pressures
3.11.10 The majority of the site is in the ownership and sympathetic management of public bodies and voluntary conservation organisations. Unlike most western estuaries, sizeable areas of saltmarsh in the Dee remain ungrazed and therefore plant species that are susceptible to grazing are widespread. This distinctive flora would therefore be sensitive to increase in grazing pressure. The intertidal and subtidal habitats of the estuary are broadly subject to natural successional change, although shellfisheries and dredging are a current concern. Threats to the estuary's conservation come from its industrialised shorelines on the Welsh side and the impact of adjacent historic industrial use. These include land contamination from chemical and steel manufacture and localised water quality problems. Remediation works are being undertaken. Contemporary issues relate to dock development and navigational dredging, coastal defence works and their impact on coastal process, regulation of shellfisheries, and the recreational use of sand dunes and saltmarshes.
3.11.11 The Dee is a large funnel-shaped sheltered estuary and is one of the top five estuaries in the UK for wintering and passage waterfowl populations. The estuary supports internationally important numbers of waterfowl and waders. The estuary is an accreting system and the extent of saltmarsh continues to expand as the estuary seeks to achieve a new equilibrium situation following large-scale historical land-claim at the head of the estuary which commenced in the 1730s. Nevertheless, the estuary still supports extensive areas of intertidal sand and mudflats as well as saltmarsh. Where land-claim has not occurred, the saltmarshes grade into transitional brackish and freshwater swamp vegetation, on the upper shore. The site includes the three sandstone islands of Hilbre with their important cliff vegetation and maritime heathland/grassland. The site also includes an
8 TP PT The Ramsar citation sheet identifies the waterfowl population as 74,230 using slightly more recent data (5 year peak mean 1998/99-2002/2003). However, this is still more than the 20,000 needed for consideration as being internationally important.
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assemblage of nationally scarce plants and the sandhill rustic moth Luperina nickerlii gueneei, a British Red Data Book species. The two shorelines of the estuary show a marked contrast between the industrialised usage of the coastal belt in Wales and residential and recreational usage in England.
3.11.12 The environmental pressures upon the Dee Estuary SAC, SPA & Ramsar site are mainly:
• Overgrazing of ungrazed/little grazed saltmarsh; • Certain recreational activities in sensitive areas at sensitive times such as shellfishing (in terms of loss of material from the food chain) and dog walking (in terms of disturbance of waterfowl) • Water quality threats from ex-industrial usage and agriculture; • Physical loss and alteration of coastal processes due to navigational dredging; • ‘coastal squeeze’ from land reclamation and coastal flood defences and drainage used in order to develop coastal land, and from sea level rise; • Introduction of non-native species; and • Risk of excessive abstraction resulting in a decrease in freshwater flows into the estuary, reducing drinking and bathing habitat for birds and increasing the salinity in localised areas.
Pathways linking St. Helens with Potential Effects upon the Site
3.11.13 The River Dee provides St Helens with approximately 75% of its public water supply. The River Dee flows into the Dee Estuary which is also designated as an SAC. As such, excessive abstraction from the Dee to meet the needs of additional housing in St Helens could reduce freshwater flows into the Dee Estuary to such a degree as to damage the interest features of that site through an increase in salinity. 3.12 Recreational Disturbance as a Pathway
3.12.1 Five of the European sites assessed are potentially affected by disturbance to wildlife or habitats as a result of increased recreational pressure, in turn arising from increased housing and thus population. These are:
• Liverpool Bay pSPA and pRamsar site, • Manchester Mosses SAC; • Mersey Estuary SPA and Ramsar site, • Mersey Narrows and North Wirral Foreshore pSPA and pRamsar site; and • Ribble and Alt Estuaries SPA and Ramsar site.
3.12.2 Recreational use of a site has the potential to:
• Cause disturbance to sensitive species, particularly ground-nesting birds such as woodlark and nightjar, and wintering wildfowl; • Prevent appropriate management or exacerbate existing management difficulties; • Cause damage through erosion; and • Cause eutrophication as a result of dog excrement.
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3.12.3 Different types of European sites (e.g. heathland, chalk grassland, estuarine) are subject to different types of recreational pressures and have different vulnerabilities. Studies across a range of species have shown that the effects from disturbance can be complex.
3.12.4 Wildlife at estuarine SPA/SACs can be affected by disturbance from pedestrian access along the banks and from personal pleasure craft such as power boats and windsurfers.
3.12.5 English Nature (2002) notes that estuaries, sand dunes and shingle banks are all habitat types that support ground nesting birds that are vulnerable to disturbance by recreational walkers, especially those with free roaming dogs. For instance, a study of oystercatchers in the Exe Estuary carried out by the Centre for Ecology and Hydrology showed that numerous small disturbances are more of a threat to species health than fewer large disturbances, and it is in winter when feeding conditions are hardest that disturbance will have a serious negative impact on the bird population (West et al., 2002). Disturbance and trampling by humans and dogs is also a key threat to bird species of shingle banks such as Dungeness SPA/SAC which is a breeding site for Mediterranean gulls, common terns and little terns (English Nature, 2002).
3.12.6 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 (Underhill-Day, 2005). 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 are particularly sensitive to the fertilising effect of inputs of phosphates, nitrogen and potassium from dog faeces (Shaw, Lankey and Hollingham, 1995).
3.12.7 Underhill-Day (2005) 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%. Even at a ‘famous’ site like the New Forest, a greater proportion of visitors were residents walking their dogs (42%) than day visitors (20%) or holiday makers (14%) (University of Portsmouth Enterprise Limited, 1996, in Underhill-Day, 2005).
3.12.8 However all 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. Gill et al. (2001) have shown that, in some cases, the most easily disturbed birds simply move to other feeding sites, whilst others may remain and suffer greater impacts on their population (Gill et al., 2001). A recent literature review undertaken for the RSPB (Woodfield and Langston, 2004) also urges caution when extrapolating the results of one disturbance study because the responses differ from species to 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 sites.
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3.12.9 There have been several papers published that empirically demonstrate that damage to vegetation in habitats can also be caused in a mechanical sense by trampling and compression from vehicles, walkers, horses and cyclists:
9 • Wilson & Seney (1994)TPF F PT 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.
10 • Cole et al (1995a, b)TPF F PT conducted experimental off-track trampling in 18 closed forest, dwarf scrub and meadow & 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, 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.
11 • Cole (1995c)TPF F PT 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.
12 • Cole & Spildie (1998)TPF FPT 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.
9 TP PT 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 10 TP PT 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 11 TP PT 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. 12 TP PT 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
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3.12.10 In recent years, access to the countryside has been promoted as a result of the Countryside and Rights of Way Act 2000. Access land created under the Act includes land within European sites.
3.12.11 Data on visitor numbers and recreational pressure at European sites are available only sporadically and for a few sites. We have not identified any predictions of future visitor numbers at European sites. 3.13 Water Flows and Quality as a Pathway
3.13.1 Four of the European sites assessed are potentially affected by waterborne pollution into the Mersey Estuary from the Sankey Brook, in turn arising from pollution into its catchment. These are:
• Liverpool Bay pSPA and pRamsar site, • Mersey Estuary SPA and Ramsar site, • Mersey Narrows and North Wirral Foreshore pSPA and pRamsar site, and • Ribble and Alt Estuaries SPA and Ramsar site.
3.13.2 Additionally, the Mersey Estuary SPA and Ramsar site is potentially affected by increased modification of watercourses or abstraction from surface waters within the Sankey catchment.
3.13.3 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 which 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. Some male fish in UK rivers, for example, have demonstrated the physiological symptoms expected of oestrogen-mimicking chemicals - symptoms which have been linked to exposure to female hormones (synthetic and natural) in sewage effluent.
3.13.4 Water quality may be indirectly altered as a result of urbanisation, for instance through:
• Trans-basin water transfers introducing water of different chemical characteristics.
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• Pollution through water runoff from hard surfaces carrying oils, heavy metals and/or de-icing compounds. • Waste-water treatment effluent introducing water of different chemical characteristics. • Pollution from waste-water treatment effluent carrying increased pollutant loads. • Waste-water effluent carrying increased nutrient load, increasing the risk of eutrophication. • Diffuse pollution resulting from land management and development.
3.13.5 Through its Review of Consents process, the Environment Agency has identified diffuse pollution to be a major factor in causing unfavourable conservation status of European sites, including rivers, wetlands and estuaries/maritime sites.
The Sankey Catchment
3.13.6 Appendix 5 includes illustrations of the Sankey Brook and Mersey River catchments. St. Helens lies almost entirely within the Sankey catchment, which in 2 turn is part of the Mersey catchment, being approximately 179kmP P or about 3.8% of the Mersey catchment’s total area. There are approximately 260,000 people residing within the Sankey catchment, most of these in St. Helens (population 178,000), and the remainder in the boroughs of Wigan, Warrington, Halton, Knowsley and West Lancashire.
3.13.7 The Sankey Brook, which originates in and flows through St. Helens generally from 3 northwest to southeast, is reported to have an average discharge rate of 2.6 mP /sP 3 (Dunbar Ed., 2002), which is 10% of the River Mersey discharge rate of 25 mP /sP (Waniek, 2006), and approximately 1.2% of the total river and tidal water volumes, 3 tidal being over 200 mP /sP (Waniek, 2006).
3.13.8 Dunbar (Ed., 2002, p.11) reports that there are public, agricultural and industrial abstractions within the Sankey catchment, including ‘12 licensed abstractions… for a variety of industrial uses’ and ’17 licenses authorising abstraction for spray irrigation… mainly from surface water sources’ (5 for golf courses, 12 for crops).
3.13.9 Within St. Helens, the following activities have impacts upon water resources and quality within the Sankey Brook catchment:
• ‘intensive farming within the catchment, both upstream and downstream of St. Helens’; • effluent disposal in the form of ‘treated domestic and industrial effluent from water company sewage treatment works (the St. Helens plant is by far the largest), on-site treated effluent from industrial plants, and combined sewer overflows’; • ‘pollution… as a consequence of urban runoff’; • ‘flow from the combined sewer outfalls during storms’; • ‘runoff from historically contaminated land’; and • ‘spoil tips’ (Dunbar Ed., 2002, p.11).
3.13.10 Finally, the St. Helens Canal is a modified water body opened in 1757 and abandoned in 1963, of which the remaining sections (those not filled in) parallel sections of the Sankey Brook, and are in fact contiguous. Dunbar (Ed., 2002, p.30)
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concludes that ‘poor water quality makes it difficult to make an assessment of the ecological impacts of the modifications. Thus more expert opinion is required, and also there is greater uncertainty over whether given water quality improvement and 13 habitat improvement will lead to achievement of GESTPF FPT. This highlights the need for a risk-based assessment approach that includes some level of uncertainty.’ 3.14 Water Abstraction as a Pathway
3.14.1 Despite being situated in England, much of the potable water supply for St Helens derives from Welsh sources. St Helens lies within United Utilities Integrated Resource Zone which serves 6.5 million people in south Cumbria, Lancashire, Greater Manchester, Merseyside and most of Cheshire. The Integrated Zone is supplied with around 1800 Ml/d of drinking water, of which about 500 Ml/d comes from water sources in Wales, about 600 Ml/d comes from sources in Cumbria, and the rest from sources in other parts of North West England. It constitutes a large integrated supply network that enables substantial flexibility in distributing supplies within the zone.
3.14.2 According to United Utilities, the proportions vary quite significantly depending on the resource circumstances, but the current estimated proportions for St Helen’s are:
• 75% from the River Dee; • 20% from Lake Vyrnwy; and 14 • 5% from Rivington Reservoirs in LancashireTPF FPT.
3.14.3 The fact that the current proportions are as above does not of course mean that the future supply situation will necessarily remain the same, particularly given the fluidity in water transfer pathways within the Integrated Supply Zone, but it is likely that a significant proportion of potable water supplied to St. Helens will continue to derive from Welsh sources.
3.14.4 The River Dee is a Special Area of Conservation and flows into the Dee Estuary which is also designated as an SAC as well as an SPA and Ramsar site. Four water companies abstract from sources that affect the River Dee including United Utilities (UU), Dee Water Valley, Welsh Water and Severn Trent Water. Excessive abstraction from the Dee could therefore result in sufficient drawdown of water to damage the interest features of the River Dee and Bala Lake SAC (through desiccation, fish entrainment or a deterioration in water quality due to the lower proportion of freshwater to sediment) and in turn reduce freshwater flows into the Dee Estuary to such a degree as to damage the interest features of that site through an increase in salinity. As such, consideration needs to be given to the indirect impacts that may arise from further development in St. Helens upon these European sites, particularly when considered in combination with the other authorities within the Integrated Supply Zone and large parts of north east Wales and the West Midlands which derive much of their potable water supply from the same sources.
13 TP PT Good Ecological Status, as defined by the Water Framework Directive 14 TP PT Personal communication on 16/03/09 from David Hardman at United Utilities to Gillian Pinder at St Helens Council
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3.15 Air Quality as a Pathway
3.15.1 Only the Manchester Mosses SAC has been identified as potentially affected by changes to air quality as a result of increased population/housing and increased traffic.
3.15.2 Many European qualifying habitats are known to be under stress partly as a result of poor air quality. This is a difficult issue to address at a regional level. Some pollutants act locally, whilst others are transported far from their source to act at a regional, national or even trans-frontier level.
3.15.3 The following anthropogenic air pollutants are of greatest importance for their adverse effect upon ecological resources:
• Oxides of Nitrogen (NOBx)B - Oxides of nitrogen are formed during high temperature combustion processes from the oxidation of nitrogen in the air.
The principal source of oxides of nitrogen – NO and NOB2 B - is road traffic,
which is responsible for approximately half the emissions in Europe. NOBx B concentrations are therefore greatest in urban areas where traffic is heaviest. 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. High NOBx B levels can also have direct effects on plants.
• Ammonia (NH3B )B – This is probably the major source of nitrogen deposition to many wildlife sites, and is mainly agricultural or industrial in origin. Reduced
N in the form of NH3B B gas, which is produced directly by cars fitted with three- way catalysts, may be a significant N input to vegetation at shorter distances from the road (up to approximately 10m).
• Dust (e.g. PM10B )B – on tarmac roads this is generally not an issue, but if the road is subject to heavy vehicle movements substantial quantities of dust can be deposited on the vegetation lining the road. If present in sufficient quantities dust can smother vegetation, preventing light penetration to the chloroplasts and blocking stomata thus interrupting photosynthesis and transpiration. In prolonged cases, death can result.
• Sulphur dioxide (SO2B )B – this is an acidic gas that combines with water vapour in the atmosphere to produce acid rain. Both wet and dry depositions have been implicated in the damage and destruction of vegetation and in the
degradation of soils and watercourses. Major SO2B B problems now only tend to occur in cities in which coal is still widely used for domestic heating, in heavy industry and in power stations.
• Low-level ozone (O3B )B – this is unlike the other pollutants mentioned, in that it is not emitted directly into the atmosphere, but is a secondary pollutant
produced by a complex reaction between nitrogen dioxide (NO2B ),B hydrocarbons and sunlight. Unlike the other pollutants, it cannot therefore be directly related to increases in housing, traffic etc. Although peak levels of ozone are generally reducing, annual average levels are generally increasing.
3.15.4 The most acute impacts of NOBx B and SO2B B take placed close to where they are emitted, but individual sources of pollution will also contribute to an increase in the
general background levels of pollutants at a wider scale, as small amounts of NOBx B
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and other pollutants from the pollution source are dispersed more widely by the prevailing winds.
3.15.5 Despite the general association with NO2B ,B ozone levels are not as high in urban
areas (where high levels of NO2B B are emitted) as in rural areas. This is largely due to the long-range nature of this pollutant, which is sufficiently great that the source of emission and location of deposition often cross national boundaries. As such, low- level ozone can only be practically addressed at the national and international level.
3.15.6 The main sources of NOxB B in the UK are (Dore et al., 2003):
• Road and other transport (approximately 47%, rising in urban areas); • Public power generation using fossil fuels (22%). • Combustion in industrial processes (14%). • Domestic and commercial sources (4%), e.g. commercial boilers in schools, hospitals etc.
3.15.7 Therefore, when considering the ecologically relevant impacts of the Local
Development Framework, by far the largest contribution to NOBxB (92%) will generally be made by the associated road traffic.
3.15.8 The main sources of SO2B B are (Dore et al., 2003):
• Public power generation using fossil fuels (69%). • Combustion in industrial processes (13%). • Domestic and commercial sources (4%). • Non-road transport sources (3%) • Road transport (less than 1%).
3.15.9 The vast majority of SO2B B comes from power generation. Combustion associated with industrial processes is of importance, but plays a lesser role, while road transport is of negligible importance.
3.15.10 The following air pollution limit values apply for the protection of vegetation and ecosystems:
-3 • NOBx:B World Health Organisation 30 μgmP P annual average; EU Air Quality -3 Framework Directive 30 μgmP P annual average away from areas close to main roads, built up areas or major industrial sites; Natural England policy in agreement with the Environment Agency in their Review of Consents process -3 is that the 30 μgmP P threshold should apply to all designated sites, due to the sensitivity of the habitats within the sites. -3 • SO2B :B EU 20μgmP P annual mean and winter mean (1 Oct – 31 March)
BackgroundU Trends
3.15.11 Guidance exists to address the potential effects of local pollution, for which the most significant contributors are power generators and other industrial processes,
and traffic. Laxen and Wilson (2002) suggests that NO2B B emissions from motorways essentially reach background levels within 200m of the roadside. Air pollution at many European sites is already believed to be having an adverse effect. Tables 5
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and 6 show the degree to which Manchester Mosses SAC is affected by atmospheric nitrogen deposition.
Table 5: Atmospheric nitrogen deposition for 1999/2000 compared with critical load at Holcroft Moss*
Is atmospheric Minimum Nitrogen nitrogen Grid critical Deposition/ Site Habitat Exceedance deposition reference Load / Kg Kg N/ha/ currently a N/ha/year year problem? Manchester SJ683928 Raised 5 21 Current Yes Mosses SAC and deposition is (Holcroft blanket more than four Moss) bogs times the minimum critical load. Source: Based on information provided by the UK Air Pollution Information System (www.apis.ac.uk). * the closest part of Manchester Mosses SAC to the M62
Table 6: Atmospheric sulphur dioxide concentrations for 1999/2000 compared with critical load at Holcroft Moss*
Is sulphur Critical SOB B Grid 2 dioxide Site Habitat Level / Concentration Exceedance reference 3 3 currently a µg/mP P / µg/mP P problem? Manchester SJ683928 Raised 20 4.9 Current No Mosses SAC and concentration is (Holcroft blanket 25% of the Moss) bogs critical level.
Source: Based on information provided by the UK Air Pollution Information System (HTUwww.apis.ac.uk).UTH * the closest part of Manchester Mosses SAC to the M62
3.15.12 The tables have limitations:
• We understand that they are based on six-year-old data. Air quality has generally improved since then. It is expected that, generally, air quality will continue to improve until roughly 2010-2015 due to improvements in (especially) vehicle technology, after which increasing transport demand may cause these positive trends to reverse. 15 • Although APISTPF FPT provides a full explanation of the sources that it used to determine critical loads, some of these may be subject to debate. • The table does not consider the critical loads for individual species, just for the habitats at the European sites.
3.15.13 Nevertheless, it is clear from Table 5 that nitrogen deposition is already a problem within Manchester Mosses SAC and it is not unreasonable to attribute this to the proximity of Holcroft Moss to the M62. Indeed, Environment Agency modelling data suggest that 40% of the nitrogen deposited on this site arises from road transport. In contrast, the site is not suffering from sulphur dioxide deposition, presumably
15 TP PT The UK Air Pollution Information System
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because road traffic contributes very little to atmospheric concentrations of sulphur dioxide.
3.15.14 The actual scale of heavy vehicle movement associated with mineral extraction facilities is entirely dependent upon both the type and scale of the facility. It is therefore impossible to give meaningful “typical” values for minerals sites. The only general conclusion that can be safely drawn is that all new mineral extraction operations are likely to result in a local increase in vehicle movements. It is also true that the distance vehicles travel may be as important as the numbers or type of vehicle in contributing to deteriorating atmospheric deposition of European sites, if the route leads the traffic within close proximity of European sites. 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” (DfT, 2004).
3.15.15 Sulphur dioxide concentrations are overwhelmingly influenced by the output of power stations and industrial processes that result in the combustion of coal and oil. None of these activities will be associated with developments under the LDF.
3.15.16 Low-level ozone is a problematic pollutant to evaluate, in that it cannot be practically assessed or avoided at anything less than a national scale, due to the complex nature of its relationship to increases in traffic, housing etc. and its trans- national character. We have therefore been unable to consider it within this assessment.
3.15.17 Many sources of atmospheric pollutants will have an effect on ecological resources at short range, being deposited close to the point of emission. However a proportion of this pollution will also have a long-range effect through being carried a greater distance and will contribute to a general deterioration in air quality throughout St. Helens and potentially further afield.
3.15.18 In July 2006, Natural England advised Runnymede Borough Council that their LDF ‘can only be concerned with locally emitted and short range locally acting pollutants’. Runnymede Council had previously suggested that as many European habitats are currently in unfavourable condition (partly) as a consequence of air pollution, then any development that resulted in any increase in pollution (taken at its extreme as only one more car journey) would be an adverse effect.
3.15.19 The implication of Natural England’s advice, if it can be applied to the St. Helen’s Core Strategy, is that any long-range contribution made to ‘background’
concentrations of NOBxB or other atmospheric pollutants by the development set out in the LDF, is outside the remit of the Habitat Regulations Assessment for the LDF. The issue of ‘long-range’ pollution will therefore not be considered further in this assessment.
3.15.20 Only one specific pathway has therefore been identified through which development within St. Helens could lead to significant effects upon the Manchester Mosses SAC - increased deposition of atmospheric nitrogen. Since St. Helens is situated approximately 8 km from the site, this will mainly be due to the increased population and increased travel by car (or other mode) along routes within 200m of the SAC, of which by far the most significant is the M62.
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3.16 Pathways Linking Minerals Development with European Sites
3.16.1 The impacts of minerals development can be slightly different from those relating to other Core Strategy policies and as such the background to the air quality and water resource/quality issues are discussed below.
Dust
3.16.2 Mineral extraction sites can contribute substantially to the atmospheric pollution load through emission of oxides of nitrogen associated with quarry traffic etc.; traffic being responsible for approximately half the emissions in Europe (Dore et al., 2005). Therefore, when considering the ecologically relevant impacts of minerals extraction under Policy CR1, by far the largest contribution to NOx will generally be made by the associated road traffic. This has been covered in the preceding section, but dust is a potential air quality impact from minerals development that also requires consideration.
3.16.3 Mineral extraction sites may also generate quantities of dust. Research carried out by Newcastle University found that a small increase in particles of less than ten micron diameter from opencast mine sites was not due to the release of coal particles but was more likely due to dust associated with earth moving and excavation, and thus is applicable to all excavation sites. An assessment framework covering areas up to 1km from such sites was proposed to determine potential impacts. Effects of dust will depend on the prevailing wind direction and the transport distance is related to particle size; large particles (>30um) will mostly deposit within 100m of the source, intermediate particles (10-30um) are likely to travel up to 200 - 500m. Smaller particles (<10um) can travel up to 1km from the source. If present in sufficient quantities dust can smother vegetation, preventing light penetration to the chloroplasts and blocking stomata thus interrupting photosynthesis and transpiration. In prolonged cases, death can result. As there are no European protected sites within the area covered by St Helens Core Strategy, the emission of dust is not a significant concern with regard to European sites.
Drawdown of flows and water quality
3.16.4 Pollution through water runoff from mineral sites may occur from hard surfaces carrying minerals, oils, or heavy metals. Mineral run-off also has potential to affect water flow and sedimentation patterns in nearby water courses. While these effects can be dispersed throughout the downstream water catchment, they will be most visibly manifested within tens of metres to a few hundred metres of the site. Discharges of leachate from minerals sites can add ammonia, other nutrients and chemical pollutants to surface water bodies. Leachate can also penetrate groundwater. Leachate can escape from landfill sites by leakage through a barrier / containment system, break out through a cap, or overtopping containment.
3.16.5 In addition, dewatering of mineral workings that lie below the water table can result in drawdown of the water table and a reduction in locally available water – these can have a deleterious effect on hydrologically sensitive sites within close proximity to mine or quarry workings. However, there are no such sites within the vicinity of
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the two safeguarded minerals areas in St Helens and therefore this particular matter can be screened out; it is therefore not discussed further in this report.
3.16.6 As such, the only impact associated with Policy CR1 that is scrutinised in the Appropriate Assessment is that of possible air quality effects on Manchester Mosses SAC.
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4 APPROPRIATE ASSESSMENT OF SUBMISSION CORE STRATEGY
4.1.1 The purpose of this section of the report is to evaluate the Core Strategy policies that were screened into the assessment against each European site and go on to discuss the mitigation that would be required in order to enable the authority to claim that the Core Strategy is unlikely to lead to significant adverse effects on European sites. Since this builds on work that has already been undertaken for the Preferred Options Core Strategy, this chapter is also the place in which we evaluate how recommendations that have been made in the past have been incorporated into the Submission Stage Core Strategy. 4.2 Liverpool Bay pSPA / pRamsar site
Recreational pressure
4.2.1 Appendix 3 provides a table of the general population of relevant species that either reside in or visit both St. Helens and Liverpool Bay pSPA. This table shows that the populations of these particular species within St. Helens are not significant relative to populations at Liverpool Bay pSPA, and thus any potential for harm to these birds within St. Helens could not lead to significant adverse effects upon the integrity of the pSPA or the achievement of its nature conservation objectives.
4.2.2 However, the following policies:
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens); and
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025).
4.2.3 May in the absence of mitigation or an appropriate policy framework lead to significant adverse effects upon Liverpool Bay pSPA and pRamsar site through increasing the quantum of residential development within St Helens and therefore within the catchment of Liverpool Bay and thereby increasing the recreational pressure to which the site will be subjected. When considered in combination with the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside) and the housing proposed across North East Wales during the same period, this would lead to significantly greater recreational pressure within the SPA and thus risk of disturbance to the sensitive wintering bird populations.
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Recommendations for Policy Changes
4.2.4 The Appropriate Assessment of the Preferred Options Core Strategy concluded that St Helens contribution to any adverse effects of increased recreational pressure upon Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA could not be mitigated or avoided by the provision of additional accessible natural terrestrial greenspace since all are coastal and estuarine in nature. Many impacts on these systems relate to waterborne activities and the provision of alternative sites is not possible.
4.2.5 It was therefore recommended that the Council should engage with other Merseyside authorities and Natural England to input into delivery of those actions of the Mersey Estuary Management Plan and other Estuary Management Plans that are linked to reducing the impacts of recreation, including wardening, fencing, signage and seasonal closures as considered appropriate by the Management Plan as it is revised and updated to account for changing patterns of visitor use. St Helens contribution should be commensurate with its population size, since St Helens can only be considered responsible for mitigating their contribution to an “in combination” effect. It was identified that a Developer Contributions Policy or similar could be used to secure St Helens contribution towards the actions of the Estuary Management Plan through imposing a levy upon developers to contribute to the management of the estuaries. However, whatever method is decided upon for funding local authority contributions must be agreed across the whole Merseyside area (in order to avoid putting some authorities at a disadvantage) and this report is therefore not the place to go into further details.
4.2.6 Engagement with the other Merseyside Authorities in a sub-region wide approach to managing recreational pressure on this network of coastal/estuarine sites through the various site Management Plans remains the only realistic measure by which recreational pressure on these sites can be controlled. Since St Helens has no direct influence over the management of these sites, as they lie outside her boundaries, the Borough’s contribution would still need to be a financial one. The 13% increase in housing to be delivered within St Helens doesn’t alter this mitigation measure but does (when considered cumulatively with the increased housing allocations across Merseyside) make the need to engage in such integrated pan-authority site management that much more essential. As such, we would recommend that a specific policy or statement within the Core Strategy should make a clear commitment on the part of St Helens Council to collaborate with the other Merseyside Authorities to manage, influence and control visitor pressure on the sensitive Liverpool Bay and Merseyside coast as far as possible and to support the delivery of the site management plans (including access management) for Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA.
Council Response to Recommendations
4.2.7 The Council have addressed this issue by proposing collaborative working with Merseyside authorities generally and the creation of a post to assess the in combination effects of the Core Strategies across the sub-region.
4.2.8 It is therefore considered that the Council have taken the necessary steps to ensure that St Helen’s contribution to significant ‘in combination’ impacts on European sites related to recreational disturbance effects will be adequately
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mitigated and managed such that no adverse effects are likely to result from the Core Strategy development.
Water quality
4.2.9 In terms of the potential for water pollution into the Sankey Brook catchment to harm the Liverpool Bay pSPA, this entirely maritime site is linked directly to the waters of the Irish Sea. In terms of indirect effects, the riverine water quality from estuaries that feed into the Irish Sea is a concern – both as a result of increases in agricultural effluent and of the wide variety of inorganic chemicals and organic compounds from waste water (Wildlife Trust, 2006).
4.2.10 It is considered that (in the absence of any mitigation) the following policies:
• CH1 – Housing Provision
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens); and
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025); and
• CE1A (Economic Development) - 88.5 ha of land for economic development between 2008 and 2025
4.2.11 Would be likely to lead to significant adverse effects upon the SPA. In the case of most of these policies this would be through the increased pressure that would be placed upon wastewater treatment infrastructure that would discharge treated effluent to the Mersey Estuary; this effluent would ultimately reach Liverpool Bay along with that from many of the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside) and the housing proposed in north-east Wales over the same period. This increased pressure could result in deterioration in water quality simply through the increased volume of treated effluent (which will contain increased nutrient loading) or, if the Sewage Treatment Works in question is at or near capacity, in deterioration in the level of treatment that discharged effluent receives. Increased discharge of treated effluent to rivers that drain to the estuary could also affect water flows and sediment patterns within the Liverpool Bay pSPA/pRamsar site.
4.2.12 The Environment Agency’s consent regime already helps to ensure that water quality is maintained, particularly at European sites, and the Water Framework Directive will further support this. In most cases, this should ensure that the integrity of European sites is not affected. However, even with the introduction of best available technology (BAT) to reduce nitrogen levels to a minimum in
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wastewater treatment effluent, the increase in discharge volumes resulting from the growth described in the LDF may contribute to a level of eutrophication that may affect the integrity of the Mersey Estuary.
4.2.13 However, correspondence with the Council indicates that they have checked with United Utilities that the relevant STW catchments still have physical/environmental capacity for the delivery of housing without adverse effects on European sites.
4.2.14 Since the Preferred Options, Policy CR1 (Minerals) has been introduced; minerals development would have the potential to affect the site through the discharge of dewatering products with a high sediment loading, dependent on capacity and location of minerals extraction sites. However this policy is specifically intended to ensure that minerals sites have no unacceptable impact on the natural environment by making that a requirement of any future minerals extraction.
4.2.15 As part of the Submission Stage Core Strategy the Council have inserted a policy (Infrastructure) that includes the commitment that the Council will ‘ensuring that the LDF process and Infrastructure Providers service planning is aligned’. This creates a policy framework within which the delivery of development will be phased in order to ensure that it only takes place once any new water treatment infrastructure or appropriate retro-fitted technology (e.g. nitrate stripping) necessary to service the development while avoiding an adverse effect on European sites is in place.
4.2.16 Furthermore, although not referenced within the Core Strategy the local authority have also committed to producing a Water Cycle Study which will indicate how this will be determined and delivered through interaction with other authorities (United Utilities, the Environment Agency etc). There are ongoing discussions and it is likely this will be produced with Halton and Warrington probably over the next year.
Recommendations for changes
4.2.17 The Appropriate Assessment of the Proposed Changes Core Strategy noted that the draft St Helen’s Design Guide SPD made the following statements regarding sustainable usage of water:
• ‘Promote environmentally sustainable development (maximise resource efficiency, including sustainable drainage and waste management, minimise impacts on the natural environment and promote biodiversity)· • ‘Considerations should be given to… water and flood management, including the use of sustainable urban drainage systems (SuDS)’· • ‘Materials should also be chosen for their contribution towards sustainable drainage where the context is appropriate (e.g. green roofing and porous surfaces)’· • ‘Consider potential secondary risks that may arise ‘off site’ from development (e.g. impacts on adjacent wildlife sites by increased public use, changes to drainage and pollution)’· • ‘Consideration should be given to use of porous surfaces as part of the design for sustainable drainage systems’
4.2.18 However, the Appropriate Assessment recommended that the St Helen’s Core Strategy demonstrates that the Council is doing everything reasonably possible to husband water resources within the borough. This could be further achieved by the incorporation of more specific statements with the Design Guide that:
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• State that Appropriate Assessment should be carried out on new developments, where sewage or run-off from proposed developments could have a significant impact on the integrity of the European site. • Promote and encourage the expansion of agri-environment schemes to reduce diffuse pollution, which although not a direct impact of the St Helen’s Plan, is likely to have an important ‘in combination’ effect.
4.2.19 As a final measure, a policy option should be incorporated that states that: “obligations will be required where necessary in planning terms to make the development acceptable and will cover… securing contributions towards mitigation measures for any adverse impact the development may have on the locality… The range of matters to be covered includes among other things: … Drainage and flood prevention measures… protection to biodiversity, geodiversity, landscape….”. This policy could be used to ensure that developers put measures in place in order to avoid a significant water quality impact upon Liverpool Bay pSPA or the Mersey Estuary SPA.
4.2.20 In the intervening period various changes have been made to national policy on the issue of sustainable water use, while the 13% increase in housing levels to be delivered in the Borough makes high water quality standards essential. Controlling water quality still lies mainly in the hands of the water companies and the Environment Agency.
Council Response to Recommendations
4.2.21 The Council have noted that they accept all the above recommendations but do not feel that the Design Guide is the appropriate place for them and instead propose the inclusion of these points within the Development Management DPD to follow after the adoption of the Core Strategy. This would be an acceptable alternative. It is concluded that these measures, together, would avoid St Helen’s contribution to significant ‘in combination’ impacts on European sites related to water quality and erosion effects. 4.3 Manchester Mosses SAC
Air quality
4.3.1 Due to the strategic nature of the LDF, detailed site/project-level information is not available, and it has therefore been necessary to assume that the effects of
increases in NOBx B (and thus nitrogen deposition) on European sites that are located within 200m of major roads will be significant. At this stage, future traffic projections are not available for the M62 as it runs through or close to Manchester Mosses SAC.
4.3.2 The St. Helens LDF alone is unlikely to lead to significant adverse effects on the SAC given the nature of development proposed by the LDF, the distance between the St. Helens boundary and the SAC and expert knowledge and experience on rates of pollution dispersal. However, Holcroft Moss SSSI (one of the three SSSIs within the Manchester Mosses SAC) does lie immediately adjacent to the M62.
4.3.3 Policy CR1 covers the safeguarding of sites for minerals extraction within St. Helens. Two safeguarded areas are named within policy CR1. Both could
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contribute to an increase in east-west traffic that could pass along the M62 as it crosses within 200m of Manchester Mosses SAC. This is most likely to occur with vehicles associated with Bold Heath; however an existing sand quarry already operates on this site, and so traffic movements already exist. Once a Development Management DPD and any further site allocations are available, then it will be possible to definitively scope out the effects of air quality reduction on Manchester Mosses SAC (or to identify any as yet unforeseen impacts requiring mitigation). Given the distance between the currently safeguarded areas, and Manchester Mosses SAC, it can still be concluded that the minerals sites as identified within the Core Strategy is unlikely to lead to significant adverse effects on Manchester Mosses SAC.
4.3.4 Manchester Mosses SAC (Holcroft Moss) is adjacent to the Liverpool to Manchester rail line and to the former Parkside colliery at which an inter-modal rail freight terminal will be constructed, as described in Issue CAS 3.1 (Development of an Inter-Modal Freight Terminal).
4.3.5 Throughout the HRA work informing the development of the St Helens Core Strategy we have generally worked on the basis that an increase in rail freight means the potential for a decrease in HGV's and is therefore a positive step for air quality. The Department of Transport have made the following comment on air quality issues as they relate to the transfer of freight movements from road to rail, which supports the approach we have taken: "It should be noted that in terms of total transport emissions, rail transport accounts for less than 1% of the total. Therefore, even with the most rail orientated transport options, perhaps doubling the rail kilometres, the potential for any significant impact on emissions will lie mainly with the saving in emissions from road transport brought about by modal transfer, rather than those generated by rail. Hence, it is suggested that emissions from rail sources can be scoped out in most cases." (Department of Transport, 2004).
4.3.6 We have therefore scoped out air quality impacts on Manchester Mosses SAC due to an increase in rail freight movements as a result of the Inter-Modal Freight Terminal. The construction of a freight terminal may increase freight vehicle movements into St Helens along the M62 (although it could equally reduce them as its close proximity to J23 of the M6 could result in alternative routes such as the A580). In addition the following policies:
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens);
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025); and
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• CE1A (Economic Development) - 88.5 ha of land for economic development between 2008 and 2025
4.3.7 Are considered likely to lead to significant adverse effects upon Manchester Mosses SAC, when considered in combination with the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside), as they will lead to greater usage of the M62 and therefore increased deposition of pollutants on this sensitive site. Any impact on the Manchester Mosses SAC will be particularly severe as the rate of nitrogen deposition within the SAC is more than four times the minimum critical load.
4.3.8 However, to counterbalance these policies there is also policy CP2 (Creating an Accessible St Helens) which details a series of measures whereby vehicle use in St Helens will be reduced and rationalised including (with regard to private car use):
• promoting development in sustainable locations where it is accessible by means of transport other than the car; and • the use of public transport or other sustainable transport systems by providing suitable infrastructure and an integrated public transport network • ensuring development will not prejudice improved rail links to Manchester and Liverpool
4.3.9 With regard to commercial and freight movements the policy details the following measures to reduce freight movement by road:
• requiring certain commercial developments to prepare travel plans; • requiring developers to submit transport assessments; • development which generates significant movement of freight to be located on sites which can be served by rail or where rail facilities can be provided as part of development; and • supporting initiatives to reduce congestion, air pollution and noise on key routes.
4.3.10 Moreover Policy CAS 3.2 states that one of the criteria for determining whether the Strategic Rail Freight Interchange will go ahead in practice is to be the incorporation of ‘measures for the … minimisation of environmental impacts… including … air quality [and] biodiversity’. The policy goes on to state that if an appropriate proposal for a Strategic Rail Freight Interchange cannot be formulated the future of the site will be reviewed.
4.3.11 When all of these measures are considered together it is considered that the Council has done everything within its power to offset the increase in vehicle usage as a result of the new development delivered by the Core Strategy and reduce short-distance vehicle movements, and therefore contribute to some reduction in traffic movements on the M62. We have therefore concluded that the Core Strategy when considered as a whole will not lead to significant adverse effects on Manchester Mosses SAC.
Recreational pressure
4.3.12 In addition, this site has been identified as being susceptible to damage from recreational activities which may be exacerbated and be likely to lead to significant
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adverse effects through the increased population associated with development facilitated by the following policies:
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens); and
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025).
4.3.13 Avoidance of recreational impacts at European sites involves location of new development away from such sites. Mitigation involves a mix of access management, habitat management and provision of alternative recreational space.
4.3.14 Provision of alternative recreational space can help to attract recreational users away from sensitive European sites, and reduce additional pressure on them. Some species for which European sites have been designated are particularly sensitive to dogs, and many dog walkers may be happy to be diverted to other, less sensitive, sites. However the location and type of alternative space must be attractive for users to be effective; some types of recreational use may be less amenable to attempts at relocation; and some European sites attract people from beyond a local area, and those people are unlikely to be easily diverted to alternative recreational space.
4.3.15 The Appropriate Assessment of the Preferred Options stage Core Strategy concluded that a series of policies to create major new areas of accessible natural greenspace within St Helens itself would ensure that an adverse effect was mitigated. Most significantly, Policy CQL1 (Green Infrastructure) identified a series of sites that were being enhanced for additional open space provision. At the time of the Preferred Options Core Strategy Appropriate Assessment, four alternative areas of new open space (St. Helens Forest Park, The Stanley Bank, Carr Mill
Dam and Billinge Hill Corridor) had been enhanced andU U delivered and others were in process of delivery. Furthermore, Policy CQL 2 (Trees and Woodland) stated that the local authority would identify and promote the development of the St Helens Forest, which would form a major alternative area of open space, much closer to St Helens that Manchester Mosses SAC.
4.3.16 The Submission Stage Core Strategy has allocated greater numbers of new dwellings, with increased potential for recreational impact on sites such as Manchester Mosses SAC. An increase in new housing requirement will also apply to other Councils within the region. The measures to deflect recreational use from this site have been revised but the following policies do still apply:
• Policy CAS1.1 promotes enhancement of green space within St Helen’s core area.
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• Policy CAS2 promotes enhancement of St. Helens canal and the town centre. • Policy CAS4 promotes enhancement of green infrastructure in Haydock. • Policy CAS5 promotes access to rural St.Helens, and still includes specific improvement schemes. • Policy CP1 includes requirement for new development to provide open space, and enhance green infrastructure. • Policy CQL1 now requires new development to “contribute to…new Green Infrastructure through planning obligations,” and to “contribute to accessibility of additional Green Infrastructure.” • Policy CQL3 will ensure the designation of further Local Nature Reserves.
4.3.17 Despite the fact that Policy CQL1 no longer includes defined open space provision targets, nor promises to “identify and protect all sites of a minimum size of 0.4ha…” as it did in the Preferred Options, it is understood that these provision targets will nonetheless still be applied through their incorporation into other SPD’s.
4.3.18 Due to the limitations of the assessment tools and data available at this time (and in particular the inability to quantify the number of residents of each allocated site that will be making use of the European sites in question and what proportion of the total cumulative load this represents), coupled with the need for any standards within the Core Strategy to be generally applicable (it not being possible to devise a unique policy or standard for each allocated site), it is not possible for the Core Strategy to specify an exact quantity of alternative natural greenspace that will need to be provided for individual developments in order to absorb recreational visitors to such an extent that they will not materially contribute towards recreational pressure on the European sites in question.
4.3.19 Natural England's more general Accessible Natural Greenspace Standards (ANGSt) provide a set of benchmarks for ensuring access to places of wildlife interest and were specifically developed to provide size and distance criteria to provide natural spaces that will contribute most towards sustainable use of recreational resources. While the criteria were not developed with the specific intention of mitigating for adverse impacts on European sites, they were intended to specify a level of semi-natural greenspace provision that would meet the needs of a development’s population.
4.3.20 In many cases natural greenspace provision to the ANG Standard should therefore serve to minimise the need for recreational resources further afield (i.e. European sites) to receive an unsustainably large influx of visitors provided that they are delivered within a timescale linked to that of the development and will fulfil a function similar to that of the European site in question (i.e. dog walking and appreciation of nature rather than more formal recreational activities). For these reasons, we have selected the Natural England ANG standards as the criterion for semi-natural greenspace provision that the Core Strategy should require developments to meet in order to ensure that sufficient recreational space is provided to minimise adverse effects on the identified European sites.
4.3.21 The core element of the ANG standard of provision is the delivery of accessible areas of natural greenspace of at least 2ha in size at a rate of 1ha/1000 population (it should be noted that St Helens own natural greenspace provision standard is 2ha/1000 population). St Helens intends to deliver 14,528 dwellings over the plan
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period, which assuming 2.2 occupants per dwelling would mean 31,962 residents. Using the ANG standard of provision therefore this would require St Helen’s to deliver 32ha of new accessible natural greenspace over the plan period. In order to draw users who might otherwise visit Manchester Mosses SAC, this greenspace would need to be provided closer to the key centres of development in St Helens than the Manchester Mosses is situated. Therefore, although the scale of housing provision within St Helens has increased by 13% since the Preferred Options to 14,528 dwellings, the scale of new accessible natural greenspace provision at the St. Helens Forest Park, The Stanley Bank, Carr Mill Dam and Billinge Hill Corridor would be likely to achieve more than the necessary level of provision to meet the ANG standard.
4.3.22 Although the prospective sites are not mentioned within the current version of policies CQL1 and CQL2, it is understood that they will still be delivered. As such, it is considered that the Council has incorporated sufficient measures into the Core Strategy to ensure that the greater recreational activity that will result from the delivery of new housing within the Borough will not be focussed on Manchester Mosses SPA to a damaging degree. As such it can still be concluded that the Core Strategy will not lead to significant adverse effects on the Manchester Mosses SAC. 4.4 Mersey Estuary SPA / Ramsar site
Water quality / Sedimentation
4.4.1 A conservation objective of the Mersey Estuary SPA is to maintain populations of qualifying species, and in turn to maintain a reference level of benthic invertebrate communities. These aquatic invertebrates are dependent upon good water quality, as well as appropriate patterns of erosion and deposition. Despite improvements in water quality, the diversity of invertebrates and populations of wading birds in recent years, The Marine Biological Association (2006) (involving English Nature, now Natural England) identifies a marked increase in British Trust for Ornithology (BTO) Alerts that necessitate investigation into possible links to changing water quality. Current issues include potential endocrine disruption as a result of sewage wastes.
4.4.2 Neither the effects of water pollution themselves nor the sources of effects are entirely understood. The Marine Biological Association (2006) makes clear that more research within the Mersey Estuary SPA needs to be conducted in order to establish whether or not adverse effects to the overall biological condition of the site are currently occurring. However, it is know that certain pollutants such as heavy metals (largely from the area’s industrial past) and alkylphenols (as a result of household and industrial detergents present in sewage) adversely affect invertebrates.
4.4.3 The Sankey Brook flowing from St. Helens, Wigan and Warrington represents approximately 10% of the riverine water flow of the Mersey Estuary. Although it has already been heavily modified, further modification or changes to peak flows, low flows, or average flow rate as a result of modification, abstraction or runoff could lead to significant alteration to erosion-deposition patterns on the Mersey Estuary. There is currently development pressure within its catchment arising from
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housing and employment growth in St. Helens, Wigan, Warrington, and to a lesser degree, Halton.
4.4.4 The Sankey Brook is currently a highly polluted watercourse. ‘Ongoing water quality impacts have arisen from contaminated land and Combined Sewer Overflows (CSOs), while in-channel and floodplain habitats have been degraded by urbanisation and land drainage’ (Dunbar Ed., 2002, p.8). Increases in sewage outflows as a result of increased population or commercial/industrial activity has the potential to exacerbate issues.
4.4.5 More generally, the Marine Biological Association states that the Mersey Estuary ‘remains chronically contaminated over much of its area (generally increasing upstream), and though there is little available data on individual discharges, the possibility that combined pressures might impair performance of sensitive species and benthic communities cannot be ruled out’ (2006, p. iv).
4.4.6 It is considered that (in the absence of any mitigation) the following policies:
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens); and
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025); and
• CE1A (Economic Development) - 88.5 ha of land for economic development between 2008 and 2025
4.4.7 Would be likely to lead to significant adverse effects upon the SPA through the increased pressure that would be placed upon wastewater treatment infrastructure that would in turn discharge treated effluent to the Mersey Estuary. This increased pressure could result in deterioration in water quality simply through the increased volume of treated effluent (which will contain increased nutrient loading) or, if the Sewage Treatment Works in question is at or near capacity, in deterioration in the level of treatment that discharged effluent receives. Increased discharge of treated effluent to rivers that drain to the estuary could also affect water flows and sediment patterns within the Mersey Estuary SPA/Ramsar site.
4.4.8 The Environment Agency’s consent regime already helps to ensure that water quality is maintained, particularly at European sites, and the Water Framework Directive will further support this. In most cases, this should ensure that the integrity of European sites is not affected. Moreover, correspondence with the Council indicates that they have checked with United Utilities that the relevant STW catchments still have physical/environmental capacity for the delivery of housing without adverse effects on European sites.
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4.4.9 Since the Preferred Options, Policy CR1 (Minerals) has been introduced; minerals development would have the potential to affect the site through the discharge of dewatering products with a high sediment loading, dependent on capacity and location of minerals extraction sites. However this policy is specifically intended to ensure that minerals sites have no unacceptable impact on the natural environment by making that a requirement of any future minerals extraction.
4.4.10 As part of the Submission Stage Core Strategy the Council have inserted a policy (Infrastructure) that includes the commitment that the Council will ‘ensuring that the LDF process and Infrastructure Providers service planning is aligned’. This creates a policy framework within which the delivery of development will be phased in order to ensure that it only takes place once any new water treatment infrastructure or appropriate retro-fitted technology (e.g. nitrate stripping) necessary to service the development while avoiding an adverse effect on European sites is in place.
4.4.11 Furthermore, although not referenced within the Core Strategy the local authority have also committed to producing a Water Cycle Study which will indicate how this will be determined and delivered through interaction with other authorities (United Utilities, the Environment Agency etc). There are ongoing discussions and it is likely this will be produced with Halton and Warrington probably over the next year.
Recommendations for changes
4.4.12 The Appropriate Assessment of the Proposed Changes Core Strategy noted that the draft St Helen’s Design Guide SPD made the following statements regarding sustainable usage of water:
• ‘Promote environmentally sustainable development (maximise resource efficiency, including sustainable drainage and waste management, minimise impacts on the natural environment and promote biodiversity)· • ‘Considerations should be given to… water and flood management, including the use of sustainable urban drainage systems (SuDS)’· • ‘Materials should also be chosen for their contribution towards sustainable drainage where the context is appropriate (e.g. green roofing and porous surfaces)’· • ‘Consider potential secondary risks that may arise ‘off site’ from development (e.g. impacts on adjacent wildlife sites by increased public use, changes to drainage and pollution)’· • ‘Consideration should be given to use of porous surfaces as part of the design for sustainable drainage systems’
4.4.13 However, the Appropriate Assessment recommended that the St Helen’s Core Strategy demonstrates that the Council is doing everything reasonably possible to husband water resources within the borough. This could be further achieved by the incorporation of more specific statements with the Design Guide that:
• State that Appropriate Assessment should be carried out on new developments, where sewage or run-off from proposed developments could have a significant impact on the integrity of the European site. • Promote and encourage the expansion of agri-environment schemes to reduce diffuse pollution, which although not a direct impact of the St Helen’s Plan, is likely to have an important ‘in combination’ effect.
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4.4.14 In order to avoid erosion effects of increased runoff from development on greenfield land within the Sankey Brook (which represents approximately 10% of the riverine water flow of the Mersey Estuary), the Design Guide should expand on its current references to SuDS to:
• Require developers to take steps (e.g. through use of SuDS) to ensure that surface water runoff from developments on greenfield land do not exceed the pre-development greenfield rates.
4.4.15 As a final measure, a policy option should be incorporated that states that: “obligations will be required where necessary in planning terms to make the development acceptable and will cover… securing contributions towards mitigation measures for any adverse impact the development may have on the locality… The range of matters to be covered includes among other things: … Drainage and flood prevention measures… protection to biodiversity, geodiversity, landscape….”. This policy could be used to ensure that developers put measures in place in order to avoid a significant water quality impact upon Liverpool Bay SPA or the Mersey Estuary SPA.
4.4.16 In the intervening period various changes have been made to national policy on the issue of sustainable water use, while the 13% increase in housing levels to be delivered in the Borough makes high water quality standards essential. Controlling water quality still lies mainly in the hands of the water companies and the Environment Agency.
Council Response to Recommendations
4.4.17 The Council have noted that they accept all the above recommendations but do not feel that the Design Guide is the appropriate place for them and instead propose the inclusion of these points within the Development Management DPD to follow after the adoption of the Core Strategy. This would be an acceptable alternative. It is concluded that these measures, together with those already implemented and the assurance provided by United Utilities, would avoid St Helen’s contribution to significant ‘in combination’ impacts on European sites related to water quality effects.
Recreational pressure
4.4.18 Policy CH1 (Meeting St Helen’s Housing Requirements) is also considered likely to lead to significant adverse effects through increased recreational disturbance as a result of the 14,528 new homes that will be delivered in the Borough by 2025, particularly when considered in conjunction with the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside).
Recommendations for Policy Changes
4.4.19 The Appropriate Assessment of the Preferred Options Core Strategy concluded that St Helens contribution to any adverse effects of increased recreational pressure upon Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA could not be mitigated or avoided by the provision of additional accessible natural terrestrial greenspace
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since all are coastal and estuarine in nature. Many impacts on these systems relate to waterborne activities and the provision of alternative sites is not possible.
4.4.20 It was therefore recommended that the Council should engage with other Merseyside authorities and Natural England to input into delivery of those actions of the Mersey Estuary Management Plan and other Estuary Management Plans that are linked to reducing the impacts of recreation including wardening, fencing, signage and seasonal closures as considered appropriate by the Management Plan as it is revised and updated to account for changing patterns of visitor use. St Helen’s contribution should be commensurate with its population size, since St Helen’s can only be considered responsible for mitigating their contribution to an “in combination” effect. It was identified that a Developer Contributions Policy or similar could be used to secure St Helen's contribution towards the actions of the Estuary Management Plan through imposing a levy upon developers to contribute to the management of the estuaries. However, whatever method is decided upon for funding local authority contributions must be agreed across the whole Merseyside area (in order to avoid putting some authorities at a disadvantage) and this report is therefore not the place to go into further details.
4.4.21 Engagement with the other Merseyside Authorities in a sub-region wide approach to managing recreational pressure on this network of coastal/estuarine sites through the various site Management Plans remains the only realistic measure by which recreational pressure on these sites can be controlled. Since St Helens has no direct influence over the management of these sites, as they lie outside her boundaries, the Borough’s contribution would still need to be a financial one. The 13% increase in housing to be delivered within St Helens doesn’t alter this mitigation measure but does (when considered cumulatively with the increased housing allocations across Merseyside) make the need to engage in such integrated pan-authority site management that much more essential. As such, we would recommend that a specific policy or statement within the Core Strategy should make a clear commitment on the part of St Helen’s Council to collaborate with the other Merseyside Authorities to manage, influence and control visitor pressure on the sensitive Merseyside Coast as far as possible and to support the delivery of the site management plans (including access management) for Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA.
Council Response to Recommendations
4.4.22 The Council have addressed this issue by proposing collaborative working with Merseyside authorities generally and the creation of a post to assess the in combination effects of the Core Strategies across the sub-region.
4.4.23 It is therefore considered that the Council have taken the necessary steps to ensure that St Helen’s contribution to significant ‘in combination’ impacts on European sites related to recreational disturbance effects will be adequately mitigated and managed such that no adverse effects are likely to result from the Core Strategy development.
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4.5 Mersey Narrows & North Wirral Foreshore pSPA / pRamsar site
4.5.1 This site is located at the mouth of the Mersey Estuary over 30km from where the Sankey Brook joins the Mersey. In terms of indirect effects, riverine water quality into the Mersey Estuary is a concern on a broad level, however the benthic communities at this site are very unlikely to be significantly affected by water quality changes within the Sankey Brook, including with consideration to dilution by 3 200mP /sP of tidal water (putting the Sankey’s inputs at 0.05% by water volume).
Recreational pressure
4.5.2 The following policies:
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025
4.5.3 Are considered likely to lead to significant adverse effects upon the SPA through increasing the quantum of residential development within St Helens and therefore within the catchment of the site leading to increased recreational pressure. Unmitigated this is considered likely (particularly when considered in combination with the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside) to lead to significantly greater recreational pressure within the SPA itself and thus disturbance to the sensitive wintering bird populations.
Recommendations for Policy Changes
4.5.4 The Appropriate Assessment of the Preferred Options Core Strategy concluded that St Helen’s contribution to any adverse effects of increased recreational pressure upon Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA could not be mitigated or avoided by the provision of additional accessible natural terrestrial greenspace since all are coastal and estuarine in nature. Many impacts on these systems relate to waterborne activities and the provision of alternative sites is not possible.
4.5.5 It was therefore recommended that the Council should engage with other Merseyside authorities and Natural England to input into delivery of those actions of the Mersey Estuary Management Plan and other Estuary Management Plans that are linked to reducing the impacts of recreation including wardening, fencing, signage and seasonal closures as considered appropriate by the Management Plan as it is revised and updated to account for changing patterns of visitor use. St Helen’s contribution should be commensurate with its population size, since St Helen’s can only be considered responsible for mitigating their contribution to an “in combination” effect. It was identified that a Developer Contributions Policy or similar could be used to secure St Helen's contribution towards the actions of the Estuary Management Plan through imposing a levy upon developers to contribute to the management of the estuaries. However, whatever method is decided upon for funding local authority contributions must be agreed across the whole Merseyside area (in order to avoid putting some authorities at a disadvantage) and this report is therefore not the place to go into further details.
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4.5.6 Engagement with the other Merseyside Authorities in a sub-region wide approach to managing recreational pressure on this network of coastal/estuarine sites through the various site Management Plans remains the only realistic measure by which recreational pressure on these sites can be controlled. Since St Helens has no direct influence over the management of these sites, as they lie outside her boundaries, the Borough’s contribution would still need to be a financial one. The 13% increase in housing to be delivered within St Helens doesn’t alter this mitigation measure but does (when considered cumulatively with the increased housing allocations across Merseyside) make the need to engage in such integrated pan-authority site management that much more essential. As such, we would recommend that a specific policy or statement within the Core Strategy should make a clear commitment on the part of St Helen’s Council to collaborate with the other Merseyside Authorities to manage, influence and control visitor pressure on the sensitive Merseyside Coast as far as possible and to support the delivery of the site management plans (including access management) for Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA.
Council Response to Recommendations
4.5.7 The Council have addressed this issue by proposing collaborative working with Merseyside authorities generally and the creation of a post to assess the in combination effects of the Core Strategies across the sub-region.
4.5.8 It is therefore considered that the Council have taken the necessary steps to ensure that St Helen’s contribution to significant ‘in combination’ impacts on European sites related to recreational disturbance effects will be adequately mitigated and managed such that no adverse effects are likely to result from the Core Strategy development. 4.6 Ribble and Alt Estuaries SPA / Ramsar site
Recreational pressure
4.6.1 Although recreational pressure within the National Nature Reserve is relatively well controlled, the connectivity between the birds using the coastal SPAs in this area and others makes this SPA sensitive to the effects of disturbance of birds as a consequence of recreational pressure on nearby sites.
4.6.2 The following policies:
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025
4.6.3 Are considered likely to lead to significant adverse effects upon the SPA through increasing the quantum of residential development within St Helens and therefore within the catchment of the site leading to an increase in recreational pressure. Unmitigated this is considered likely (particularly when considered in combination with the 416,000 new homes proposed across the northwest under the Regional Spatial Strategy (80,460 within Merseyside) to lead to significantly greater recreational pressure within the SPA itself and thus disturbance to the sensitive wintering bird populations.
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Recommendations for Policy Changes
4.6.4 The Appropriate Assessment of the Preferred Options Core Strategy concluded that St Helen’s contribution to any adverse effects of increased recreational pressure upon Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA could not be mitigated or avoided by the provision of additional accessible natural terrestrial greenspace since all are coastal and estuarine in nature. Many impacts on these systems relate to waterborne activities and the provision of alternative sites is not possible.
4.6.5 It was therefore recommended that the Council should engage with other Merseyside authorities and Natural England to input into delivery of those actions of the Mersey Estuary Management Plan and other Estuary Management Plans that are linked to reducing the impacts of recreation including wardening, fencing, signage and seasonal closures as considered appropriate by the Management Plan as it is revised and updated to account for changing patterns of visitor use. St Helen’s contribution should be commensurate with its population size, since St Helen’s can only be considered responsible for mitigating their contribution to an “in combination” effect. It was identified that a Developer Contributions Policy or similar could be used to secure St Helen's contribution towards the actions of the Estuary Management Plan through imposing a levy upon developers to contribute to the management of the estuaries. However, whatever method is decided upon for funding local authority contributions must be agreed across the whole Merseyside area (in order to avoid putting some authorities at a disadvantage) and this report is therefore not the place to go into further details.
4.6.6 Engagement with the other Merseyside Authorities in a sub-region wide approach to managing recreational pressure on this network of coastal/estuarine sites through the various site Management Plans remains the only realistic measure by which recreational pressure on these sites can be controlled. Since St Helens has no direct influence over the management of these sites, as they lie outside her boundaries, the Borough’s contribution would still need to be a financial one. The 13% increase in housing to be delivered within St Helens doesn’t alter this mitigation measure but does (when considered cumulatively with the increased housing allocations across Merseyside) make the need to engage in such integrated pan-authority site management that much more essential. As such, we would recommend that a specific policy or statement within the Core Strategy should make a clear commitment on the part of St Helen’s Council to collaborate with the other Merseyside Authorities to manage, influence and control visitor pressure on the sensitive Merseyside Coast as far as possible and to support the delivery of the site management plans (including access management) for Liverpool Bay pSPA, Mersey Estuary SPA, Mersey Narrows and North Wirral Foreshore SPA and Ribble & Alt Estuaries SPA.
Council Response to Recommendations
4.6.7 The Council have addressed this issue by proposing collaborative working with Merseyside authorities generally and the creation of a post to assess the in combination effects of the Core Strategies across the sub-region.
4.6.8 It is therefore considered that the Council have taken the necessary steps to ensure that St Helen’s contribution to significant ‘in combination’ impacts on European sites related to recreational disturbance effects will be adequately
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mitigated and managed such that no adverse effects are likely to result from the Core Strategy development. 4.7 River Dee & Lake Bala SAC / Dee Estuary SAC SPA & Ramsar site
Water abstraction
4.7.1 Like all riverine European sites, the River Dee is sensitive to the effects of excessive abstraction for the public water supply (particularly at times of low flow) and the resulting impacts this can have on the interest features of the river through desiccation, fish entrainment and increased sediment loading in the water that remains. Since the interest features of the Dee Estuary persist in part because of the balance between saline and freshwater inputs, a substantial increase in abstraction from the River Dee to meet the water resource needs of St Helens may result in a damaging reduction in the freshwater inputs to the estuary.
4.7.2 The following policies:
• CSS1 (Overall Spatial Strategy);
• CAS 1.1 (St Helens Core Area Strategy);
• CAS2 (Town Centre Strategy);
• CAS3 (Newton-le-Willows and Earlestown Strategy);
• CAS4 (Haydock & Blackbrook Strategy);
• CAS5 (Rural St Helens); and
• CH1 (Meeting St Helens Housing Requirements) - up to 14,528 new dwellings by 2025); and
• CE1A (Economic Development) - 88.5 ha of land for economic development between 2008 and 2025
4.7.3 Are considered likely to lead to significant adverse effects upon the SAC through increasing the quantum of residential development within St Helens and therefore within the water supply catchment of the site. Unmitigated it is considered that there is potential (particularly when considered in combination with some of the 229,240 new homes proposed across Manchester, West Cumbria and Cheshire under the North West RSS and at least some of the housing proposed for North East Wales and the West Midlands over the same period) for damaging levels of drawdown within the SAC.
4.7.4 At the same time, a sense of proportion must be maintained. Unlike most of the indirect impacts on European sites that can derive from development (e.g. from recreational pressure or vehicle exhaust emissions) and which are generally not covered by any independent assessment or consenting regime, water supply is covered by a detailed abstraction licencing and Review of Consents process controlled by the Environment Agency. One of the principal functions of this regime
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is to ensure that the abstraction of water at volumes, rates or times of year that would result in adverse effects on internationally designated sites do not take place. As such, even without the existence of the St Helens LDF and its development control function, the delivery of new housing within the district would be unlikely in practice to lead to adverse effects upon European sites in normal circumstances since the Environment Agency licencing regime would not in reality approve damaging scales of abstraction.
4.7.5 Avoiding adverse effects on European sites as a result of increased scales of abstraction to supply new housing must therefore be principally the responsibility of 16 the water companies (in this case United Utilities and Severn Trent WaterTPF F)PT through their Water Resource Management Plans, water supply operations and abstraction licence applications and the Environment Agency through their licencing regime and Review of Consents process. St. Helens Council has no control over the water supply strategy chosen for the borough since this is the responsibility of the statutory water supplier (United Utilities), the Environment Agency and the Regulator (the Office of Water Services, Ofwat) and is part of a much larger complex of catchment transfers between rivers and reservoirs in Wales, Cumbria and elsewhere in north-west England and involving at least three water companies – United Utilities, Severn Trent Water and Dee Valley Water.
4.7.6 The most recent draft United Utilities Water Resource Management Plan (January 2009) indicates that the water available for use in the Integrated Resource Zone is expected to reduce by 24.8 Ml/d between 2009/10 and 2014/15. Without water efficiency measures or new resources the initial supply demand balance for the Integrated Resource Zone is calculated to be in deficit by 8 Ml/day by 2024/25. Nonetheless, United Utilities have been able to confirm to St Helens Council that they will be able to provide the new housing that St Helens plans to deliver under the Core Strategy with potable water without damaging levels of abstraction from European sites. With regard to future developments in order to meet the anticipated 8 Ml/day shortfall, United Utilities intends to undertake the following activities:
• Construction of a bi-directional pipeline, known as the “West-to-East Link”, between Merseyside and North Manchester. It is due to be in operation by 2012. This will help United Utilities maintain adequate supplies to Greater Manchester and Merseyside if there is a need to temporarily reduce supply from a major reservoir, for example due to maintenance work or drought conditions. • Maintain current leakage levels. • Help customers save 9 Ml/d by 2014/15 (increasing later on to 12 Ml/d), through a base service water efficiency programme. • Achieve a water demand reduction of 10 Ml/d in a dry year by 2014/15 (increasing to 22 Ml/d by 2034/35) as a result of the expected scale of voluntary metering of households. • Non-household customers in the Integrated Zone are expected to reduce water demand by 87 Ml/d by 2014/15 (141 Ml/d by 2034/35) due to the effects of the economic downturn and as part of their continuing water efficiency programmes.
16 TP PT United Utilities is responsible for the potable water supply in St Helens, while Severn Trent Water operate Lake Vyrnwy
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4.7.7 United Utilities enhanced plans identified as part of their economic programme to maintain adequate supply-demand balances are:
• Further reducing leakage by 23 Ml/d by 2034/35. • A programme of economic water efficiency measures to save 4 Ml/d by 2034/35. 17 • Implementing water source enhancements of 48 Ml/d by 2034/35TPF FPT.
4.7.8 The result will be a final supply-demand balance of 0 Ml/day by 2024/25.
4.7.9 The Environment Agency is proposing to change the abstraction licence conditions for some of United Utilities water sources because of anticipated impacts on European sites and other nature conservation sites without such modification. Specifically within the Integrated Zone the Environment Agency has identified the need to modify licences in the case of Haweswater and Thirlmere reservoirs and rivers Brennand and Whitendale. However, according to the latest United Utilities WRMP no reductions have been required at this stage regarding the River Dee or any of the water sources in Wales.
4.7.10 From the current draft Water Resource Management Plan it does not appear that additional abstraction from the River Dee SAC are anticipated in order to meet the water needs of St. Helens borough during the plan period. Although a scheme to expand raw water treatment at Huntingdon to allow abstraction from the River Dee up to the full licenced capacity was considered, it has not been taken forward according to the current draft Water Resource Management Plan. In any case, since this scheme would involve taking the abstraction from the River Dee up to a level that is already permitted (as actual abstraction by United Utilities is currently less than the permitted abstraction volumes) the volumes that would be abstracted will have already been accounted for in the Environment Agency’s Review of Consents (RoC) process, since the RoC uses the full licenced abstraction volume irrespective of whether the current actual abstracted volume is less.
Creating an Appropriate Policy Framework
4.7.11 Clearly the concept of strategic forward planning of development requires local authorities to play their part in ensuring the pressures on available water resources are minimised as far as is practical, rather than relying entirely on the Environment Agency licencing regime, and this is the context within which the St Helens Core Strategy can deliver mitigation measures on its own account to supplement those avoidance strategies that will be implemented by the Environment Agency and United Utilities as part of their wider resource planning roles.
4.7.12 Whereas in some districts of England it is possible for local authorities to locate housing in areas that receive potable water from different sources and thereby help to alleviate pressures on certain European sites by changing the location of development, this is not the case in St Helens since the area is not geographically apportioned in a simple manner between different water sources but is supplied through an elaborate network of catchment transfers. As such, moving new housing within St Helens to different parts of the borough would be unlikely to make a material impact on the actual contribution of the borough to water supply demands on European sites. St Helens Council must therefore focus on delivering
17 TP PT Widnes groundwater (22.7 Ml/d), Southport groundwater (22.5 Ml/d) and Oldham groundwater (2.5 Ml/d)
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alternative measures. Measures that could be delivered through the LDF process essentially take two broad forms:
• A policy or supporting text that makes an explicit commitment to phase the delivery of development in such a way as to ensure that occupation/operation only takes place once any new infrastructure that the water company may need to provide in order to service the development and avoid an adverse effect on European sites, is in place. The local authority should also indicate how this need will be determined and delivered through interaction with other authorities (United Utilities, the Environment Agency etc) i.e. through a Water Cycle Study.
• Since May 2008 the ‘Code for Sustainable Homes’ standard for new
development has become mandatory butU U no minimum standard has yet been set. The Code for Sustainable Homes has benefits because it has minimum requirements of water efficiency for every different rating. It is understood that from 2010 the Building Regulations will make it mandatory that at least level 3 is achieved. However, local authorities could pre-empt the change to the Building Regulations and either require developments to achieve greater than Level 3 or 4 (which are the same in terms of water efficiency) from the time of plan adoption or encourage developers to exceed these requirements where possible.
Council Response to Recommendations
4.7.13 As part of the Submission Stage Core Strategy the Council have inserted a policy (Infrastructure) that includes the commitment that the Council will ‘ensuring that the LDF process and Infrastructure Providers service planning is aligned’. This creates a policy framework within which the delivery of development will be phased in order to ensure that it only takes place once any new water treatment infrastructure or appropriate retro-fitted technology (e.g. nitrate stripping) necessary to service the development while avoiding an adverse effect on European sites is in place.
4.7.14 Although not referenced within the Core Strategy the local authority have also committed to producing a Water Cycle Study which will indicate how this will be determined and delivered through interaction with other authorities (United Utilities, the Environment Agency etc). There are ongoing discussions and it is likely this will be produced with Halton and Warrington probably over the next year.
4.7.15 In relation to Code for Sustainable Homes the Council have now opted in Policy
CP1 for a level of atU least U Code 4 with an opportunity to advance to level 5 and 6 when a wider and robust evidence base has been collated through the forthcoming climate change Development Plan Document.
4.7.16 It can therefore be concluded that an adequate policy framework exists (with allowance for high levels of water efficiency if necessary) to address water resource issues adequately. 4.8 Conclusion
4.8.1 The Appropriate Assessment of the Submission Stage Core Strategy (March 2009) indicates that all of the mitigation measures that Scott Wilson has identified to set
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an appropriate policy framework for the avoidance and mitigation of adverse effects on European sites have been adopted or will be adopted in a future DPD/SPD. In addition, St Helens Council has adopted or is in the process of taking forward several initiatives that will ensure that the Council’s contribution to requirements for additional potable water and recreational pressure on coastal European sites as a result of the housing to be delivered under the Core Strategy is minimised.
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Pless-Mulloli, T., Howel, D., King, A., Stone, I., Merefield, J., Besselll, J. and Darnell, R. (2000). Living near opencast coal mining sites and children's respiratory health. Occup Environ Med 57(3): 145–151.
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page-3810UTH Webb et al., 2004b – Webb A., McSorley C..A., Dean B. J. and Reid J. B. (2004b). Recommendations for the selection of, and boundary options for, an SPA in Liverpool
Bay. http://www.jncc.gov.uk/default.aspx?page=3815HTU UTH
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West Lancashire District Council (2006). West Lancashire Replacement Local Plan 2001-2016.
http://www.westlancsdc.gov.uk/planningpolicy/index.cfm?ccs=356HTU UTH
Wigan Council (2006). Wigan Unitary Development Plan: Replacement Plan with Proposed
Modifications. http://www.cartoplus.co.uk/wigan/#HTU UTH
Wikipedia (2006). River Dee, Wales. http://www.netipedia.com/index.php/River_Dee,_WalesHTU UTH
The Wildlife Trusts (2000). Great Crested Newt (Triturus cristatus).
http://www.wildlifetrust.org.uk/urbanwt/ecorecord/bap/html/gcnewt.htmHTU UTH
Wildlife Trust, 2006 – The Wildlife Trust for Lancashire, Manchester and North Merseyside (2006).
uses and abuses. http://www.lancswt.org.uk/LearnHTU ing%20&%20Discovery/theirishsea/
usesandabuses.htmUTH Wirral MBC, 2001 – Wirral Council (2001). Consultations on proposed designation of North Wirral Foreshore SSSI and Mersey Narrows SSSI as a potential Special Protection Area and proposed Ramsar sire.
http://www.wirral.gov.uk/minute/public/envped011029rep02_3275.pdfHTU UTH
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APPENDIX 2 – ‘TIERING’ IN APPROPRIATE ASSESSMENT
The North West Plan AA
Increasing Sub-Regional Strategies AA specificity in terms of evidence base, impact evaluation, mitigation, consideration of Local Development AA alternatives etc. Frameworks
Individual projects AA
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APPENDIX 3 – MAP OF ST. HELENS AND THE EUROPEAN SITES CONSIDERED
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APPENDIX 4 – QUALIFYING SPECIES WITHIN ST. HELENS AS A POTENTIAL PATHWAY
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Definitions:
Yes = the population of birds is numerically significant applying a standard 1% criterion (i.e. the population of a species within St. Helens is more than approximately 1% of the population of that same species within the European site). There could be a direct association between the birds of that species within St. Helens and at the European site that should be looked into further. No = the population of birds is not numerically significant. Even if there were a direct link between the birds of that species within St. Helens and at the European site, any potential harm to the population within St. Helens would not lead to significant effects upon the conservation objectives of the European site.
Main Sites in St. 18 “Significant” with relation Annex I Bird Species Name Population summaryTPF FPT 19 Helens Where Found to European site pop.?TPF FPT Liverpool Bay pSPA
Eccleston Mere Occasional winter sitings. No Red-Throated Diver Gavia stellata Prescot Reservoirs Occasional sitings. No Summer visits by typically one flock at a time of Prescot Reservoirs approximately up to ten birds are becoming increasingly No Common Scoter Melanitta nigra regular. (Eccleston Mere) Very rare sitings. No
Martin Mere SPA Eccleston Mere Regular autumn visits by approximately several birds. No Northern Pintail Anas acuta (Newton Lake) Occasional visits. No Eccleston Mere Regular autumn visitors of a few birds. No Carr Mill Dam Rare visits of very small numbers of birds. No Wigeon Anas penelope Regular sitings of up to approximately 10 birds, with Prescot Reservoirs No most present during the spring. Taylor Park Rare visits of very small numbers of birds. No
18 TP PT Data from sources: St. Helens Wildlife Recording Group (2005 and 2006) 19 TP PT A “significant” population is not to be confused with a potentially significant effect on a European site.
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Main Sites in St. 18 “Significant” with relation Annex I Bird Species Name Population summaryTPF FPT 19 Helens Where Found to European site pop.?TPF FPT Up to approximately 2,000 birds feed in the area in Catchdale Moss the winter. Up to approximately 5,000 birds winter in the area – large flocks are frequently seen on the ground Pink-Footed Anser around Moss Lane, Reed’s Moss, Old Coach Road, Yes Goose brachyrhynchus The Rainford Dairy Farm Road and Reed’s Lane. Approximately Mosslands half of these birds roost on the remains of Simonswood Moss, east of the Old Coach Road, and seemingly do not return to Martin Mere to roost. Cygnus Very rare sightings of overhead flying birds – no Bewick’s Swan columbianus ssp. Prescot Reservoirs No known visits. bewickii Eccleston Mere Occasional visits. No Occasional sitings of approximately several birds. A Whooper Swan Cygnus cygnus The Rainford handfull of birds may have recently begun to No Mosslands overwinter in or around St. Helens. Mersey Estuary SPA Eccleston Mere Regular autumn visits by approximately several birds. No Northern Pintail Anas acuta (Newton Lake) Occasional visits. No Eccleston Mere Occasional visits. No Regular winter numbers, recently exceeding 200 Newton Lake birds. No evidence of breeding recently, and no Yes sitings in summer 2005. The Rainford Occasional visitors. No Mosslands Common Teal Anas crecca Regular winter visitors of up to approximately 40 Prescot Reservoirs birds. No evidence of breeding recently, and no No sitings in summer 2005. Regular winter visitors of up to approximately 70 Sankey Valley birds. No evidence of breeding recently, and no No sitings in summer 2005. Wigeon Anas penelope Eccleston Mere Regular autumn visitors of a few birds. No Carr Mill Dam Rare visits of very small numbers of birds. No Regular sitings of up to approximately 10 birds, with Prescot Reservoirs No most present during the spring.
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Main Sites in St. 18 “Significant” with relation Annex I Bird Species Name Population summaryTPF FPT 19 Helens Where Found to European site pop.?TPF FPT Taylor Park Rare visits of very small numbers of birds. No Carr Mill Dam Rare sitings of very small numbers of birds. No Calidris alpina Present throughout the year, with up to Northern Dunlin alpina Prescot Reservoirs approximately 30 birds in the spring, and with recent No increases in sitings. Present winter and summer, potentially with up to Charadrius Prescot Reservoirs No Ringed Plover approximately 30 birds in the spring. hiaticula Eccleston Mere Rare sitings of very small numbers of birds. No Black-tailed Limosa limosa Increasingly frequent winter and (particularly) spring Prescot Reservoirs No Godwit ssp. limosa sitings of up to approximately 10 birds. The Rainford Regular sitings of small numbers in the spring. No Mosslands Numenius Carr Mill Dam Rare sitings of very small numbers of birds. No Curlew arquata Eccleston Mere Rare sitings of very small numbers of birds. No Regular summer visitors of up to approximately 10 Prescot Reservoirs No birds. Regular spring visitors of declining numbers: from Catchdale Moss No over 1,000 in 1991, to 0 sitings in 2005. Regular winter and spring visitors of up to The Rainford approximately 20 birds, with a rare siting of over 200 No Golden Plover Pluvialis apricaria Mosslands birds in March 2005. Eccleston Mere A siting of 21 birds in October 2005. Regular sitings of up to approximately 20 birds, Prescot Reservoirs No mostly fly-overs. Pluvialis Grey Plover Prescot Reservoirs Rare visits by very small numbers of birds. No squatarola Present throughout the year, with up to Carr Mill Dam Yes approximately 50 birds in the summer. Present throughout the year in numbers of up to Eccleston Mere Yes Great Crested Podiceps approximately 10 to 20. Grebe cristatus Prescot Reservoirs Present throughout the year in small numbers. Yes Attracts breeding winter birds of up to approximately Taylor Park Yes 10 to 20 in number. Shelduck Tadorna tadorna Catchdale Moss Regular spring visitors in small numbers. No
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Main Sites in St. 18 “Significant” with relation Annex I Bird Species Name Population summaryTPF FPT 19 Helens Where Found to European site pop.?TPF FPT Eccleston Mere Regular spring visitors in very small numbers. No The Rainford Winter and spring sitings in very small numbers. No Mosslands Carr Mill Dam Rare sitings of very small numbers of birds (winter). No Winter and spring visitors of up to approximately 10 Prescot Reservoirs No birds. Occasional sitings of very small numbers of birds at Prescot Reservoirs No Redshank Tringa totanus all times of the year. Taylor Park Rare sitings. No Carr Mill Dam Occasional sitings. No Catchdale Moss Sitings of up to several hundred birds in the winter. Yes Breeding pairs of small numbers of birds, but up to Eccleston Mere Yes approximately 200 in the winter. Lapwing Vanellus vanellus Present throughout the year, particularly spring, Prescot Reservoirs summer and autumn, with sitings of approximately Yes 600 in December 2005. The Rainford Breeding pairs of at least a couple of hundred birds. Yes Mosslands
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APPENDIX 5 – THE CATCHMENTS OF THE SANKEY BROOK AND MERSEY ESTUARIES
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Sankey Brook Catchment
Source: Dunbar Ed., 2002
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Source: Mersey Basin Campaign, 2004
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APPENDIX 6 – SCREENING SUMMARY TABLE
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Long-term improvement in domestic and industrial pollution of waters, increases in agricultural effluent over same period (see below). Current relevant pressures incl.: • recirculation of heavy metals bound into the sediment • treated sewage and industrial waste in rivers • agricultural effluent in rivers, leading to algal blooms and de-oxygenation of seawater
SPAU - Annex I Species:U • coastal squeeze • navigational dredging • Red-throated diver Gavia stellata • marine aggregate extraction (1405 wintering individuals = 28.7% of the GB population) • proposed offshore wind turbines
Liverpool Bay pSPA / Liverpool & North Wales • water-based recreation and related 197,504.24 ha Common scoter Melanitta nigra pRamsar site (c. 15 km west of St. Helens) • development along the foreshore (53,454 wintering individuals = 3.3% of the GB population). Summary of Nature Conservation
RamsarU – Criterion 5: Objectives None at this stage; likely to be similar to those for Site regularly supports > 20,000 waterfowl. the Mersey Estuary SPA/Ramsar, i.e.:
• No significant reduction in numbers or displacement of all qualifying species
• No significant damage to or decrease in extent of habitat, vegetation characteristics or landscape features
• No significant reduction in abundance of prey species, primarily aquatic invertebrates but also aquatic vegetation (including algae)
20 TP PT Note that Grid References are taken from the approximate centre of the SPA/SAC and for large sites (e.g. estuaries), they may extend significantly beyond the grid reference provided.
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Historical loss of habitats due to drainage and infill for agriculture and development. Recent rehabilitation management has increased Sphagnum species.
Main environmental pressures: • pressure from agriculture to increase drainage, which causes succession; • afforestation as a result of natural succession; • fly-tipping; • loss of neighbouring mossland habitat as a result of agricultural and development; and • loss of Sphagnum species as a result of increased air pollution. Summary of Nature Conservation Manchester Mosses SAC Objectives
Contains: AnnexU I Habitats …………………. Warrington & Wigan Uas Astley & Bedford Mosses 172.81 ha (c. 8km east of St. Helens) 7120 – Degraded raised bogs still capable of natural Re-establish peat-forming vegetation with at least
regeneration 30% comprising Sphagnum mosses and Holcroft Moss remainder primarily cotton grasses.
Risley Moss Bog water should be stagnant and close to ground level and indicative of anaerobic conditions; the water table should normally be within c. 25 cm of the surface, equating to the acrotelm.
Absence of dominant scrub or bracken invasion over more than 10% of the mire expanse unless tree/scrub is essential for other interest features such as nightjar.
The re-instatement of an undrained area around the raised bog with appropriate habitat such as fen surrounding the bog for such a distance as hydrological studies recommends.
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Main environmental pressures:
SPAU – Annex I Species: • nutrient enrichment from agricultural fertilisers Over-wintering: and run-off • Bewick’s swan Cygnus columbianus ssp. bewickii • weakening of stems through poor growth (449 individuals = 6.2% of GB population) conditions • Whooper swan Cygnus cygnus (621 = 11.3% of GB population) • natural succession to woodland • Pink-footed goose Anser brachyrhynchus • reduced water level by abstractions or (25,779 = 11.5% of Icelandic/Greenland & UK populations) agricultural drainage • Pintail Anas acuta • removal of reeds and other plants through (978 = 1.6% of NW European population) routine management of ditches and riverbanks • recreational use of waterbodies and waterways
RamsarU – Criterion 5 (>20,000 waterfowl): • habitat loss or degradation due to the isolation Peak counts in winter: of reedbeds as a result of losses elsewhere 25,306 waterfowl (5-year peak mean 1998/99 – 2002/03) Includes pochard Aythya farina, mallard Anas platyrhynchos, teal, Anas crecca, species referred to above, and: Martin Mere SPA / Lancashire UA 119.89 ha • Wigeon Anas penelope Ramsar site (c. 11km north of St. Helens) (9,062 = 0.7% of GB population) Summary of Nature Conservation
RamsarU – Criterion 6 (important pop’ns): Objectives Spring/autumn: • Pink-footed goose Anser brachyrhynchus (8,186 = avg 3.4% of the Icelandic/Greenland & UK populations) Winter: No significant reduction in numbers of all qualifying • Bewick’s swan Cygnus columbianus ssp. bewickii species (see left) over-wintering birds from a (61 = avg 0.7% of GB population) reference level. • Whooper swan Cygnus cygnus (1,320 = avg 6.3% of population) No significant damage to or decrease in extent of • Eurasian wigeon Anas penelope habitat, hydrology or landscape features from a (3,062 =avg 0.7% GB population) reference level. • Northern pintail Anas acuta (415 = avg 1.4% of GB population) Presence and abundance of aquatic plants and freshwater invertebrates (food items) should not deviate significantly from a reference level.
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
SPAU – Annex I Species: Over-wintering: th Historic pollution since 18P P century, peaked • Golden plover Pluvialis apricaria (3,070 individuals = 1.2% of GB pop’n) around 1960, major improvements in water quality • Redshank Tringa totanus since 1985. (3,516 = 2.0% of Eastern Atlantic pop’n) • Ringed plover Charadrius hiaticula Main environmental pressures: (1,453 = 2.9% of Europe/N. African pop’n) • Dunlin Calidris alpina alpina • heavy metal pollution (44,300 = 3.2% of Northern Siberian/Europe/West African • agricultural effluent, leading to algal blooms and population) de-oxygenation of seawater • Pintail Anas acuta • treated sewerage and untreated runoff (2,744 = 4.6% of NW European pop’n) • coastal squeeze • Redshank Tringa totanus • navigational or aggregate dredging (4,689 = 3.1% of E. Atlantic population) • increased recreational pressure Shelduck Tadorna tadorna • • introduction of non-native species and (5,039 = 1.7% of wintering NW European population) translocation • Teal Anas crecca Halton, Wirral, Cheshire • selective removal of species Mersey Estuary SPA / (11,667 = 2.9% of NW European pop’n) & Liverpool Uas 5,033.14 ha Ramsar site (c. 5.5 km south of St. Helens) RamsarU – Criterion 5 (>20,000 waterfowl): Summary of Nature Conservation Peak counts in winter: 89,576 waterfowl (5-year peak mean 1998/99 – 2002/03) Objectives
RamsarU – Criterion 6 (important pop’ns): Spring/autumn: No significant reduction in numbers or • Common shelduck Tadorna tadorna displacement of all qualifying species (see left) (12,676 = avg 4.2% of total population) over-wintering birds from a reference level. • Black-tailed godwit Limosa limosa ssp. limosa (2,011 = avg 5.7% of total population) No significant damage to or decrease in extent of • Redshank Tringa totanus habitat, vegetation characteristics or landscape (6,651 = avg 2.6% of total population) features from a reference level. Winter: • Eurasian teal Anas crecca Presence and abundance of prey species, (10,613 = avg 2.6% of total population) primarily aquatic invertebrates but also aquatic • Northern pintail Anas acuta vegetation (including algae) (food items) should (565 = avg 2%of GB population) not deviate significantly from a reference level. • Dunlin Calidris alpina alpina (48,364 = avg 3.6% of total population)
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
th Historic pollution since 18P P century, peaked around 1960, major improvements in water quality since 1985.
Main environmental pressures: • heavy metal pollution • agricultural effluent, leading to algal blooms and de-oxygenation of seawater
SPATU – Annex I Species:U • treated sewerage and untreated runoff
• CommonT tern Sterna hirundo • coastal squeeze (124 pairs breeding = 1.0% of the GB population) • navigational dredging • Bar-tailed godwit Limosa lapponica • marine aggregate extraction (537 individuals wintering = 1.0% of the GB population) • proposed offshore wind turbines • water-based recreation and related SPAU – Article 4.2:U development along the foreshore Used regularly by 1% or more of the biogeographical • introduction of non-native species and populations of the following migratory species: translocation • Knot Calidris canutus • selective removal of species Mersey Narrows & North Sefton & Wirral UAs (10,661 individuals = 3.0% of NW European, NE Canadian, Wirral Foreshore pSPA / 2,078.23 ha Summary of Nature Conservation (c. 16 km west of St. Helens) Greenland & Icelandic populations) pRamsar site • Redshank Tringa totanus Objectives (1,606 individuals = 1.1 % Eastern Atlantic population) • Turnstone Arenaria interpres (1,593, individuals = 2.3% Western Palearctic population) No absolute loss of any more than 50% of the bird RamsarU – Criterion 5 (>20,000 waterfowl):U populations (see left). 28,841 waterfowl in the non-breeding season No significant damage to or decrease in extent of RamsarU – Criterion 6 (important pop’ns):U habitat, vegetation characteristics and landscape Regularly supports 1% of the species or subspecies of features from a reference level. waterbird (e.g. listed above) in any season.
Presence and abundance of prey species, primarily aquatic invertebrates but also aquatic vegetation (including algae) (food items) should not deviate significantly from a reference level.
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
SPAU – Annex I Species:U During the breeding season; • Common tern Sterna hirundo (182 pairs = 1.5% GB breeding pop’n) • Ruff Philomachus pugnax (1 pair = 9.1% GB breeding pop’n) Over winter; • Bar-tailed Godwit Limosa lapponica Long-term improvement in domestic and industrial (18,958 = 35.8% of GB population) pollution of waters, increases in agricultural • Bewick’s swan Cygnus columbianus ssp. bewickii effluent over same period. Largely undisturbed (229 = 3.3% of GB population) until the 19th century, then modification and • Golden Plover Pluvialis apricaria dredging of river for the Port of Preston, and (4,277 = 1.7% of GB population) landfill and drainage for agriculture. Recent • Whooper Swan Cygnus cygnus dramatic changes in the course of channels in the (159 = 2.9% of GB population) outer estuary., and climatic and sea level changes
are likely to exaggerate patterns of erosion and SPAU – Article 4.2 (important populations):U During the breeding season; accretion. • Lesser black-backed gull Larus fuscus On passage; Main environmental pressures: Ribble & Alt Estuaries • Ringed Plover Charadrius hiaticula • oil and gas exploration SPA / Ramsar site Lancashire & Sefton UAs 12,361.13 ha • Sanderling Calidris alba • intense grazing (c. 16 km west of St. Helens) Over winter; • intensified recreation (water- and land-based) • Black-tailed godwit Limosa limosa ssp. limosa • heavy metal pollution • Dunlin Calidris alpina alpina • agricultural effluent, leading to algal blooms and • Grey plover Pluvialis squatarola de-oxygenation of seawater • Knot Calidris canutus • treated sewerage and untreated runoff • Oystercatcher Haematopus ostralegus • coastal squeeze • Pink-footed goose Anser brachyrhynchus • navigational dredging • Pintail Anas acuta • marine aggregate extraction • Redshank Tringa totanus • proposed offshore wind turbines • Sanderling Calidris alba • introduction of non-native species and • Shelduck Tadorna tadorna translocation • Teal Anas crecca • selective removal of species • Wigeon Anas penelope
SPAU – Article 4.2 (populations):U Regularly supports 29,236 individual seabirds and over winter, 301,449 individual waterfowl.
(continued…)
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Summary of Nature Conservation Objectives
(…continued)
RamsarU – Criterion 2 (endangered species):U Supports up to 40% of GB population of natterjack toads Bufo calamita (…continued)
RamsarU – Criterion 5 (>20,000 waterfowl):U No significant reduction in numbers or Peak counts in winter: displacement of all qualifying species (see left) 222,038 waterfowl (5-year peak mean 1998/99 – 2002/03) over-wintering birds from a reference level. Ribble & Alt Estuaries SPA / Ramsar site RamsarU – Criterion 6 (important pop’ns):U No significant damage to or decrease in extent of (…continued) Includes the species for which it qualifies as an SPA under habitat, vegetation characteristics and landscape Article 4.2, and: features from a reference level. Spring/autumn:
• Red knot Calidris canutus islandica Presence and abundance of prey species, Winter: primarily aquatic invertebrates but also aquatic • Bewick’s swan Cygnus columbianus ssp. bewickii vegetation (including algae) (food items) should • Whooper Swan Cygnus cygnus not deviate significantly from a reference level. • Bar-tailed Godwit Limosa lapponica
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Dwindling numbers of great-crested newts nationally at a rate of 2% of colonies per year. Major causes have been the loss of breeding ponds and surrounding terrestrial habitat by built development and waterborne pollution from industry and roads.
Main environmental pressures: • habitat loss due to built development • barriers to movement due to built development • natural succession • significant pollution of habitat from industry and roads • ‘park-style’ maintenance of terrestrial habitat • fish stocking of ponds • landscaping and reclamation of derelict land Warrington UA AnnexU II SpeciesU: Rixton Clay Pits SAC (SJ 684901) 13.99 ha Summary of Nature Conservation Great crested newt Triturus cristatus (c. 8km east of St. Helens) Objectives
No loss of area or fragmentation of site. No barriers of newt movement between ponds.
No reduction in number of waterbodies at site (currently 33 within SSSI/pSAC)
Slight pollution is acceptable; unfavourable if pollution reduces viability of the pond as a breeding site e.g. causes major macrophyte losses.
75% of waterbodies to hold water throughout the breeding and tadpole development season (February - mid August).
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20 European Site LocationTPF FPT Area Reason(s) for Designation Management, Key Issues or Other History
Historic interruption of erosion /deposition patterns.
Main environmental pressures:
AnnexU I Habitats (Qualifying) • recreational pressure
• 2110 – Embryonic shifting sand dunes • dredging or hard-standing interrupting (one of the best areas in the UK – total extent in the UK erosion/deposition estimated at less than 1,000 hectares) • loss of great-crested newt habitat, and • 2120 – Shifting dunes along the shoreline with Ammophila fragmentation arenaria (“white dunes”) • fish stocking of ponds (one of the best areas in the UK) Summary of Nature Conservation • 2130 – Fixed dunes with herbaceous vegetation (“grey dunes”) Objectives (one of the best areas in the UK) HabitatsU No decrease in extent of sand dunes (extent must • 2170 – Dunes with Salix repens ssp. argentea (Salicion account for natural variation as a result of succession arenariae) to and interaction with other dune habitats). Bare Sefton UA (one of the best areas in the UK – total extent in the UK Sefton Coast SAC 4,563.97 ha sand should not exceed 25% cover. (c. 16 km west of St. Helens) estimated at less than 1,000 hectares) • 2190 – Humid dune slacks Maintain range and mosaic of sand dune communities, vegetation structure and species (one of the best areas in the UK) present. (Prevent increase of existing coniferous • 2150 – Atlantic decalcified fixed dunes (Calluno-Ulicetea) woodland or scrub cover at expense of fixed dune (supports significant presence – total extent in the UK vegetation.) estimated at less than 1,000 hectares)
PetalwortU
No net loss of the existing 47 populations and general AnnexU II Species 2 P extent of area (c. 600 mP within relatively young frontal • Petalwort Petalophyllum ralfsii dune slacks of the Ainsdale and Birkdale Hills LNR). (one of the best areas in the UK) Maintain favourable vegetation structure (<1 cm with • Great crested newt Triturus cristatus bare substrate (20 – 90%); most abundant for which the area is considered to support a significant populations occurring at 30% bare substrate.
presence. Great -crested newt No loss of area or fragmentation of terrestrial habitat. No barriers to prevent newt movement between suitable ponds Prevent reduction of waterbodies present that currently support great crested newts.
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APPENDIX 7 – EC ADVICE ON AA MITIGATION MEASURES
• List each of the measures to be introduced
• Explain how the measures will avoid the adverse impacts on the site
• Explain how the measures will reduce the adverse impacts on the site
Then, for each of the listed mitigation measures:
• provide evidence of how they will be secured and implemented and by whom;
• provide evidence of the degree of confidence in their likely success;
• provide a timescale, relative to the project or plan, when they will be implemented;
• provide evidence of how the measures will be monitored, and, should mitigation failure be identified; and
• how that failure will be rectified.
Source: European Commission, 2001
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APPENDIX 8 - NATURAL ENGLAND CONSULTATION RESPONSE REGARDING THE HRA OF THE PREFERRED OPTIONS CORE STRATEGY
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