THE WEST LOCAL PLAN 2012 TO 2032

DRAFT PREFERRED STRATEGY

HABITAT REGULATIONS ASSESSMENT

January 2012

This report was prepared by on behalf of the National Park Authority, as the 'competent authority' under the Conservation of Habitats and Species Regulations 2010.

Copyright The maps in this report are reproduced from Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty’s Stationery Office. © Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. (Somerset County Council)(100038382)(2011)

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Contents

1. Introduction ...... 4 2. Screening Exercise ...... 6 3. Characteristics and Description of the Natura 2000 Sites ...... 8 Introduction ...... 8 Identification of Natura 2000 sites...... 8 Ecological Zones of Influence ...... 11 Description and Characterisation of Natura 2000 Sites ...... 11 4. Potential Impacts of the Plan on Ecology ...... 42 Introduction ...... 42 Recreational Pressure ...... 42 Habitat Loss ...... 44 Habitat Fragmentation...... 45 Barrier Effects ...... 45 Habitat Isolation ...... 46 Proximity Impacts...... 46 Air Pollution...... 47 Hydrological Impacts...... 47 Renewable Energy Schemes...... 48 Cumulative Impacts...... 48 Summary of Potential Effects from the Core Strategy and Development Management Policies on SAC Features ...... 49 5. Analysis of Policy in the Local Plan Draft Preferred Strategy ...... 51 Introduction ...... 51 Analysis of Effects on Natura 2000 Sites ...... 51 Management for Nature Conservation Purposes ...... 52 Plan Analysis...... 52 Analysis of Potential Significant Effects on Features of Natura 2000 Sites...... 76 6. Other Relevant Plans or Projects ...... 92 7. Counteracting Measures ...... 94 Introduction ...... 94 Identified Likely Significant Effects...... 94 Counteracting Measures...... 95 8. Conclusion ...... 103 Bibliography ...... 104

3 1. Introduction

1.1 This report details the findings of the Habitat Regulations Assessment (HRA) process of the West Somerset District Council Local Plan (formerly known as the draft LDF Core Strategy). As the ‘competent authority’ under the Conservation of Habitats and Species Regulations 2010, West Somerset District Council (WSDC) is required to assess its Local Plan through the HRA process as policies in the plan can potentially affect Natura 2000 sites under the Conservation of Habitats and Species Regulations 2010 (the ‘Habitats Regulations’).

1.2 The Local Plan will set out WSDC's spatial vision and objectives for sustainable development, including housing and other development in its administrative area. Policies will guide decisions on planning applications and appeals.

1.3 Natura 2000 sites, for the purpose of considering development proposals that may affect them, include European Sites - Special Protection Areas (SPA) classified under the EC Birds Directive 1979 and Special Areas of Conservation (SAC) and candidate Special Areas of Conservation (cSAC) designated under the EC Habitats Directive 1992, and, as a matter of Government policy, all Ramsar sites as if they are fully designated European Sites for the purpose of considering development proposals that may affect them. Ramsar sites are those designated under the Ramsar Convention on Wetlands 1971.

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

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

1.6 West Somerset District lies on the north coast of the south west peninsula between North and Districts. More than half of the District’s area is within the Exmoor National Park (which has its own local planning authority). About three quarters of West Somerset’s 35,400 population10 (ONS Mid 2010 estimate) lives within the area for which this Local Plan is being prepared, outside the National Park. Figure 1 shows the Local Plan in relation to the National Park and Nature 2000 sites. About two thirds of the Local Plan

4 area’s population (c.18,000 out of c.27,000 people) live on or near the coast in the three main settlements of , and .

1.7 The Local Plan area comprises:

• a coastal zone between Minehead in the west and Peninsula in the east, • the north western part of the notable for its exposed, moorland character, • to the south, part of the Hills and • a further, detached southern area at Brushford in the to the south of Exmoor.

The area’s geography is complex ranging from the coastal levels, parts of which are vulnerable to sea flooding between Blue Anchor and Minehead and at the , and the Brendon and Quantock Hills rising to over 300 metres.

5 2. Screening Exercise

2.1 The Department for Communities and Local Government’s (DCLG) consultation document ‘Planning for the Protection of European Sites: Appropriate Assessment’ (August 2006). This document gives three main tasks to the Appropriate or Habitats Regulations Assessment1 process:

1. Likely significant effects

2. Appropriate assessment and ascertaining the effect on site integrity

3. Mitigation and alternative solutions

2.2 The process is further detailed in ‘The Appropriate Assessment of Spatial Plans in ’, published by the Royal Society for the Protection of Birds (Dodd et al, 2007).

2.3 The RSPB guidance (2007) sets out a 3-step approach to appropriate assessment as follows.

Step 1: Screening for likely significant effects. This is the initial evaluation of a plan’s effects on a Natura 2000 site. If it cannot conclude there will be no significant effect upon any Natura 2000 site, an AA is required. In the DCLG guidance this is called evidence gathering.

Step 2 Appropriate Assessment – scoping and further information gathering Preparation for the AA where the screening has shown there is likely to be significant effects or where there is uncertainty about a potential significant effect upon a Natura 2000 site.

Step 3 Appropriate Assessment An evaluation of the evidence gathered on impacts and consideration of whether changes to the plan are needed to ensure that it will have no significant adverse effect upon any Natura 2000 site. This should be the end of the AA process and the plan can be adopted.

2.4 This report contains Step 1 of the process and compiles information in order to assess the likely effects of potential policy options and development proposals contained within the Local Plan on Natura 2000 sites alone, or in combination with other plans or projects.

1 Note that the terms Habitats Regulations Assessment and Appropriate Assessment have been used interchangeably. However, for the purpose of this report the term Appropriate Assessment will refer to Step 3 of the Habitats Regulations Assessment process.

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2.5 When carrying out this screening, it must be viewed as a coarse filter and therefore a ‘Precautionary Approach’ has been taken in the assessment of significance. The EC Guidance sets out a number of principles as to how to approach decision making during the process. The primary one is the ‘Precautionary Principle’, which requires that the conservation objectives of Natura 2000 sites should prevail where there is uncertainty. In other words if the answer is ‘don’t know’ an adverse impact is assumed. This is the case throughout the AA process.

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

2.7 and other relevant stakeholders will be consulted on the screening opinion to ensure all elements of the plan are considered which, either alone or in-combination, have the potential for a significant effect on relevant sites. This will help the National Park Authority identify potential impacts, likely pathways for those impacts and key indicators to be used for identifying impacts. The screening should therefore look at the significant effects of the plan objectives and of each individual policy.

2.8 This screening report will include the following information for the Natura 2000 sites:

• Why the site is important for wildlife, i.e. the features (species and habitats) for which the site was designated;

• The conservation objectives for the site;

• The latest assessment of the site’s ecological condition; and

• Any particular problems or sensitivities of the site’s features that could be affected by a plan’s policies or proposals

7 3. Characteristics and Description of the Natura 2000 Sites

Introduction 3.1 This section identifies which Natura 2000 sites are potentially affected

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

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

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

Identification of Natura 2000 sites 3.5 The following Natura 2000 sites have component sites present within the geographic area administered by West Somerset District Council.

• Exmoor and Quantock Oak Woodlands SAC • SPA/ SAC / Ramsar

3.6 A further review for other Natura 2000 sites potentially affected within 10 kilometres of the WSDC boundary has been carried out in Table 1 through consideration of impacts identified in Chapter 4, such as such as from land use change to areas in the District which nonetheless form part of the ecological functioning of the sites.

Table 1: Screening Natura 2000 Sites outside Somerset Natura 2000 Site Designated Features Screening Conclusion Exmoor Heaths Wet heath, dry heath, Included. The site is potentially affected by increased SAC vegetated cliffs, recreational pressure from development in the blanket bogs, alkaline administrative area of WSDC. There may also be issues fens, sessile oak with air quality and hydrology. woodland

Culm Molinia meadows, wet Not included as SAC is not linked hydrologically to the Grasslands SAC heath, marsh fritillary District, it would not be influenced by improved walking and butterfly cycling access and infrastructure such as cycle ways and would not effect habitat within the dispersal range of marsh fritillaries (Fowles, 2003)

8 Natura 2000 Site Designated Features Screening Conclusion Holm Moor and Calcareous fens: Not included as SAC is not linked hydrologically to the Clean Moor SAC alkaline fens; Molinia National Park meadows

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Map 1: Natura 2000 Sites

10 Ecological Zones of Influence 3.7 Natura 2000 sites are designated for both species and habitat features. Conservation objectives and targets relate to maintaining the integrity of these features. This section describes how ‘Ecological Zones of Influence’ (EZI) are arrived at for each of the Natura 2000 sites potentially affected by the implementation of the Local Plan. These are areas outside the designated Natura 2000 site, which nonetheless if affected can adversely impact on the integrity of the site’s conservation objectives. For example, bat flight lines and feeding areas supporting a designated roost site if lost may affect the viability of the population.

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

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

3.10 Finally all the EZI for each of a site’s features, i.e. the site itself, its species and habitats, are combined into one EZI per site. A map of the EZI is given at the end of this chapter.

Description and Characterisation of Natura 2000 Sites

Exmoor Heaths SAC

Component Sites 3.11 Component SACs sites are:

North Exmoor SSSI South Exmoor SSSI Exmoor Coastal Heaths SSSI West Exmoor Coast and Woods SSSI

11 Site Condition 3.12 Based on the tables for the equivalent Site of Scientific Interest the condition of the affected components, by % of site, is as follows:

Table 2: Exmoor Heaths Condition Summary SAC component site Favourable Unfavourable Unfavourable Unfavourable Destroyed, recovering no change declining part destroyed North Exmoor 16.77 78.93 4.00 0.30 0

South Exmoor 0 99.06 0.62 0.32 0

Exmoor Coastal Heaths 8.25 89.65 0 2.1 0

West Exmoor Coast & Woods 12.62 85.37 0.07 1.94 0

The condition also includes areas outside of the SAC. The North Exmoor SAC component of the SSSI is 100% favourable.

Determining Reasons for Designation 3.13 The North Exmoor component site is a southern outpost of typically northern and upland elements of Britain's flora and fauna. The site is nationally important for its south-western lowland heath communities and for transitions from ancient semi- natural woodland through upland heath to blanket mire. The site is also of importance for its breeding bird communities, its large population of the nationally rare Heath Fritillary butterfly Mellicta athalia, an exceptional woodland lichen flora and its palynological interest of deep peat on the . The site is in two main blocks: the major one to the North and a smaller one by to the South. The highest point, Dunkery Beacon, is 519 metres above sea level, the lowest heathland is at about 250 metres and the site extends down to 80 metres in woodland.

3.14 South Exmoor contains extensive areas of heathland including lowland communities which are only found in South West England and South . Transitions between these communities and upland heathland, and semi-natural scrub and woodland, are important because they are not well represented in the South West outside Exmoor. Other important components of the site are acidic and more mesotrophic mires, and wet heath communities found only rarely elsewhere on Exmoor. There is a diverse assemblage of breeding birds typical of mixed heathland and scrub. There is one large colony of the nationally rare Heath Fritillary butterfly (Mellicta athalia).The site includes the five main blocks of heath and moorland vegetation to the southern part of Exmoor: Anstey and Molland Commons, Common, Winsford Hill, NorthMolton Ridge and Barcombe Down, and .

12 3.15 Exmoor Coastal Heaths This site contains extensive areas of heathland communities which are rare in Britain or confined largely to South West England and South Wales. The site is also important for the presence, range and transitions between habitats including upland heath, mires and grassland. At lower altitudes and in the coastal zone further important habitats occur including woodland and scrub, acidic and maritime grassland. Associated particularly with the coastal communities and woods are a wide range of nationally rare and scarce plants. A breeding colony of a nationally rare butterfly also occurs. The site comprises four separate blocks (between Combe Martin and Minehead) centred on Trentishoe, Cosgate Hill, Countisbury and North Hill.

3.16 West Exmoor Coast and Woods supports important areas of ancient sessile oak woodland, maritime plant communities, an outstanding coastal lichen flora in the Valley of Rocks and a rich bird population. There are also three important geological features represented within the site. The north-facing cliffs rise steeply from the rocky shore platform to over 200m and are composed of sand-stones and shales. These have given rise to shallow and well-drained, coarse, loamy soils. The exposed cliffs support typical maritime plant communities, including heather (Calluna vulgaris), bilberry (Vaccinium myrtillus), bell heather (Erica cinerea) and western gorse (Ulex gallii) in heathland areas and thrift (Armeria maritima), rock sea-spurrey (Spergularia rupicola), buck’s-horn plantain (Plantago coronopus) and common scurvy-grass (Cochlearia officinalis) on the ledges and turf slopes. Poorly vegetated scree occurs on the steepest slopes, particularly in Heddon’s Mouth Cleave, but where shelter permits, woodland has developed such as at Neck Wood and Woody Bay.

3.17 Exmoor is representative of upland wet heath in south-west England. Exmoor Heath SAC is designated for the presence of Northern Atlantic wet heaths with Erica tetralix habitat. M152 Scirpus cespitosus – Erica tetralix wet heath predominates on gently-sloping and level ground. It is extremely variable in nature and has in places been modified by management, particularly burning. Typically, heather Calluna vulgaris dominates, with scattered plants of purple moor-grass Molinia caerulea, cross-leaved heath Erica tetralix, bilberry Vaccinium myrtillus and deer grass Trichophorum cespitosum. In other areas Molinia and Calluna are more-or-less co-dominant, with the former forming tussocks. There are transitions to H12 Calluna vulgaris – Vaccinium myrtillus heath on well-drained, steeper slopes and to M17 Scirpus cespitosus – Eriophorum vaginatum blanket mire on deeper peat, where the northern species crowberry Empetrum nigrum occurs.

3.18 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the Northern Atlantic wet heaths with Erica tetralix’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

2 Reference numbers refer to the National Vegetation Classification described in Rodwell, J. S. (ed.) 1998/2000. British Plant Communities. Volumes 1 – 5. Cambridge: University of Cambridge Press.

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• Extent • Dwarf-shrub diversity and cover • Bryophyte abundance • Age structure • Graminoid cover • Grazing impact • Vegetation mosaic • Water quality and soil nutrient status • Hydrology

3.19 Exmoor Heath SAC is also designated for the presence of European dry heaths. The site is notable because it contains extensive areas of H4 Ulex gallii – Agrostis curtisii heath, a type most often found in the lowlands, and H12 Calluna vulgaris – Vaccinium myrtillus heath, a predominantly upland type, together with areas of H8 Calluna vulgaris – Ulex gallii heath. In wetter situations or on peat there can be a high frequency of purple moor-grass Molinia caerulea and cross-leaved heath Erica tetralix, which results in frequent transitions to wet heaths. The associated valley mires support the oceanic species pale butterwort Pinguicula lusitanica and ivy-leaved bellflower Wahlenbergia hederacea. The Exmoor heaths are also important as the largest stronghold for the heath fritillary butterfly Mellicta athalia, associated with sheltered slopes in the transition to woodland. The site holds a small breeding population of merlin Falco columbarius that is the most southerly in the western Palearctic.

3.20 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the European dry heaths’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• Extent • Bryophyte / lichen abundance • Dwarf-shrub diversity and cover • Grazing impact • Vegetation structure • Vegetation mosaic • Soil structure and nutrient status • Species characteristic of the site: Heath Fritillary

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

14 influence. Exposure to the sea is a key determinant of the type of sea cliff vegetation. The long fetch associated with these coasts generates high waves and swell, and the prevailing winds help deliver salt spray to the cliff face and cliff tops. However, the degree to which this affects the salinity of cliff-top vegetation also depends on the amount of rainfall, Cliff structure and geomorphological processes are major influences on cliff vegetation.

3.22 Cliff-top heath vegetation is included in the Annex I definition, and comprises maritime heath communities referable to NVC types H7 Calluna vulgaris – Scilla verna heath and H8d Calluna vulgaris – Ulex gallii heath S. verna sub- community. Cliff-top heath vegetation may extend landward into non-maritime zones, where it is considered as part of Annex I type European dry heaths.

3.23 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the Vegetated Sea Cliffs of the Atlantic and Baltic Coasts’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• Extent • Bryophyte abundance • Dwarf-shrub diversity & cover • Graminoid cover • Grazing impact • Extent of bare ground or ground covered by algal mats • Hydrology

3.24 Blanket bogs are a feature of the Exmoor Heaths SAC. These extensive peatlands have formed in areas where there is a climate of high rainfall and a low level of evapotranspiration, allowing peat to develop not only in wet hollows but over large expanses of undulating ground. The blanketing of the ground with a variable depth of peat gives the habitat type its name and results in the various morphological types according to their topographical position, e.g. saddle mires, watershed mires, valley side mires.

3.25 Blanket bogs show a complex pattern of variation related to climatic factors, particularly illustrated by the variety of patterning of the bog surface in different parts of the UK. Such climatic factors also influence the floristic composition of bog vegetation. An important element in defining variation is the relative proportion of pools on the bog surface. In general, the proportion of surface patterning occupied by permanent pools increases to the north and west, although the precise shape and pattern of pools appears to depend on local topography as well as geographical location. Variety within the bog vegetation mirrors this pattern and is also affected by altitude. Similarly, the number of associated habitats and communities, such as springs, flushes, fens and heath,

15 is greater in the milder, wetter and geologically and topographically more complex north and west.

3.26 ‘Active’ is defined as supporting a significant area of vegetation that is normally peat-forming. Typical species include the important peat-forming species, such as bog-mosses Sphagnum spp. and cotton grasses Eriophorum spp., or purple moor-grass Molinia caerulea in certain circumstances, together with heather Calluna vulgaris and other ericaceous species. Thus sites, particularly those at higher altitude, characterised by extensive erosion features, may still be classed as ‘active’ if they otherwise support extensive areas of typical bog vegetation, and especially if the erosion gullies show signs of re-colonisation.

3.27 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the Blanket bogs’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• Extent • Bryophyte abundance • Dwarf-shrub diversity & cover • Graminoid cover • Grazing impact • Extent of bare ground or ground covered by algal mats • Hydrology

3.28 Alkaline fens form another feature of the Exmoor Heaths SAC. They consist of a complex assemblage of vegetation types, characteristic of sites where there is tufa and/or peat formation with a high water table and a calcareous base-rich water supply. The core vegetation is short sedge mire (mire with low-growing sedge vegetation). At most sites there are well-marked transitions to a range of other fen vegetation, predominantly, but not exclusively, to M14 Schoenus nigricans – Narthecium ossifragum mire and S24 Phragmites australis – Peucedanum palustre tall-herb fen in the lowlands. Alkaline fens may also occur with various types of swamp (such as species-poor stands of great fen-sedge Cladium mariscus), wet grasslands (particularly various types of purple moor- grass Molinia caerulea grassland) and areas rich in rush Juncus species, as well as fen carr and, especially in the uplands, wet heath and acid bogs. There is considerable variation between sites in the associated communities and the transitions that may occur. Such variation can be broadly classified by the geomorphological situation in which the fen occurs, namely: flood plain mire, valley mire, basin mire, hydroseral fen (i.e. as zones around open waterbodies) and spring fen. Another important source of ecological variation is altitude, with significant differences between lowland fens, which are rich in southern and continental species, and upland fens, which are rich in northern species.

16 3.29 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the Alkaline fens’ (Natural England conservation objectives). The attributes that measure the condition of the feature are sward structure and composition.

3.30 In conjunction with heaths this site also supports tracts of old sessile oak woods. These woods are rich in bryophytes, ferns (including Dryopteris aemula) and epiphytic lichens, the latter often associated with old pollards, since parts are former wood-pasture rather than the oak coppice that is more common with this type.

3.31 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the old sessile oak woods with Ilex and Blechnum in the British isles’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• Area • Natural processes and structural development • Regeneration potential • Composition • Distinctive and desirable elements: 1. Rich Atlantic bryophyte communities. 2. Epiphytic lichens 3. Western oakwood 4. Breeding bird community. 5. River, stream and mires. 6. Transition to open heath with c. 3 km of wood/heath edge & Heath Fritillary colony. 7. Heronry

Table 3: Exmoor Heaths SAC Key Environmental Conditions

Qualifying features Key environmental conditions to support site integrity Northern Atlantic wet heaths with Erica Air quality tetralix Soil conditions

Hydrological conditions

Appropriate management

Control of inappropriate invasive species

17 Qualifying features Key environmental conditions to support site integrity European dry heaths Air quality

Appropriate management

Soil conditions

Control of inappropriate invasive species

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

Appropriate management

Blanket bogs Appropriate management

The control of inappropriate and invasive species.

Hydrology

Water quality

Air quality

Alkaline fens Topography

Hydrology

Drainage

Water quality

Soil conditions

Appropriate management

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

Ecological Zone of Influence 3.32 For the purposes of this assessment it is considered that the EZI lies entirely within the site boundary as any impacts are only likely to be from visitor pressure. However, there may also be air quality impacts as a result of increased highways usage resulting from the proposed developments in the Local Plan.

18 Vulnerability 3.33 These heathlands retain significant areas of mature heather stands. This habitat is dependent upon low intensity, traditional agricultural management by grazing and controlled burning. Such management is becoming less economic, except with agri-environment funds. Agri-environment schemes such as the Environmentally Sensitive Area Scheme and more recently the Higher Level Stewardship Scheme have been useful in promoting traditional grazing management, as have other management agreements and conservation body ownership. Illegal and uncontrolled burning is adversely affecting heathland structure in some areas, and localised winterfeeding of cattle and overgrazing has caused some losses to heathland in the past although these have been largely resolved through prescriptions in agri-environment agreements. Incentive payments are currently seen as the only effective means of influencing burning practices. Rhododendron has spread in some areas, and work to eliminate it from heathland sites has been funded through National Park Authority grants and conservation plans which form part of Natural England’s agri-environment scheme agreements.

3.34 This site is also vulnerable to atmospheric deposition and eutrophication.

Exmoor and Quantocks Oak Woodlands SAC

Component Sites 3.35 Component SACs sites are:

Barle Valley SSSI North Exmoor SSSI The Quantocks SSSI West Exmoor Coast & Woods SSSI Watersmeet SSSI

Site Condition 3.36 Based on the tables for the equivalent Site of Special Scientific Interest the condition of the affected components, by % of site, is as follows:

Table 4: Exmoor and Quantock Oak Woodlands Condition Summary S\AC Favourable Unfavourable Unfavourable no Unfavourable Destroyed, component site recovering change declining part destroyed Barle Valley 7.64 87.93 1.66 2.77 0

North Exmoor 16.77 78.93 4.00 0.30 0

The Quantocks 7.70 84.64 4.54 3.12 0

19 S\AC Favourable Unfavourable Unfavourable no Unfavourable Destroyed, component site recovering change declining part destroyed West Exmoor 12.62 85.37 0.07 1.94 0 Coast & Woods

Watersmeet 0.41 92.98 6.61 0 0

Determining Reasons for Designation 3.38 The Barle Valley component site contains extensive tracts of ancient upland sessile oak woodland which exhibit variations in structure and species composition as a result of difference in past management, geology and topography. There is a wide range of vascular plants including many indicators. The diversity of the site is increased substantially by areas of valley mire, heathland and acid grassland. The richness of lichens and bryophytes is of exceptional national importance and is significant internationally. There is also an outstanding assemblage of breeding woodland birds and high invertebrate interest including nationally vulnerable and scarce species.

3.39 North Exmoor is a southern outpost of typically northern and upland elements of Britain's flora and fauna. The site is nationally important for its south-western lowland heath communities and for transitions from ancient semi-natural woodland through upland heath to blanket mire. The site is also of importance for its breeding bird communities, its large population of the nationally rare Heath Fritillary butterfly Mellicta athalia, an exceptional woodland lichen flora and its palynological interest of deep peat on the Chains. The site is in two main blocks: the major one to the North and a smaller one by Simonsbath to the South. The highest point, Dunkery Beacon, is 519 metres above sea level, the lowest heathland is at about 250 metres and the site extends down to 80 metres in woodland.

3.40 The woodland in the Quantocks component of the site is ancient and semi- natural, with three major stand types. Birch/sessile oak woodland is present in Holford Combe, Hodder's Combe, Shervage Wood and Five Lords where sessile oak Quercus petraea dominates the canopy. Understorey species include downy birch Betula pubescens, holly Ilax aquifolium, rowan Sorbus sucuparia, and hawthorn Crataegus monogyna, The ground flora tends to be dominated by wavy hair-grass, bilberry and common cow-wheat but hairy wood-rush Luzula pilosa, honeysuckle Lonicera periclymenum and heather are also present. These woodlands have an interesting management history. They used to be managed as coppice for charcoal production and tanning and with the exception of the more exposed portions that are severely wind-pruned, are now developing into high forest. A number of the standards have been pollarded in the past. Alfoxton Wood supports a magnificent stand of mature sessile sak. Valley Alder woodland dominated by alder Alnus glutinosa occurs alongside many of the streams. Ash/wych elm woodland is present on more neutral soils in Holford Glen where

20 ash Fraxinus excelsior and wych elm Ulmus glabra form the canopy. Understorey species include hazel Corylus avellana, field maple Acer campestre, and blackthorn Prunus spinosa. The ground flora is dominated in many of the drier areas by dog's mercury Mercurialis perennis or by pendulous sedge Carex pendula on wetter soils. ramsons Allium ursinum is present on flushed slopes. Scrub has developed on many parts of the hills; especially around the margins of the woodlands. An unusual feature is the way in which holly is colonising some areas of open ground. Scattered bushes of hawthorn, holly, rowan, sessile oak and downy birch are frequent on less exposed slopes.

3.41 West Exmoor Coast and Woods supports important areas of ancient sessile oak woodland, maritime plant communities, an outstanding coastal lichen flora in the Valley of Rocks and a rich bird population. There are also three important geological features represented within the site. The north-facing cliffs rise steeply from the rocky shore platform to over 200m and are composed of sand-stones a nd shales. These have given rise to shallow and well-drained, coarse, loamy soils. The exposed cliffs support typical maritime plant communities, including heather (Calluna vulgaris), bilberry (Vaccinium myrtillus), bell heather (Erica cinerea) and western gorse (Ulex gallii) in heathland areas and thrift (Armeria maritima), rock Sea-spurrey (Spergularia rupicola), buck’s-horn plantain (Plantago coronopus) and common scurvy-grass (Cochlearia officinalis) on the ledges and turf slopes. Poorly vegetated scree occurs on the steepest slopes, particularly in Heddon’s Mouth Cleave, but where shelter permits, woodland has developed such as at Neck Wood and Woody Bay.

3.42 Watersmeet encompasses an extensive area of ancient oak woodland, of special interest as one of the largest remaining semi-natural ancient woodlands in south west Britain; with rare and local plant species and rich breeding bird populations. The site also has important geological features. It occupies the winding valley system of the and its tributaries, with an altitude range from near sea level to 290m. The generally shallow soils are derived from the underlying Devonian sandstones and slates and are of a fine loamy or silty nature.

3.43 This SAC supports extensive tracts of old sessile oak woods in conjunction with heath. They are rich in bryophytes, ferns (including Dryopteris aemula) and epiphytic lichens, the latter often associated with old pollards, since parts are former wood-pasture rather than the oak coppice that is more common with this type.

3.44 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for the old sessile oak woods with Ilex and Blechnum in the British isles’ (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• Age/size class variation within and between stands; presence of open space and old trees; dead wood lying on the ground; standing dead trees

21 • Successful establishment of young stems in gaps or on the edge of a stand • Cover of native versus non-native species (all layers) • Death, destruction or replacement of native woodland species through effects of non-native fauna or external unnatural factors • Ground flora type • Distinctive and desirable elements: 1. Rich Atlantic bryophyte communities. 2. Western oakwood 3. Breeding bird community. 4. Streams and mires. 5. Transitions to alder wood. 6. Transition to open heath with c. 15km of wood/heath edge • Air quality measures • Presence of undesirable indicator species

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

3.46 Many such woods are dynamic, being part of a successional series of habitats. Their structure and function are best maintained within a larger unit that includes the open communities, mainly fen and swamp, of earlier successional stages. On the drier margins of these areas other tree species, notably ash Fraxinus excelsior and elm Ulmus spp., may become abundant. In other situations the alder woods occur as a stable component within transitions to surrounding dry- ground forest, sometimes including other Annex I woodland types.

3.47 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, the habitats for Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae) [Natural England conservation objectives]. The attributes that measure the condition of the feature are:

• Age/size class variation within and between stands; presence of open space and old trees; dead wood lying on the ground; standing dead trees • Structures associated with the hydrological regime • Successful establishment of young stems in gaps or on the edge of a stand • Cover of native versus non-native species (all layers) • Death, destruction or replacement of native woodland species through effects of non-native fauna or external unnatural factors

22 • Ground flora type • Distinctive and desirable elements: • Epiphytic lichens (see Old sessile oak woods) • Transitions to old sessile oak woods. • Streams and mires.

3.48 There is a maternity colony of Barbastelle Bat Barbastella barbastellus utilising a range of tree roosts in this area of predominantly oak woodland on the Exmoor site. However, recent survey has indicated barbastelle bats are also roosting within the Quantocks component site. Foraging areas can lie several kilometres from the roost sites.

3.49 Barbastelle bats prefer riparian vegetation, broad leaved woodland, unimproved grassland, improved grassland, scrub, mixed woodland and coniferous woodland but avoid urban, upland moor, arable habitats and areas of open water (Zeale, 2009). Over 90% of barbastelle bats from Horner wood in Somerset foraged along linear wooded scrub strips including along watercourses, overgrown hedgerows, uncut grassland, heather moorland edge (within Exmoor Heath SAC), gardens and areas of low level street lighting. Gorse was also important. (Billington, 2002)

3.50 Barbastelle bats go out in groups from the roosting area then disperse to individual hunting grounds (Dietz et al, 2009; Greenway, 2001; Greenway, 2004; Zeale, 2009). Barbastelle bats are reliant on darkened connecting habitat features between roost sites and feeding areas. Typically these are along vegetated rivers and streams or lines of trees and large hedgerows and paths between these. (Greenaway, 2004) Barbastelle bats’ foraging paths are generally within 200 metres of water features (Greenaway, 2008). When barbastelle bats are crossing open ground they will fly low level (Greenaway, 2008).

3.51 The summer foraging range of barbastelle bats was recorded as being up to 9 kilometres in the Horner Wood area on Exmoor (English Nature, Conservation Objectives for North Exmoor SSSI). Other studies have shown that barbastelle bats can fly up to 20 kilometres from roost sites although the average was about 8 kilometres (Greenway, 2004). On the individual mean maximum foraging range of radio tracked barbastelle bats varied from 3.16 to 20.38 kilometres (Zeale, 2009).

3.52 Foraging takes place within the home range in core areas of between 2 and 70 hectares (Boye & Dietz, 2005). Dietz et al (2009) report foraging areas of 8.8 hectares with single bats hunting each night in up to 10 separate areas. There is minimal overlap of individual core foraging areas although the home wood is shared (Zeale, 2009).

3.53 Current factors considered to be causing loss or decline in barbastelle include:

23

• Loss or fragmentation of foraging habitats • Loss/ disruption of flyway, e.g. woodland edges, mature hedge banks • Loss, destruction or disturbance of roost sites • Loss of cover in the vicinity of roost sites • Disturbance of underground swarming sites

(Bat Conservation Trust/ BMT Cordah Ltd., 2005)

3.54 Bechstein’s bat Myotis bechsteinii has not been recorded in the Quantocks component site. However, as the foraging areas can lie several kilometres from the roost sites the species is considered.

3.55 Bechstein’s bat is a woodland species. They prefer semi natural or ancient woodland but will make use of oak and mixed forestry plantations. Most summer roost sites for Bechstein’s bats are in woodpecker holes, although sometimes they use loose bark or tree crevices. They change roosts nearly every day and therefore large number of sites are required, perhaps as many as 50. (Greenway, 2004) In one colony the actual roost site was a hedgerow tree 3.5 kilometres from the main plantation foraging area. Hedgerow trees are not uncommon for colonies foraging in plantations, as frequently they are the only trees available with woodpecker holes (Fitzsimmons et al, 2002)

3.56 The standard pattern of foraging within a colony is for suitable canopy areas within woodland to be divided between individuals. About 50 hectares of mature oak with good understorey and small streams is ideal. (Greenway, 2004) Other woodland would need to be larger to sustain a colony, for example coniferous woodland home ranges of 100 hectares per individual have been recorded. (Boye & Dietz, 2005; Fitzsimmons et al, 2002) Bechstein’s bats have a small range of movement around summer roost of about 1 kilometre. The main foraging areas are usually from 500 to1500 metres from the roost. Sometimes they will fly up to 3.8 kilometres. Foraging range is smaller in continuous woodlands than those in fragmented forests. (Boye & Dietz, 2005; Fitzsimmons et al, 2002) Radio tracking of Bechstein’s bats from Bracket’s Coppice was carried out in 1998 and 1999 by the Vincent Wildlife Trust in the months between May and August. The maximum range of foraging was 0.98 kilometres from a roost site within the woodland. (Schofield & Morris, 2000) At Ebernoe in Sussex the distance from roost site to the middle of foraging area was an average of 700 metres with a maximum of 1.4 kilometres (Fitzsimmons et al, 2002).

3.57 Bechstein’s bats are also sensitive to artificial lighting, which can disrupt or deny habitat use (Outen, 2002; BCT/ILE, n/d).

3.58 Maternity colonies form socially closed units with all the females being related over the summer period from May to August. During this period males occupy

24 separate roosting areas, often in sub-optimal habitat (Schofield and Greenaway, 2008; Safi. & Kerth, 2003; Fitzsimmons et al, 2002).

3. 59 Maternity colonies disperse at the end of August and swarm at underground sites to mate (Dietz et al, 2009). Swarming sites have been recorded 4.5 kilometres away from maternity roost sites (Schofield & Morris, 2000).

3.60 Following swarming hibernation roosts are used over the winter usually in caves, tunnels or cellars but tree holes may be used (Schofield & Greenaway, 2008; Boye & Dietz, 2005). Movements between summer and winter roosts are usually less than 10 kilometres but can be up to 73 kilometres (Schofield & Greenaway, 2008; Dietz et al, 2009)

3.61 The conservation objective for the features are ‘To maintain, subject to natural change, in favourable condition, the Barbastelle and Bechstein’s Bats (Natural England conservation objectives). The attributes that measure the condition of the feature are:

• No loss of ancient semi-natural stands • Current area of semi-natural woodland to be retained • At least the current level of structural diversity maintained. • Canopy cover present over 50-90% of area • A minimum of 4 trees per ha allowed to die standing • Signs of seedlings growing through at sufficient density to maintain required canopy cover over a 10-year period • Current length and extent of woodland/moorland scrub edge to be retained • No overall loss of open water • Human access to roost area controlled and limited; no significant increase since previous visit

3.62 Otter Lutra lutra are found on all types of watercourse including canals, ponds, lakes and reservoirs. They use tiny ditches and streams including dry watercourses as regular commuting routes. They may also cross overland between watersheds and will short cut across bends in rivers. (Chanin, 2003)

3.63 Otter in Somerset are generally nocturnal and use undisturbed holts and couches in which to rest up. Couches occur in thick vegetative cover. Otter holts are usually tunnels in riverbanks among roots and boulders. Holt sites, used for lying up and breeding areas are located in areas away from human disturbance and can occur up to 50 metres away over dry land (Chanin 1993). Holts are known to occur in urban areas but are likely to be closer to a watercourse than in a rural setting.

3.64 Natal holts seem to be located away from main watercourses and from water altogether even being found 500 metres away. Most sites are within 3.5 metres of

25 water although have been recorded 40 metres from a lake edge and 100 metres in a young conifer plantation. Breeding sites are generally located on but not restricted tributary streams (width 0.7 to 4 metres). (Chanin, 2003)

3.65 Main habitat types for otter breeding sites are: reed beds; ponds and lakes; deciduous woodland (ranging from 20 metre strip to several hectares; young conifer plantations; and extensive areas of scrub. Structures or buildings immediately adjacent to a watercourse may be used occasionally. Mature sycamore and ash trees are important as potential holt sites and holt density is higher in areas dominated by peat. (Liles, 2003)

3.66 Otter breeding sites require security from disturbance; one or more potential natal den sites; play areas for cubs; no risk of flooding; and access to good food supply. (Liles, 2003)

3.67 The presence of ash or sycamore trees along river banks is particularly important to otters as the roots of these species provide the majority of den sites. Other species used include rhododendron bushes, oak and elm trees. Bankside vegetation, such as woodland and scrub, can provide cover for otters. They also use reed beds and islands as rest sites and marshy areas to forage for frogs. Optimal habitat includes stream banks with dense herbaceous vegetation and fringes of trees (e.g. alder) with branches hanging low near the water, lakes, coastlands, rivers and marshes. (Chanin, 2003)

3.68 A dog otter requires about 20 kilometres of lowland river by about 20 metres wide as territory whilst a bitch requires about 11 kilometres (Wayre, 1979). Estimates for area of water occupied vary between 2 hectares and 50 hectares per otter. This is equivalent to one individual every 3–50km of stream (median value of one otter per 15 km of stream) (Chanin, 2003). An otter territory is approximately 15 to 20 kilometres long in Somerset or approximately three riverside parishes (pers. comm. James Williams, Somerset Otter Group).

3.69 Current factors considered to be causing loss or decline in otters include:

• Road mortality • Pollution events • Loss or fragmentation of habitat • Human disturbance • Liver fluke (introduced from ‘alien’ fish species)

3.70 The conservation objective for the feature is ‘To maintain, subject to natural change, in favourable condition, Otter’. The attributes that measure the condition of the feature are water quality, flow rate, site integrity, fish stocks, disturbance, bank side cover and the presence of otters.

26

Table 5: Exmoor and Quantock Oak Woodlands Qualifying Features

Qualifying features Key environmental conditions to support site integrity Old sessile oak woods with Ilex Appropriate woodland management (holly) and Blechnum (fern) in the British Isles Air quality

Alluvial forests with Alnus glutinosa Appropriate woodland management (alder) and Fraxinus excelsior (ash) Hydrology

Barbastelle bat Barbastella barbastellus Undisturbed roosts

Woodland management

Availability of decaying and veteran trees

Bechstein’s bat Myotis bechsteinii Maintenance and connectivity of habitats used as flight lines on and off site

Feeding areas

Otter Lutra lutra Maintenance of river water quality and flow

Fish stocks

Bankside vegetation

Levels of disturbance

Ecological Zone of Influence 3.71 The woodland habitats are sensitive to changes in hydrology and to changes in air quality. The habitat therefore may be influenced outside the SAC by air pollution resulting from issues set out in Chapter 6. Any watercourse entering and upstream of the site in the catchment is mapped by enclosing within a Minimum Convex Polygon (MCP).

3.72 For components of the SAC where barbastelle bats are present a buffer of 9 kilometres around the maternity roost site area is formed. The area of likely habitat use is then digitised by copying whole polygons from OS Mastermap, particularly flyways through woodland and along watercourses and hedgerows in

27 unfragmented corridors connecting to the roost area. This process uses aerial photographic interpretation and available radio tracking data (Billington, 2000). This forms the EZI for barbastelle bats.

3.73 For components of the SAC where Bechstein’s bats are present a buffer of 3.8 kilometres around the maternity roost site area is formed. Starting with maternity roosts, woodland feeding areas are digitised by copying whole polygons from OS Mastermap, as are any connecting flyways to other woodland blocks. This forms the EZI for Bechstein’s bats.

3.74 There are records of otters for every watercourse within the SAC. The watercourses are digitised for 10 kilometres both sides of a record and then buffered by an extent of 500 metres. Otter holts can be located up to 500 metres along small side streams (Chanin, 2003).This then forms the Ecological Buffer for otters.

Vulnerability 3.75 Some grazing/browsing is essential to maintain conditions suitable for lower plant assemblages, which are a key feature of the woodlands. However, sheep and/or red deer graze many woods and this can prevent regeneration and change the ground flora. Invasive non-native species such as Rhododendron are a problem in some woods and beech continues to be problematic in many sessile oak woodlands. Conservation bodies or management agreements are eliminating these species. Dense monocultures of coppiced oak occur, of little structural or species diversity., Opportunities are being taken to diversify age and species composition to restore near-natural conditions where possible, especially to encourage important upland breeding bird migrants such as wood warbler, redstart and pied flycatcher for which Exmoor woodlands has a stronghold.

3.76 Drainage and potential impacts of lowering water table (including abstraction) is potentially an issue. In the review of Agency consents, there are seven Agency consented abstraction and two discharge consents identified as potentially having a significant effect on the site.

3.77 There is potential conflict between forestry and woodland management, and potential impacts from surrounding land use (e.g. agriculture, pheasant rearing affecting bats and otter)

Severn Estuary

Component Sites 3.78 The Severn Estuary SPA comprises the following component SSSIs:

28 Bay Severn Estuary Sully Island Upper Severn Estuary Penarth Coast

3.79 The Ramsar site comprises all or parts of SSSI, Flat Holm SSSI, Severn Estuary SSSI, Steep Holm SSSI, Sully Island SSSI and Upper Severn Estuary SSSI. Bridgwater Bay, covering 2,703 ha, was designated as a Ramsar site on 5 January 1976.

3.80 The Severn Estuary SAC contains habitat types and/or species which are rare or threatened within a European context. The SSSI describes the special interests for which the site was notified in the British context. The area is considered to have a high density of habitats/Species of European interest.

3.81 It is considered that only significant effects arising from the Local Plan – potentially affect the Bridgwater Bay SSSI only. Saltmarsh and coastal habitats are present east of and birds listed as features are potentially affected. It is considered that listed fish species would be unaffected lacking streams supporting migratory movements within the District and are therefore omitted from the assessment.

Site Condition 3.82 Based on the tables for the Bridgwater Bay Site of Special Scientific Interest the condition of the affected components, by % of site, is as follows:

Table 6: Bridgwater Bay Site Condition SAC Favourable Unfavourable Unfavourable Unfavourable Destroyed, component recovering no change declining part site destroyed 90.56 7.97 0.90 0.57 0

Determining Reasons for Designation 3.83 The Severn Estuary has a classic funnel shape, unique in the U.K., which helps give it the second highest tidal range in the world at more than 12 metres. This results in a range of terrestrial and aquatic habitats composed of plants and animals typical of extreme conditions of strong flows, mobile sediments, changing salinity and turbid waters.

3.84 The Severn Estuary has extensive intertidal and sand flats, rocky

29 platforms and islands. Salt marsh fringes the coast backed by grazing marsh and freshwater ditches and occasional brackish ditches. The tidal regime results in plant and animal communities typical of the extreme physical conditions of liquid mud and tide swept sand and rock. The species poor invertebrate community includes high densities of ragworms, lugworms and other invertebrates forming an important food source for passage and wintering waders.

3.85 The site is important in the spring and autumn migration periods for waders moving up the coast of west Britain, as well as in winter for large numbers of water birds, especially swans, ducks and waders.

Special Protection Area 3.86 The Severn Estuary supports populations of European importance of over wintering Bewick's swan Cygnus columbianus bewickii. However, this species is not present in the Bridgwater Bay component site. Bridgwater Bay supports populations of European importance of migratory ringed plover Charadrius hiaticula on passage (particularly around the Axe Estaury, Berrow and Brue Estuary) and over wintering populations of curlew Numenius arquata, dunlin Calidris alpina alpina, pintail Anas acuta, redshank Tringa totanus and shelduck Tadoma tadoma.

3.87 Over winter the Severn Estuary regularly supports 72,000 individual waterfowl. In the Bridgwater Bay component site there are important populations of shelduck Tadoma tadoma, dunlin Calidris alpina alpina, curlew Numenius arquata, redshank Tringa totanus, wigeon Anas penelope and teal Anas crecca.

3.88 Shelduck are present in Bridgwater Bay all year. They are present in the Parrett estuary in significant numbers year round (500 - 3000 in 2003; 350 – 3595 in 2006). However, the number of breeding birds is extremely low (Somerset Ornithological Society).

3.89 Shelduck are found on sheltered coast and estuaries where there are sandbars and mud flats. They also visit farmland near the coast. (Holden & Cleeves, 2002) Typically they range up to 1 or 2 kilometres out to sea and a little further inland. (Cramp, 1977) Shelduck nest in burrows, often a rabbit hole, amongst dense vegetation, or other crevices and gaps including under buildings. Eggs are laid in April or May. (Holden & Cleeves, 2002) Shelduck moult in late summer, rendering them flightless for about a month. This makes them particularly sensitive to disturbance during this period. They are likely to seek the shelter out at sea riding the tide out. Also at this time youngsters form crèches. (Holden & Cleeves, 2002; Bob Corns, Natural England pers. comm.)

3.90 The reclamation of intertidal feeding grounds is a threat to Shelduck populations in the U.K. (Duncan et al, 1999)

30 3.91 Wigeon are a winter visitor to Somerset and can be found on coastal estuaries and marshes of Bridgwater Bay in the over winter period between September and March/April. (Somerset Ornithological Society) Wigeon winter along shallow coastlines, in sheltered waters with extensive tracts of or salt marsh (Cramp, 1977). They graze on land or find food in water. It eats mainly vegetation such as grasses, buttercups, algae, pondweed and especially eelgrass, which is found in estuaries. (Holden & Cleeves, 2002)

3.92 Space and visibility are essential for wigeon and they are sensitive to human disturbance such as from recreational activity. (Cramp, 1977; Holden & Cleeves, 2002)

3.93 Teal are present over the winter period from August/September to March/April on the Parrett/Brue estuary. (Somerset Ornithological Society)Teal are found on tidal coasts, in large estuaries, salt marshes and lagoons on passage in winter. They have long established wintering areas. Outside of the breeding season they rest by day in tight packed groups on open water or on the edge of mud flats. As dusk progresses they move progressively towards dense vegetation. In the Carmargue they make flights of up to 15 kilometres between roost sites and feeding areas. (Cramp, 1977)

3.94 Teal find food mostly in shallow water and feeds mainly on the seeds of grasses, rushes and other plants such as pondweed, dock, birch and buttercup. In the summer it also feeds on invertebrates. (Holden & Cleeves, 2002)

3.95 Dunlin are a winter visitor and passage migrant in Somerset and are present in Bridgwater Bay in high numbers (2,000 to 21,000 in 2003; 818 to 24,500 in 2006) between August and March but can be seen in small numbers outside this period. However, 520/583 dunlins were still present in April/ May 2006 (Somerset Ornithological Society)

3.96 Outside the breeding season, dunlins are strongly attracted to broad coastal beeches, especially mudflats but also occur on lagoons and in estuaries, tidal rivers and on lake margins and freshwater bodies. Roosting tends to follow the tidal rises. At high tide they roost in salt marshes extending along the waterline 3 to 9 times as wide as their depth. There may be as many as 20 birds per square metre. (Cramp, 1983) Food is taken from the surface by probing mud or wading in water and consists of invertebrates such as beetles, molluscs, microscopic crustacea and worms. (Holden & Cleeves, 2002) When as breeding adults dunlin may feed up to 3 kilometres away from their broods (Bright et al, 2006).

3.97 Conservation of estuaries is essential for wintering populations and for –passage migrants. Recreational activity on coast can disturb roosting sites. (Holden & Cleeves, 2002)

3.98 The black–tailed godwit is mainly a passage migrant or winter visitor to

31 Somerset with most numbers (c.300) being present from September to December in 2003. However, in 2006 numbers for the estuary in the same period numbered from 1 to 23. (Somerset Ornithological Society)

3.99 Outside the breeding season black-tailed godwits are found on muddy estuaries where it feeds on invertebrates. Black-tailed godwits are highly gregarious and use communal roost sites outside the chick-rearing season. They prefer shallow water, such as fens and flooded fields. They can make roosting flights of up to 11 kilometres. (Cramp, 1983; Holden & Cleeves, 2002)

3.100 Whimbrel are found on the coast, mainly in estuaries, coastal grassland and saltmarsh habitats. In Bridgwater Bay they were recorded visiting on migration in April and May and were present in small number from June to September. (Somerset Ornithological Society)

3.101 Curlew have been recorded on the east Parrett estuary in all months apart from April and May. 641 Curlew were present in January 2003 falling to 48 in July. In 2006 1276 were present in January falling to 35 in May. (Somerset Ornithological Society)

3.102 Curlews can breed in coastal marshes or even agricultural land in lowland areas. In winter they are found mostly around the coast and especially in estuaries. Curlews form flocks outside the breeding season, and shift to coastal habitats such as mudflats and sands, which are extensive at low tide. Feeding birds spread out but congregate at high tide and usually roost on nearby fields or salt marsh. The principal features of roost sites are shallow water, some vegetative clear ground and clear views. They may travel up to 20 kilometres to roost. Roost site fidelity is strong even outside the breeding season. (Cramp, 1983; Holden & Cleeves, 2002) Curlews prefer open fields that have little activity about them, with low intensity agricultural fields and existing meadows away from frequent human disturbance providing ideal living conditions (Cramp, 1983).

3.103 In 2003 redshank numbering from 100 to 800 were using the east Parrett estuary in Bridgwater Bay, with the highest number recorded in August and being absent only in May and June. In 2006 they were absent during May and June whilst the rest of the year ranged from 1 in April to 790 in February. (Somerset Ornithological Society)

3.104 Outside the breeding season redshanks are mainly found in coastal areas, feeding in saltmarsh habitats, and un-vegetated mud in estuaries. Its food consists of shrimps, small crabs, ragworms and other marine worms. When they remain inland redshanks are found with ample food supplies, such as around sewage works and watersides. (Cramp, 1983; Holden & Cleeves, 2002) On an estuary in Scotland wintering redshank fed for 24 hours, using nearby fields to do so at high tide (Cramp, 1983).

32 3.105 Threats to redshanks include the disappearance of coastal marshes due to sea levels rising. (Holden & Cleeves, 2002)

3.106 The conservation objectives for a site relate to the important wintering populations of birds listed in Annex I of the Bird’s Directive, populations of passage birds and populations of waterfowl, ‘to maintain at, or restore to, favourable conservation status, the natural habitats and/or the populations of birds for which the site has been selected’. The conservation status of a species is defined as favourable when the population, range and natural habitats of the species are stable or increasing.

Special Area of Conservation 3.107 The Severn Estuary is one of the best areas in the UK for mudflats, sand flats and Atlantic salt meadows. The estuary is also an important area for migratory fish and as a nursery for juvenile fish of many species, which are not considered father I this assessment lacking migratory stream connections.

3.108 The area is considered one of the best in the U.K. for Atlantic salt meadows (Glauco-Puccinellietalia maritimae). These occur on the coast at the eastern end of the district. This habitat encompasses saltmarsh vegetation containing perennial flowering plants that are regularly inundated by the sea. The species vary according to the duration and frequency of flooding with seawater, geographical location and grazing intensity. Salt-tolerant species, such as common saltmarsh grass Puccinellietalia maritimae, sea aster Aster tripolium and sea arrowgrass Trigochin maritime, are particularly characteristic of this habitat.

3.109 Nationally scarce flora occurs including bulbous foxtail (Alopecurus bulbosus) in Bridgwater Bay and the . Slender hare's-ear Bupleurum tenuissimum is also frequently found in Bridgwater Bay and Rivers Parrett and Brue. Hordeum marinum, sea barley, is found in a particularly dense population in Bridgwater Bay.

3.110 The conservation objective for the “Atlantic salt meadow” feature of the Severn Estuary SAC is to maintain the feature in favourable condition, as defined below. The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions is met:

i. the total extent of Atlantic salt meadow and associated transitional vegetation communities within the site is maintained; ii. the extent and distribution4 of the individual Atlantic salt meadow and associated transitional vegetation communities within the site is maintained; iii. the zonation of Atlantic salt meadow vegetation communities and their associated transitions to other estuary habitats is maintained; iv. the relative abundance of the typical species of the Atlantic salt

33 meadow and associated transitional vegetation communities is maintained; v. the abundance of the notable species6of the Atlantic salt meadow and associated transitional vegetation communities is maintained. vi. the structural variation of the salt marsh sward (resulting from grazing) is maintained within limits sufficient to satisfy the requirements of conditions iv and v above and the requirements of the Ramsar and SPA features vii. the characteristic stepped morphology of the salt marshes and associated creeks, pills, drainage ditches and pans, and the estuarine processes that enable their development, is maintained. viii Any areas of Spartina anglica salt marsh (SM6) are capable of developing naturally into other saltmarsh communities.

3.111 Estuaries, which lie to the east of the District, are not assessed further as the habitat would not be affected by Local Plan policies.

3.112 The area is considered one of the best in the U.K. for mudflats and sandflats not covered by seawater at low tide. These are mud and sand sediments on the shore that are exposed at low tide but submerged at high tide. Many sites are important feeding areas for waders and wildfowl. These lie adjacent to the coast at the eastern end of the district.

3.113 The conservation objective for “mudflats and sandflats” feature of the Severn Estuary SAC is to maintain the feature in favourable condition, as defined below. The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions is met:

i. The total extent of the mudflats and sandflats feature is maintained; ii. the variety and extent of individual mudflats and sandflats communities within the site is maintained; iii. the distribution of individual mudflats and sandflats communities within the site is maintained; iv. the community composition of the mudflats and sandflats feature within the site is maintained; v. the topography of the intertidal flats and the morphology (dynamic processes of sediment movement and channel migration across the flats) are maintained.

3.114 Reefs are biological concretions formed from various invertebrate species. Reefs occur in the sub-tidal zone, but may extend onto the shore. They form the habitat for a variety of biological communities, such as those characterised by encrusting animals and seaweed.

3.115 Isolated reefs of agglomerated Sabellaria worms are found in Bridgwater Bay, which is highly mobile, nearly liquid mud with some areas of sand waves and an

34 intertidal area of firm sandy mud. Dense aggregations of Sabellaria alveolata worms have been recorded (density exceeding 1000 worms per m²) off Hinkley Point. Intertidal Sabellaria reef is present to the north east of Steart Point outside the Parrett Estuary.

3.116 The conservation objective for the “reefs” feature of the Severn Estuary SAC is to maintain the feature in a favourable condition, as defined below. The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions are met:

i. the total extent and distribution of Sabellaria reef is maintained; ii. the community composition of the Sabellaria reef is maintained; iii. the full range of different age structures of Sabellaria reef are present; iv. the physical and ecological processes necessary to support Sabellaria reef are maintained.

3.117 Sandbanks which are slightly covered by sea water all the time occurs off the coast directly west of Burnham on Sea and would not be affected by the policies in the Local Plan and is therefore not further assessed.

Ramsar 3.118 The Ramsar site is a Wetland of International Importance because the site qualifies under several criteria for determining qualification. Under Criterion 1 it qualifies because it contains a representative, rare, or unique example of a natural or near-natural wetland type found within the appropriate biogeographic region. It has an immense tidal range exceeded only by that occurring in the Bay of Fundy, Canada. This tidal regime affects both the physical environment and the biological communities present in the estuary.

3.119 Under Criterion 3 it supports populations of plant and/or animal species important for maintaining the biological diversity of a particular biogeographic region. It supports unusual estuarine communities, reduced species diversity and high productivity. The high tidal range leads to strong tidal streams and high turbidity, producing communities characteristic of the extreme physical conditions of liquid mud and tide-swept sand and rock.

3.120 The site qualifies under Criterion 4 because it supports plant and/or animal species at a critical stage in their life cycles, or provides refuge during adverse conditions. It is particularly important for migratory birds during passage periods in spring and autumn. The rich food resources available in the tidal flats and nearby freshwater wetlands support these large bird populations. The bird species are synonymous with those listed under the SPA designation above.

3.121 The site qualifies under Criterion 5 because it regularly supports 20,000 or more

35 water birds and in the non-breeding season, the area regularly supports 68,026 individual water birds (5 year peak mean 1988/89 – 1992/93). The site qualifies under Criterion 6 (previously Criterion 3c) because it regularly supports 1% of the individuals in the populations of species or subspecies of water bird in any season. The bird species are synonymous with those listed under the SPA designation above.

3.122 The site qualifies under Criterion 8 because it is an important source of food for fishes, spawning ground, nursery and/or migration path on which fish stocks, either within the wetland or elsewhere, depend. The Sea Lamprey and the Twaite Shad are now considered to be larger than in any other UK estuary. The rare and endangered Allis Shad is now only an occasional visitor although formerly a substantial spawning population was present.

3.123 Atlantic salmon is an anadromous species (i.e. adults migrate from the sea to breed in freshwater). Spawning takes place in shallow excavations called redds, found in shallow gravelly areas in clean rivers and streams where the water flows swiftly. The young that emerge spread out into other parts of the river. After a period of 1-6 years the young salmon migrate downstream to the sea as ‘smolts’. Salmon have a homing instinct that draws them back to spawn in the river of their birth after 1-3 years in the sea. Salmon use the Washford stream to spawn. The Estuary also acts as a nursery for the species.

4.124 Adult common eel are most abundant in estuaries and low salinity pools but are also found around the coast in permanent tide pools, on the lower shore and shallow sublittoral. Being nocturnal it is inactive during the day concealed under rocks or weed or in soft sediments. It has a complex life history that is poorly understood. It involves migration of mature adults from European rivers and estuaries to the Sargasso Sea in the western Atlantic for spawning, and the subsequent return of juveniles. They metamorphose twice, part of the life cycle spent in fresh water and part in estuarine or full seawater. It is present in the River Parrett catchment flowing into Bridgwater Bay.

Table 7: Severn Estuary Key Environmental Conditions

Site Qualifying features Key environmental conditions to support site integrity

36 Site Qualifying features Key environmental conditions to support site integrity

Severn Estuary SPA Migratory species – ringed Bird usage of the site varies seasonally, with plover, curlew, dunlin, pintail, different areas being favoured over others at certain redshank, Shelduck times of year. Bird communities are highly mobile and exhibit patterns of activity related to tidal water movements and many other factors. The most Waterfowl important factors are:

• Current extent and distribution of suitable feeding and roosting habitat. • Sufficient prey availability • Levels of disturbance are maintained within necessary levels. • Water quality and quantity.

Severn Estuary Ramsar Criterion 1 Ramsar Immense tidal range The estuary has an extreme type of hydrodynamic and sedimentary regime and these determine the type of habitat and species present. Management must ensure that these factors are not unduly influenced by anthropomorphic activities. Ramsar criterion 3 Unusual estuarine Dynamic habitats need to be taken account of when communities managing the site.

Ramsar criterion 4 As per criterion 8 below. No obstacles in streams Migratory species used for migration.

Bird usage of the site varies seasonally, with different areas being favoured over others at certain Ramsar criterion 5 times of year. Bird communities are highly mobile Species with peak counts in and exhibit patterns of activity related to tidal water winter: 70919 waterfowl movements and many other factors. The most important factors are:

• Current extent and distribution of suitable feeding Ramsar criterion 6 and roosting habitat. Species with peak counts in

winter: • Sufficient prey availability

. • Shelduck • Levels of disturbance are maintained within • Gadwall necessary levels. • Dunlin

• Redshank • Water quality and quantity

37 Site Qualifying features Key environmental conditions to support site integrity

Ramsar criterion 8 Natural structure and form of rivers maintained to Very high fish species diversity support natural flow regime for Britain with over 110 species. Avoidance of creating artificial barriers to the passage of migratory fish.

Exploitation of fish populations or other native animals or plants at a sustainable level

Water quality

Severn Estuary SAC Mudflats and sandflats not See Ramsar Criterion 1 covered by sea water at low tide Avoidance of disturbance of human activities Atlantic salt meadows Grazing management of saltmarsh

Management of creek density

Reefs Abundance of suitable coarse sediments

The availability of suitable substrates

Ecological Zone of Influence 3.125 Habitats in the estuary are sensitive to changes to water quality in outfalls and watercourses entering Bridgwater Bay as described in Chapter 3.

3.126 Records for each bird species are analysed outside of the SPA and any supporting habitat that supports a bird species is digitised. In flight records are ignored, as are those over 10 years old. Birds can be disturbed by human activity or development (Stillman et al, 2007). Populations of curlew, redshank and dunlin are significantly reduced through sustained disturbance, such as construction work or road traffic on adjacent land to mudflats (Burton et al, 2002a; Burton et al, 2002b). Where people were showing against the skyline shorebirds were disturbed at distances of 400 metres compared with 200 metres when not exposed on the skyline but moving at a steady pace. (Goss-Custard, 2005)

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

Table 8: Disturbance from Human Proximity Species Flight Distance (FD) Shelduck 102-124 metres

38 Species Flight Distance (FD) Wigeon 89 -250 metres Teal No data Dunlin 97– 175 metres Black-tailed Godwit 45-73 metres Whimbrel 84 metres Curlew 90-339 metres Redshank 70 –95 metres (from Bright et al; Goss-Custard, 2005; Mathers et al, 2000)

3.128 The largest FD is 339metres. Therefore, a distance of 400 metres is used for buffering the Natura 2000 site and any additional digitised habitat. This allows for a period of alertness before taking flight and also the possibility that development is on the skyline.

3.129 Records outside of the SPA/Ramsar sites are examined and where it is considered that the habitat potentially supports the ecological requirements of the bird species listed for the designation this is digitised and buffered. A list of the sites is given in Appendix 1.

3.130 Flight paths also need considering as many species listed fly in the lower air space and can be disturbed by land use change along these corridors. These are digitised by forming MCPs around the records per species for the site, linking the habitat outside the site with that on the Natura 2000 site.

3.131 Birds are also dependent on prey species, which are in turn partly dependent on the maintenance of water quality entering the estuary. Therefore, watercourses entering the Ramsar sites supporting these species should also be digitized.

3.132 The riverine records for the fish species listed were examined and the Environment Agency consulted. None of the species for which the SAC site is designated have been recorded for some time in the rivers entering Bridgwater Bay. (SERC have records for River Lamprey dating from 1905 for the ) However, Atlantic salmon and common eel frequent the and would be dependent on conditions in these watercourses to migrate and breed. Fish are also dependent on the maintenance of water quality entering the estuary. Therefore, watercourses entering the SAC site supporting these species should be digitized as part of the EZI.

Vulnerability 3.133 The conservation of the site features is dependent on the tidal regime. The tidal range in the Severn Estuary is the second-highest in the world and the scouring of the seabed and strong tidal streams result in natural erosion of the habitats and the presence of high sediment loads. Natural processes cause the width and depth of the estuary to change over time and the location and extent of salt

39 marshes and mudflats may change provided there is capacity to accommodate readjustment.

3.134 However, where this process is constrained by human intervention, the capacity of habitats to accommodate readjustment may be adversely affected. The estuary’s tidal regime makes it vulnerable to large-scale interference, including human actions such as:

• Land-claim leading to salt marsh loss and reduction in suitable habitats for resident and migrating birds species. • Aggregate extraction/ dredging. Scouring of the seabed and strong tidal streams result in natural erosion. • Physical developments, such as potential construction and resultant change in tidal and sediment regimes • Coastal squeeze due to sea level rise and existing or new flood defences (for protection of new development), leading to saltmarsh loss and changes to coastal erosion and deposition processes. • Pollution (industrial, oil spillage) and resultant declining water quality. • Nutrient enrichment, especially due to agricultural runoff or increased sewage treatment work discharges associated with development. • Tourism based activities or population increase / urban growth and resulting potential for increased disturbance, especially to inter-tidal bird habitats, and feeding and roosting wildfowl. • Development pressure for wind farms and associated land take, construction disturbance and impact on bird migration routes. • Inappropriate grazing regimes e.g. of saltmarsh (under-grazing or over­ grazing). • Low summer water levels affecting coastal swamp /marsh.

3.135 There are several management mechanisms that seek to secure sustainable management of the Severn Estuary and its wildlife interest. A management scheme under Regulation 34 of the Habitats Regulations was established in 2004 in relation to the international bird interest that underpins designation as a Special Protection Area.

40 Map 2: Ecological Zones of Influence (EZI)

41 4. Potential Impacts of the Plan on Ecology

Introduction 4.1 This chapter considers further the potential ecological impacts from the WSDC Local Plan on features of Natura 2000 sites. Any distances mentioned in the text will be used in considering impacts that may affect a Natura 2000 site and areas supporting ecological functioning arising, and are explained in the following sections.

4.2 The following potential affects on features of Natura 2000 sites are considered:

• Recreational Pressure • Habitat Loss • Habitat Fragmentation • Barrier Effects • Habitat Isolation • Proximity Impacts • Air Pollution • Hydrological Changes • Renewable Energy Schemes • Cumulative Impacts

Recreational Pressure 4.3 Increased recreational pressure from urban populations, including dog walking, jogging, horse riding, mountain biking, motorbike scrambling, off road car driving and other, mostly informal, are likely to result from housing and other development proposed in the WSDC Local Plan and of other Core Strategies or Local Plans of district and borough councils within and surrounding the National Park. (Lowen et al, 2009; Penny Anderson Associates, 2009)

4.4 Exmoor National Park is also a popular holiday and leisure destination, and has many environmental assets that attract both visitors as well as residents. This can lead to significant pressure on sensitive habitats resulting in damage and disturbance to the species they support. Typical impacts of tourism and recreation include:

• Physical damage, for example from trampling and erosion. • Disturbance to species, such as ground-nesting birds and wintering wildfowl, from walking, cycling, and water sports, resulting in increased mortality and nesting success, and displacement. • Air pollution (dealt with under air quality below) and disturbance from traffic.

42 • Disturbance from dogs and damage from dog excrement.

4.5 In addition, in particular where sites are close to urban areas, recreational pressures can be exacerbated by other damaging activities described as proximity impacts above, rubbish tipping, vandalism, arson, and predation particularly by cats (see proximity impacts below).

4.6 The impacts of tourism, recreation and urban effects can affect a wide variety of habitat types. Some of the most sensitive are heathland habitats, coastal habitats including dunes, shingle banks and estuaries, other wetlands and watercourses, woodland and grasslands. Trampling can be a serious issue which causes damage to or loss of vegetation. (Lowen et al, 2009; Penny Anderson Associates, 2009)

4.7 The presence of humans can cause visual disturbance to some species, for example to birds (Treweek, 1999; Evink, 2002; Seiler, 2002). The introduction or increase in human activity in an area can affect sensitive species by reducing the amount of time spent on essential activity such as feeding or rearing young, and can lead to displacement, declines in populations or even local extinction. Where there is an open aspect human activity may cause disturbance affecting behaviour of sensitive birds, such as golden plovers, at some distance. For example, breeding golden plovers can be disturbed at distances of 200 metres by the presence of humans (Finney at al, 2005).

4.8 Another example is otters. Anecdotal evidence suggests that otters are not seriously affected by disturbance from anglers, walkers and dogs. Otters do not appear to avoid houses, industry, roads and campsites The response of otters to the sounds of anglers or walkers with dogs is to move to a position where they can see the source of disturbance, dive and swim underwater, then resurface and rest on the bank before resuming their previous activity a short while later. Although individual otters do not appear to be influenced by short periods of disturbance there is a lack of information on how sustained levels of disturbance influences female otters with young. (McCafferty, n/d)

4.9 Traffic noise has been shown to affect the behaviour of species, e.g. bird densities decline where noise is over 50 dbA. Dutch and Swedish research (Reijnen et al, 1995; Helldin & Seiler, 2003) into breeding bird populations has shown an increased shift away from roads according to the amount and speed of traffic.

4.10 Street lighting is known to effect wildlife by altering nocturnal conditions. Street lighting can disturb the diurnal rhythm of species. Many of the species, including otters and bats are sensitive to artificial lighting. Indeed, the introduction of street lighting can have significant effects on their behaviour, cause loss of access to feeding areas and resting areas, and hence affect the viability of populations. (Outen, 2002; Stone, 2009).

43

Habitat Loss 4.11 There is unlikely to be direct loss of habitat within the designated boundaries of a Natura 2000 site. However, outside the designated site loss of habitat is more likely through non recognition of the function it provides in ecologically supporting the conservation objectives of the features of the Natura 2000 site. This can be where land provides habitat which supports qualifying species that are usually mobile, e.g. bats and otters or where a habitat relies on water sources upstream of the site.

4.12 Habitat loss is a major threat to species. In some cases it is directly linked to mortality, and in other cases survival depends on the ability of displaced species to locate alternative habitat. Species require minimum habitat to maintain their populations and it is difficult to assess the impacts of any single scheme. Size of habitat left after loss is also important for species diversity, as there is a threshold for many species that makes smaller patches unviable. The spatial placement of habitat is also important (Treweek, 1999).

4.13 The effects may be local or on a larger geographic scale. Delayed effects of habitat loss are probably common but rarely analysed in ecological impact assessments. Species are not only threatened by habitat loss but also by reorganisation of land use and by reduction in size of habitat patches (Treweek, 1999).

4.14 There are specific issues relating to bats (where these are qualifying features) that need to be considered when assessing the potential effects of the plan. In many instances, Natura 2000 sites will have been designated for bat breeding and roosting sites. However, bats often rely on foraging habitat some distance away from the designated sites, and on habitat features linking foraging locations with breeding and roosting sites. As a result, in order to maintain the integrity of the Natura 2000 sites, and in particular to ensure that there are no adverse effects on bats as qualifying features, the foraging habitat and flight paths also need to be considered, and direct effects such as physical loss from development, or from indirect effects such as disturbance from people, traffic or artificial lighting need to be avoided. Direct loss or change of habitat due to land use change could affect the numbers and types of prey available.

4.15 Habitat loss is most likely to occur as a result of land use change, for example from forestry operations or agricultural practice, but it is also likely from housing development. Habitat loss is likely to affect sites which ecologically support the conservation objectives of a SAC, for example the feeding areas and /or flight lines of barbastelle bats.

44 Habitat Fragmentation 4.16 Fragmentation is the breaking down of habitat units into smaller units of habitat. It is linked to changes in quality and quantity. These could include increase in edge effects, reduction in size of habitat and changes in species composition (Treweek, 1999).

4.17 A key issue in a fragmented landscape is the ability of species populations to survive in and move between small isolated habitat patches scattered within an urban and agricultural landscape. Research has shown that habitat size and wildlife corridors are of vital importance to nature conservation, and to a thriving and diverse wildlife (English Nature, 1996; Dufek, 2001; Evink, 2002). The value of a large area of semi natural habitat outweighs its division into smaller areas where alterations, for example to light, hydrology and levels of disturbance can have a radical effect on species survival. Fragmentation into smaller areas can lead to extinction of predators, larger species and habitat specialists as well effecting pollination in flora – for example Bluebells produce less seed in smaller areas. Road construction and widening would increase fragmentation effects. (Treweek, 1999; Evink, 2002; Seiler, 2002)

4.18 The reduction in habitat area would be less able to support a level of population prior to the land use change and may result in inbreeding to genetic problems and eventual local extinction (Treweek, 1999).

4.19 The WSDC is most likely to cause habitat fragmentation by loss or changes to habitat outside the SAC’s designated boundaries in areas which nonetheless ecologically support its conservation objectives, for example the flight lines of barbastelle bats..

Barrier Effects 4.20 Linear development, such as new roads and even cycle ways, can form barriers, which prevent the movement of wildlife through the landscape. This is a particular problem for migrating species. Many amphibians use different habitat at different seasons of the year. Barriers formed by roads can cause traffic casualties or reluctance in a species to cross it. Small mammals will not cross roads of 20 to 25 metres wide. Traffic density also forms part of the ability of species to cross roads. (Treweek, 1999)

4.21 Wild flowers, invertebrates, amphibians, reptiles and small mammals will be affected by the presence of a road. Those species, which are unable or reluctant to cross roads, will become isolated and hence loose genetic diversity. This isolation could also lead to in the long term the local extinction of some species, which in turn may affect others up the food chain. The creation of barriers or other obstacles affecting the movement of animals may be caused by cumulative development, be it roads and/or housing, within a species range. Road casualties are a significant cause of fauna mortality. In Somerset, otters are increasingly

45 becoming victims of vehicle collision. In 2008 approximately 25% to 30% of the Somerset population were casualties. Numbers of casualties counted are often under estimated (Slater, 2002).

4.22 Within Exmoor barrier effects are most likely to occur from increased visitor traffic using roads to access locations around the Park.

Habitat Isolation 4.23 Habitat Isolation is the combined effect of habitat loss, fragmentation and barrier effects. It affects the genetics of a population if it cannot interact with populations elsewhere which can have a long-term effect on viability.

4.24 In general, consequences are:

• Loss of key species (species on which the ecology of other species depend); Reduction or extinction of species at newly formed edges, increased vulnerability to external influences such as disturbance, increased likelihood of invasion by uncharacteristic species; • Inbreeding; • Loss of characteristic species; and • Increased vulnerability to stochastic events, e.g. climate change. (Treweek, 1999)

4.25 Limitations on genetic exchange and response to climate change may have an effect on the population of the species maintained. This isolation can result in a ‘sink’ where a population is growing but there is not sufficient habitat to support this increase and there is no route out of the area to enable migration (Hanski, 1999).

Proximity Impacts 4.26 These are impacts on species and habitats arising from the closeness of development to a Natura 2000 site, including those resulting from development within the distance that residents in West Somerset are prepared to travel for recreational purposes. They are numerous but can include:

• Disturbance effects from construction activities (including noise and lighting); • Increased traffic impacts from construction activities; • Increase human disturbance from use of the new site; • Increased predation from domestic cats and increases in urban living species, such as foxes, rats and corvids; • Increased fly tipping; • Increased incidence of fires on heathland; • Increased levels of lighting;

46 • Increased random disturbance events.

4.27 Habitat may also be degraded through increased fly tipping including of garden waste, which in turn may introduce alien species (e.g. see Gilbert & Beavan, 1997). Increased numbers of domestic cats (Felis catus) can lead to higher mortality to wildlife within 400 metres of new development (Woods et al, 2003).

4.28 Street lamps can also have an effect on prey availability to bats (Outen, 2002; pers. comm. Emma Stone, University of Bristol). Whereas they do not sustain insect populations per se but attract insects from the surrounding natural environment. Therefore, as a consequence of attracting the insects, street or other artificial lights can deplete prey availability for light sensitive bats in the surrounding area to where they have been installed.

Air Pollution 4.29 Certain interest features of Natura 2000 or Ramsar sites can be directly and/or indirectly affected by pollutants concentrated in the air such as oxides of nitrogen (NOx), oxides of sulphur (SOx) or ammonia, or by pollutants deposited on the ground through acidification or terrestrial eutrophication via soil (deposition of nitrogen).

4.30 Road transport is the source of a number of airborne pollutants. The impacts of nitrogen and nitrogen oxides deposition on vegetation growth are of particular concern. Transport produces other pollutants including sulphur dioxide, ozone and particulates. Air pollution has been linked to ill health amongst trees, particularly over mature specimens, and also a failure to regenerate, either from coppice, pollard or seed. In grassland nitrogen loving species will suppress sensitive flora. Lichens and bryophytes are particularly sensitive.

431 The Habitat Regulations Assessment of the draft Regional Spatial Strategy for the South West (2006) considered 200 metres as the outer distance from a road where nitrogen deposition is expected to occur. Bignall et al, (2004) consider that at an outer distance of 150 metres air quality returns to background levels. The greater distance is used, as a precautionary approach is required.

4.32 Within the National Park increased levels of visitor traffic are likely to be the source of raised levels of deposition on sites which support sensitive flora.

Hydrological Impacts

Water Quality 4.33 Many Natura 2000 sites are dependent upon there being appropriate water quality to support their integrity, including water courses and estuaries and other wetland habitats, as well as less obvious habitat types (such as heathlands)

47 which may be dependent on ground water quality. Water quality can be affected by a number of factors, such as:

• Pollution from toxic chemicals, metals, oils, pesticides, etc., arising for example from accidental spills, industrial processes, run-off from urban areas, and agriculture. • Pesticides and nutrient enrichment, for example from agricultural fertilisers, leading to eutrophication. • Discharges from sewage treatment works, and over-flowing foul water systems at times of high rainfall and flooding.

4.34 Many of the most significant risks to water quality are as a result of agricultural activity. Housing development can potentially increase the risk of water quality being affected due to extra loads being placed on sewage treatment works, increased hard surfacing and hence run-off, and potential accidental spills, for example from port related activity. Diffuse pollution could result in an in combination impact. Changes in hard surface runoff may lead to changes in flow patterns in watercourses (storm water surges), and increased nutrient and sediment levels in watercourses. River, ditch and floodplain habitats such as alluvial forests would be especially vulnerable.

Groundwater Supply 4.35 Both groundwater and surface water levels can be affected by abstraction for public water supply and for industrial and agricultural uses. Climate change is likely to lead to drier summers, which could reduce the availability of water at a time when both population growth and per capita water usage is increasing. Particularly vulnerable are those habitats dependent on groundwater

Flood Risk Management 4.36 This impact may arise due to flood management schemes altering flows in river, rhyne and ditch habitats. Such impacts may not necessarily be negative, especially if the flood plain is used to manage flood risk.

Renewable Energy Schemes 4.37 Bat species that are features of Natura 2000 sites may be vulnerable to mortality from the development of wind turbines (Hötker et al, 2006; Mitchell-Jones & Carlin, 2009). There may also be other impacts as described above, such as disturbance effects, habitat loss and fragmentation.

Cumulative Impacts 4.38 Cumulative impacts are those where an impact in itself may not be significant, but in combination with other impacts from the plan, or from other plans and

48 projects, may amount to a significant impact.

Summary of Potential Effects from the Core Strategy and Development Management Policies on SAC Features 4.39 The following table provides a general guidance on the potential significant effects that could arise from the WSDC Local Plan, either alone or in combination with either other plans or projects, on the features of the Exmoor SACs and the Severn Estuary SPA / SAC / Ramsar. Note disturbance, fragmentation, isolation and other effects on features could occur outside the designated site boundaries.

Table 6: Potential Impacts on Natura 2000 and Ramsar Features from Local Plan Policies

Qualifying features Recreational Habitat Loss Habitat Barrier Habitat Proximity Air Renewable Pressure or Fragmentation Effects Isolation Impacts Pollution Energy Degradation

Northern Atlantic wet heaths with Erica X X X tetralix

European dry heaths X X X Vegetated sea cliffs of the Atlantic and Baltic X X coasts

Blanket bogs X X X

Alkaline fens X X

Old sessile oak woods with Ilex (holly) and Blechnum (fern) in the X X X X British Isles

Alluvial forests with Alnus glutinosa (alder) and Fraxinus excelsior X X X (ash)

Barbastelle bat Barbastella X X X X X X barbastellus

Bechstein’s bat Myotis bechsteinii X X X X X X

Otter Lutra lutra X X X X X

Wintering and migratory birds; waterfowl assemblage X X

Atlantic salmon X X X X X

49 Qualifying features Recreational Habitat Loss Habitat Barrier Habitat Proximity Air Renewable Pressure or Fragmentation Effects Isolation Impacts Pollution Energy Degradation

Common eel X X X X X

50 5. Analysis of Policy in the Local Plan Draft Preferred Strategy

Introduction 5.1 The Local Plan will set out WSDC’s spatial strategy spatial and over-arching objectives for sustainable development in its administrative bondaries, including those for housing development and it location. It will guide decisions on planning applications and appeals and support any developing Neighbourhood Plans.

5.2 Every policy option will be assessed against each of the qualifying features of the Natura 2000 site’s, identified in this report, in terms of ‘significant effects’ on those features. Many policies are likely to have a neutral effect on each site feature and are therefore are likely to be eliminated at this stage of the HRA process as they would not have any significant effect on a Natura 2000 site.

5.3 “Significant” is interpreted as an effect likely to adversely affect a Natura 2000 site’s integrity. “Integrity” is described in ODPM Circular 06/2005: Biodiversity and Geological Conservation as 'the site’s coherence, ecological structure and function across its whole area that enables it to sustain the habitat, complex of habitats and/or the levels of populations of species for which it was classified' (ODPM Circular 06/2005, para. 20).

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

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

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

Analysis of Effects on Natura 2000 Sites 5.6 This chapter will look at the likely direct, indirect or secondary impacts of policy options, identified as potentially having a significant effect in the previous chapter on the integrity of designated sites, alone or in-combination with other relevant plans.

5.7 The determination of ‘favourable condition’3 of a site is separate from the

3 ‘Favourable condition’ means that the Natura 2000 site’s features are being adequately conserved and is meeting the site is meeting its 'conservation objectives', however, there is scope for the enhancement of these sites

51 judgement of effect upon integrity. For example, there may be a time-lag between a plan being implemented and a consequent adverse effect upon integrity becoming manifest in the condition assessment. In such cases, a plan may have an adverse effect upon integrity even though the site remains in favourable condition.

5.8 In addition, and in order to secure the long term presence and stability of Natura 2000 sites and the network, climate change should be a key consideration in the application of Habitat Regulations Assessment (HRA). Consideration should be given as to whether the plan inhibits in any way the potential of species to adapt to climate change.

Management for Nature Conservation Purposes 5.9 The Local Plan does not introduce any management measures for nature conservation purposes at this stage.

Plan Analysis 5.10 Table 7 analyses the policies given in the Local Plan Preferred Option Strategy and for each gives an assessment of its potential impact on Natura 2000 sites. Those policies that have a potential significant effect are highlighted in Orange. Impacts on each qualifying feature for each site affected are then assessed in detail in Chapter 7.

Table 7: Plan Analysis Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected SD1 PRESUMPTION IN FAVOUR OF None likely None The policy is a statement of intent SUSTAINABLE DEVELOPMENT to apply the principles of sustainable development. It states Proposals which help to deliver sustainable that the planning system will be development through used to protect the natural the application of the policies and proposals of environment. the will be supported.

52 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EN1 MITIGATION OF IMPACT OF HINKLEY POINT Barbastelle Bats Exmoor and Lacking evidence to the contrary it NEW NUCLEAR PROPOSALS Loss of feeding Quantocks is assumed that the barbastelle habitat and Oak bats are from roosts sites in the Proposals for the mitigation of impacts arising severance of flight Woodlands Quantocks component of the SAC. from the development of a new nuclear power lines preventing SAC station at Hinkley point must demonstrate that: access to feeding The types of mitigation are not areas specified although some would • they respect the positive economic and result from offsetting impacts on social characteristics of communities barbastelle bats others may have affected especially those neighbouring an adverse effect. them, that; Although provision in the policy is • adequate measures are taken to given for ‘adequate mitigation mitigate the adverse cultural, measures’ but this is environment economic, environmental and social with regard to the community not impact of the related development, the natural environment for its own (both temporary and permanent and, sake. Provision is also given for preparatory and ancillary) on the ‘respect’ to the ‘local natural communities affected, both in the short environment’. Respect is not and the longer term, and that; defined and as it stands does not imply that significant effects are • they respect the local natural eliminated. Local is not defined. environment in which they are located. In addition the policy does not specifically mention potential effects on barbastelle bats outside of the designated SAC boundary, which are known to be affected by development at Hinkley. Barbastelle bats have individual territories up to 9 kilometres and more from their roosts site (Billington, 2000; Zeales, 2009).

EN2 MITIGATION OF IMPACT OF MAJOR ENERGY Barbastelle Bats Exmoor and Although provision in the policy is GENERATING PROPOSALS Mortality from wind Quantocks given for ‘adequate mitigation turbine Oak measures’ but this is environment Major energy generating development proposals development Woodlands with regard to the community not will be supported where it can be clearly SAC the natural environment for its own demonstrated that: sake. Provision is also given for ‘respect’ to the ‘local natural • they make an essential contribution to environment’. Respect is not the nation’s energy needs; defined and as it stands does not imply that significant effects are • they respect the local natural eliminated. environment in which they are located; The policy is not locational. • they respect the positive economic and social characteristics of communities Barbastelle bats are considered by affected especially those neighbouring Natural England to be of medium them; and, risk to collision with turbines and at medium risk to the continuing • adequate measures are taken to viability of a population from mitigate the cultural, economic, resulting mortality. (Mitchell-Jones environmental and social impact of any & Carlin., 2009) related development on the communities affected, both in the short Wintering, Severn There is a risk of collision of bird and the longer term migratory birds, Estuary SPA / species with wind turbines located

waterfowl Ramsar at the eastern end of the WSDC Mortality from wind area turbine development

53 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected SC1 HIERARCHY OF SETTLEMENTS None likely None The policy concerns the hierarchy of settlements only and is non 1. New development will be concentrated locational. in the district’s main Centre, Minehead, and in the rural service centres of Watchet and Williton. This will be on a scale generally proportionate to their respective roles and functions to their own communities and Those in surrounding settlements that rely on their larger Neighbours for essential services and facilities.

2. Limited development in the remaining settlements, which do not have development limits, may be permitted where it can be demonstrated that it will contribute to wider sustainability benefits for the area where it meets a clearly identified local need.

3. Development in the open countryside will be limited to that for which there is an established long-term need and the location is essential, including agriculture, forestry, horticulture and, hunting. Development in such locations will also need to demonstrate good proximity and easy accessibility to the existing Highway network, or alternative transport modes, and settlements providing essential services and facilities.

4. Development within or in close proximity to the built-up limits of settlements without a development limit boundary (as shown on the proposals map) will only be considered where it can be demonstrated that:

A. It is well related to existing essential services and social facilities within the settlement, and; B. There is safe and easy pedestrian access to the essential services and social facilities within the settlement, and; C. It enhances the service and social facility provision of the settlement / settlement-cluster, and; D. It provides employment opportunities for local residents, and; E. Is of a scale which complements the character of the existing settlement, and; F. It does not generate significant additional traffic movements over minor roads to and from the national primary and county highway route network.

54 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected SC2 STRATEGIC DEVELOPMENT None likely None The policy allocates the amount of dwellings per annum only and is New housing within the core strategy area will be not locationally specific delivered at a minimum average rate of 125 dwellings per year:

• of these, an average of 65 dwellings per year will be provided at Minehead; • an average of 30 dwellings per year will be provided at Williton and Watchet, and • a maximum of 30 dwellings per year will be provided at settlements elsewhere within the district

SC3 APPROPRIATE MIX OF HOUSING TYPES None likely None The policy is for housing types only AND TENURES

Residential and mixed development proposals should provide a mix of housing sizes, tenures and types to meet the demonstrated needs of The area’s communities.

55 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected SC4 AFFORDABLE HOUSING None likely None Policy is for proportion of affordable housing only 1. Where residential development is proposed, provision should be made for affordable housing to meet the needs of those who Cannot afford to access the open housing market at these specified thresholds on sites in the following locations:

A. In Minehead on sites of 8 or more dwellings B. In Watchet on sites of 5 or more dwellings C. In Williton on sites of 5 or more dwellings D. Elsewhere on sites of 1 or more dwellings Or - alternatively: D. Elsewhere on sites of 3 or more dwellings

2. Local needs housing will be provided from developments in the minimum ratio of 35 affordable units for every 65 open-market (pro-rata) based on the total number of dwellings to be provided in the development.

3. The local needs housing element will be provided on the following basis: A. Proportionate like-for-like basis in terms of house type with a minimum of 2-bedrooms, unless the latest local housing needs survey indicates otherwise B. Built to the minimum homes and communities agency standard sizes for type of dwelling or larger C. Built to a minimum of homes and communities agency design Code 4 unless this has been superseded by higher code Levels determined by the hca, successor agencies and/or the relevant central government department D. Built at nil-cost to the registered social landlord / registered provider.

4. Local needs affordable housing will be considered on sites in and around settlements without development limits where it can Be demonstrated that; A. There is, and will be, a clear ongoing need for this type of housing in the settlement, and; B. There is a clear employment, social and/or, long-term historic family linkage between the potential occupants and the settlement, and; C. No suitable alternative sites are available (in more sustainable locations, and; D. There is good access to basic essential services and facilities within the settlement/ settlement-cluster or via access to good public transport connections nearby to neighbouring larger settlements.

Proposals for development may include an element of open market housing where this is necessary in order to enable the development of affordable housing to take place. In such Proposals, the minimum proportion of affordable housing to market housing should be 1:3.

56 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected SC5 SELF CONTAINMENT OF SETTLEMENTS None likely None The policy is for self containment of settlements only and is not Development which improves the balance of land locationally specific uses within a settlement in terms of minimising overall transport use will be encouraged. Development resulting in the loss of community facilities such as public houses and shops where these are the last such facilities in the settlement, will be resisted unless it can be demonstrated that the business is not and cannot be made viable, and that all Reasonable efforts have been made to sell the business.

SC6 MIXED-USE DEVELOPMENT None likely None The policy is for provision of mixed use within development only Large developments and re-developments should provide a mix of uses and activities that will offer the opportunity of greater self containment within itself and in conjunction with existing neighbouring community / settlement. The type of activities and / or uses should seek to complement any existing provision elsewhere in the settlement and not have a detrimental impact on the vitality and viability of existing identified

MD1 MINEHEAD DEVELOPMENT None likely None The policy gives aims for development in Minehead to meet Within the development limits at Minehead, criteria only development proposals should aim to achieve one or more of the following:

• support and strengthen the settlement’s role as the main service and employment centre in West Somerset, particularly in terms of the diversity and quality of its historic and natural environment, services and facilities,

• maintain and enhance its attractiveness as a tourist destination,

• where appropriate, contribute towards resolving the flood risk issues which affect the settlement including improving the sea defences protecting the eastern end of the town,

• give appropriate treatment to the town’s surroundings in the context of national designations.

57 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected MD2 STRATEGIC DEVELOPMENT AROUND Barbastelle Bats Exmoor and Potential loss of feeding habitat MINEHEAD Loss of feeding Quantocks and habitat forming structural flight habitat and Oak lines due to housing development Provision will be made in the environs of severance of flight Woodlands south of the A39, which lies within Minehead for a mixed development including a lines preventing SAC the Ecological Zone of Influence of total of about 1000 dwellings within the area to access to feeding the SAC the south of the A39, Minehead, and to the north areas including east of Seaward way, and in the longer term, from the effects of post 2022 to the west of Marsh, as street lighting indicated on the key diagram. Disturbance due to Barbastelle bats are sensitive to increased human disturbance at roosts (Zeale, 2009). activity around roosts as part of recreational activity generated by new residential housing

Otters Exmoor and Otters at natal holts could be Disturbance at Quantocks sensitive to increased or sustained natal holt sites due Oak recreational activity (McCafferty, to increased Woodlands n/d) human activity SAC around roosts as part of recreational activity generated by new residential housing

Heathland Exmoor Potential for increased recreational habitats Heaths SAC pressure on sensitive habitats. The Degradation and /or current population of Minehead is loss of habitat due about 12500 and the housing stock to increased access is around 9700 dwellings4. The policy is for 1000 new homes which Woodland is likely to increase the population habitats Exmoor and by around 10%. Degradation and /or Quantocks loss of habitat due Oak to increased access Woodlands SAC

Heathland Exmoor Potential for a deterioration in air habitats Heaths SAC quality resulting from increased Degradation and /or traffic levels from development loss of habitat due to decreased air quality

Woodland Exmoor and habitats Quantocks Degradation and /or Oak loss of habitat due Woodlands to decreased air SAC quality

4

58 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected WA1 WATCHET DEVELOPMENT None likely None The policy gives aims for development in Watchet to meet Within the development limits at Watchet, criteria only development proposals should aim to achieve one or more of the following:

• support and strengthen the settlement’s role as a local service and employment centre for the north eastern part of West Somerset district, particularly in terms of the range and quality of its services and facilities,

• maintain and enhance its attractiveness as a tourist destination and the operation of its marina,

• where appropriate, contribute towards resolving the flood risk Issues which affect the settlement,

• seek, where appropriate, to improve linkages between the town centre and the parts of the town south of the railway,

• provide additional allotments for the town

• complement the provision of employment opportunities, services and facilities in neighbouring Williton.

WA2 STRATEGIC DEVELOPMENT AT WATCHET Heathland Exmoor Potential for increased recreational habitats Heaths SAC pressure on sensitive habitats in Provision will be made at Watchet for a mixed Degradation and /or combination with development development including about 250 dwellings loss of habitat due elsewhere in West Somerset and within the area to the south and or east of the to increased access other local planning authority Town as indicated on the key diagram. districts. The current population of Woodland Watchet is around 4500 with a habitats Exmoor and housing stock of about 27255 Degradation and /or Quantocks dwellings. The policy is for 250 loss of habitat due Oak dwellings and increase of around to increased access Woodlands 9% SAC

Heathland Exmoor Potential for a deterioration in air habitats Heaths SAC quality resulting from increased Degradation and /or traffic levels from development in loss of habitat due combination with development to decreased air elsewhere in West Somerset and quality other local planning authority districts Woodland Exmoor and habitats Quantocks Degradation and /or Oak loss of habitat due Woodlands to decreased air SAC quality

5

59 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected Migratory Fish Severn Atlantic salmon and common eel Degradation to Estuary use the Washford River and could habitat and / or Ramsar be considered part of the Ramsar barrier effects populations of these species.

However, proposed strategic sites are outside the Washford River valley and otherwise development would be subject to Environment Agency regulatory processes.

WI1 WILLITON DEVELOPMENT None likely None The policy gives aims for development in Williton to meet Within the development limits at Williton, criteria only development proposals should aim to achieve one or more of the following:

• support and strengthen the settlement’s role as a local service, administrative and employment centre for the north Eastern part of West Somerset district, particularly in terms of the range and quality of its services and facilities,

• where appropriate, contribute towards resolving the flood risk Issues which affect the settlement,

• contribute to the improvement of traffic and transport management within the village,

• complement the provision of employment opportunities, services and facilities in neighbouring Watchet

WI2 STRATEGIC DEVELOPMENT AT WILLITON Barbastelle Bats Exmoor and Potential loss of feeding habitat Loss of feeding Quantocks and habitat forming structural flight Provision will be made at Williton for a mixed habitat and Oak lines due to housing development development including a total of about 300 severance of flight Woodlands east of the A358, which lies within dwellings within the areas to the west, east and lines preventing SAC the Ecological Zone of Influence of north of the town as indicated on the key access to feeding the SAC diagram areas including from the effects of street lighting

Disturbance due to Barbastelle bats are sensitive to increased human disturbance at roosts (Zeale, 2009). activity around roosts as part of recreational activity generated by new residential housing

60 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected Heathland Exmoor Potential for increased recreational habitats Heaths SAC pressure on sensitive habitats in Degradation and /or combination with development loss of habitat due elsewhere in West Somerset and to increased access other local planning authority districts. Williton has a population Woodland of about 3500 people and 1300 habitats Exmoor and dwellings6. The policy is for 300 Degradation and /or Quantocks new dwellings an increase of 23%. loss of habitat due Oak to increased access Woodlands SAC

Heathland Exmoor Potential for a deterioration in air habitats Heaths SAC quality resulting from increased Degradation and /or traffic levels from development in loss of habitat due combination with development to decreased air elsewhere in West Somerset and quality other local planning authority districts Woodland Exmoor and habitats Quantocks Degradation and /or Oak loss of habitat due Woodlands to decreased air SAC quality

SV1 DEVELOPMENT AT OTHER SETTLEMENTS None likely None The policy gives aims for development in other settlements Development at other settlements should: to meet criteria only

• maintain or enhance their existing level of service provision and

• help to create balanced communities (including settlement clusters of villages and hamlets) at a level appropriate to their role and function

6

61 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected OC1 OPEN COUNTRYSIDE DEVELOPMENT Barbastelle Bats Exmoor and It is considered will be of small Loss of feeding Quantocks scale only and by itself is unlikely to Residential development in the open countryside habitat and Oak cause a significant effect. will only be permitted where it can be severance of flight Woodlands demonstrated that: lines preventing SAC It is assumed that development access to feeding would take place outside the • it is essential for agricultural , forestry, areas designated boundaries of Natura horticulture equestrian or hunting purposes, 2000 sites. or; Individual conversion of buildings • it is provided through the conversion of may affect bat roots. However, existing, traditionally constructed buildings barbastelle and Bechstein;s bat in association with employment or tourism roosts are located in old mature purposes as part of a work / live trees and are therefore not affected development, or; although other non SAC species may be. • it meets an ongoing identified local need for affordable housing in the nearby However, the policy is not restricted settlement which cannot be met within or to using existing buildings is non closer to the settlement, or; locational and may result in development affecting the • it is a low impact dwelling provided on- landscape use of barbastelle bats site as part of a sustainable land management or smallholding business

EC1 WIDENING AND STRENGTHENING THE None likely None The policy gives criteria for LOCAL ECONOMY strengthening the local economy only Proposals which will make the West Somerset economy stronger and more diverse and that are likely to increase the proportion of higher paid jobs locally will be supported.

New development, redevelopment and, conversion proposals for all types of employment generating activities will be encouraged and directed to existing and extant premises and sites for similar and compatible uses and would not have an adverse impact on the amenity of existing neighbouring land uses

EC2 MAJOR EMPLOYMENT SITES None likely None The locations will avoid potential impacts on bat features of the The major employment sites at Mart Road, Exmoor and Quantocks Oak Minehead and Roughmoor, Williton are identified Woodlands SAC. on the proposals map. Within these sites there will be a general presumption in favour of uses in The second part of the policy is the B1, B2 and B8 use classes. criteria only.

Employment and service based land uses falling outside these use classes will be permitted where these can be demonstrated to make a positive contribution to the overall vitality and viability of the local economy.

62 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EC3 GREENFIED EMPLOYMENT GENERATING Barbastelle Bats Exmoor and The policy is non locational and DEVELOPMENT Loss of feeding Quantocks therefore greenfield employment habitat and Oak development may occur within the Development proposals requiring a greenfield severance of flight Woodlands EZI of the SAC if its criteria are location will be directed to existing identified lines preventing SAC met. Potential for impacts to and/or allocated sites for those type of uses access to feeding ecologically supporting habitats unless it can be demonstrated that: areas outside the designated sites

• the proposed location is essential to the Otters business and that it could not be located Disturbance to holt elsewhere, and, sites including • it does not adversely affect the vitality and those used for viability of existing centres, and; breeding • It complements existing service and facility provision in the settlement and surrounding area without generating new unsustainable transport patterns.

EC4 HOME-BASED BUSINESS ACTIVITIES None likely None The policy is for criteria affecting home working only Development proposals for employment generating activities within residential properties, will be permitted where the essentially residential character of the building and area is maintained by:

• limiting the type and level of activity, including the hours of work and deliveries, to that consistent with the residential amenity of the area, • preventing any harmful future intensification, and; • limiting any advertisement to a small, discrete notice.

Where subsequent intensification of the employment activity results in an unacceptable level of adverse impact on the residential amenity of the area, the business will be expected to reduce the impact of its increased activities or re-locate to a more appropriate location.

63 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EC5 SAFEGUARDING EXISTING EMPLOYMENT None likely None The policy is for criteria affecting USES existing business only

Sites and premises with existing commercial activities will be safeguarded against change of use to residential or other non employment generating uses unless it can be demonstrated that:

• the business is no longer viable in that location, • the business/site has been marketed (at a competitive price for comparable uses) for a minimum of twelve months and has generated no interest, • the activity is no longer appropriate or sustainable in that location, and; • the new use will result in a reduction in undesirable transport movements to the location over minor roads linking it to the National Primary and County Highway Principal Route network.

Consideration will also be taken account of businesses relocating from the site / premises to more sustainable locations nearby.

EC6 WORK/LIVE DEVELOPMENTS None likely None The policy is for criteria affecting existing work / live business Proposals for work/live developments through premises only new build or conversion of existing buildings will be supported where:

• the employment element within each unit forms and remains a majority of the gross floorspace of each unit, • the employment and residential elements are integrated with one another and cannot be separated or sold off as separate units and activities at a subsequent point in time, • there would be no adverse impact upon the vitality and viability of existing employment provision within the settlement or in neighbouring settlements, and; • there is no generation of significant additional traffic movements to and from the premises as a result of the new business activity.

EC7 TRAINING AND EDUCATIONAL PROVISION None likely None The policy is for supporting training opportunity only Proposals which strengthen the range and quality of training opportunities offered within the area will be supported.

Development proposals that combine education, training and employment functions and opportunities in one location will be supported provided that they do not adversely affect the vitality and viability of existing centres

64 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EC8 TOURISM IN SETTLEMENTS None likely None The policy is for supporting tourist attractions within settlements only Tourism proposals which increase the range of open air and wet weather attractions / activities within existing settlements will be encouraged.

EC9 TOURISM OUTSIDE OF SETTLEMENTS Barbastelle Bats Exmoor and The policy is non locational and Loss of feeding Quantocks therefore greenfield employment Tourism developments outside settlements will habitat and Oak development may occur within the only be supported where it can be demonstrated severance of flight Woodlands EZI of the SAC if its criteria are that: lines preventing SAC met. Potential for impacts to access to feeding ecologically supporting habitats • the proposed location is essential to the areas outside the designated sites business and that it could not be located elsewhere, and; • it does not adversely affect the vitality and viability of existing provision in neighbouring settlements, and; • it complements existing tourism service and facility provision in neighbouring settlements and surrounding area without generating new unsustainable transport Wintering and Severn Potential for increased recreational patterns. Migratory Birds, Estuary SPA activity in coastal areas affecting Wildfowl bird features of the SPA particularly Disturbance to in the north east of the District birds in coastal areas from increased access

Heathland Exmoor Potential for increased recreational habitats Heaths SAC pressure on sensitive habitats in Degradation and /or combination with development in loss of habitat due West Somerset and other local to increased access planning authority districts The justification for the policy Woodland specifically states that Minehead habitats Exmoor and will be emphasised as a visitor Degradation and /or Quantocks centre foe Exmoor with an loss of habitat due Oak increased profile for outdoor to increased access Woodlands pursuits. SAC

Heathland Exmoor Potential for a deterioration in air habitats Heaths SAC quality resulting from increased Degradation and /or traffic levels from tourist access in loss of habitat due combination with development in to decreased air West Somerset and other local quality planning authority districts

Woodland Exmoor and habitats Quantocks Degradation and /or Oak loss of habitat due Woodlands to decreased air SAC quality

65 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected EC10 GATEWAY SETTLEMENTS Barbastelle Bats Exmoor and The policy encourages increased Disturbance at Quantocks numbers of visitors to Exmoor and Tourism development proposals which enhance roost sites Oak to the Quantock Hills which may Minehead’s role as a Gateway centre for visiting Woodlands increase incidents of disturbance to Exmoor and Williton’s role as a gateway for the Otters SAC sensitive species Quantock Hills and the will be Disturbance to holt supported. sites including those used for breeding Heathland Exmoor Potential for increased recreational habitats Heaths SAC pressure on sensitive habitats in Degradation and /or combination with development in loss of habitat due West Somerset and other local to increased access planning authority districts

Woodland habitats Exmoor and Degradation and /or Quantocks loss of habitat due Oak to increased access Woodlands SAC

Heathland Exmoor Potential for a deterioration in air habitats Heaths SAC quality resulting from increased Degradation and /or traffic levels from tourist access in loss of habitat due combination with development in to decreased air West Somerset and other local quality planning authority districts

Woodland Exmoor and habitats Quantocks Degradation and /or Oak loss of habitat due Woodlands to decreased air SAC quality

EC11 AGRICULTURE Barbastelle Bats Exmoor and The policy is not locational. Low or Mortality from wind Quantocks zero carbon economy could include Development proposals for farm diversification turbine Oak the development of wind turbines which help to support the local agricultural development Woodlands on agricultural land. Barbastelle economy by facilitating: SAC bats are considered by Natural England to be of medium risk to • the development of a low or zero collision with turbines and at carbon economy; medium risk to the continuing • the implementation of sustainable viability of a population from tourism, or; resulting mortality. (Mitchell-Jones • the development of local food markets, & Carlin, 2009)

will be supported. It is assumed that ‘sustainable tourism’ will be of low scale

Wintering, Severn There is a risk of collision of bird migratory birds, Estuary SPA / species with wind turbines located waterfowl Ramsar at the eastern end of the WSDC Mortality from wind area turbine development

66 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected TR1 ACCESS TO AND FROM WEST SOMERSET Barbastelle Bats Exmoor and The policy is non locational and Loss of feeding Quantocks therefore road improvements may Proposals for larger development must address habitat and Oak occur within the EZI of the SAC. the requirement to enhance the use of severance of flight Woodlands Potential for impacts to ecologically sustainable modes of transport within and lines preventing SAC supporting habitats outside the between West Somerset’s communities and access to feeding designated sites travel to and from communities outside the core areas strategy area.

Provision may include: Woodland • the improvement of public transport habitats The A39 runs adjacent to oak services, Loss or degradation woodlands in the Quantocks • making walking and cycling more of habitat due to component of the SAC attractive and safer as means of road improvements transport • road improvements • improvements to the heritage railway services of the

TR2 REDUCING RELIANCE ON THE PRIVATE None likely None The policy is for reducing the CAR reliance on private car use only

Development should be located and designed to maximise the attractiveness of modes of transport other than the private car Where appropriate, particularly where:

• it complements existing service and facility provision in the settlement and surrounding area without generating new unsustainable transport patterns (as a consequence), and; • does not generate significant additional traffic movements over minor roads to the national primary and county highway route network.

CF1 MAXIMISING ACCESS TO RECREATIONAL Barbastelle Bats Exmoor and The policy is non locational and FACILITIES Loss of feeding Quantocks therefore new recreational facilities habitat and Oak may occur within the EZI of the The provision of new, and retention and severance of flight Woodlands SAC. Potential for impacts to improvement of existing, sport, recreation and lines preventing SAC ecologically supporting habitats cultural facilities will be supported, where this access to feeding outside the designated sites helps to strengthen and or enhance a balanced areas range of provision for local communities and visiting tourists.

67 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected CF2 PLANNING FOR HEALTHY COMMUNITIES None likely None The policy is a statement about spatial planning for healthy In order to help address the causes of ill health communities and it is assumed and maximise the benefit which spatial planning would apply as a consideration can provide in shaping healthy communities, within development sites development proposals should be designed in order to maximise the attractiveness of walking and cycling as means of making journeys to local services and facilities, and also to encourage recreational walking and cycling. Provision for disability access is also to be encouraged. A health impact assessment will be required for all major development proposals.

CC1 CARBON REDUCTION Barbastelle Bats Exmoor and The minimisation of CO² emissions Mortality from wind Quantocks from development is important to Development proposals which assist in the turbine Oak help avoid changes to species development of a low or zero carbon economy development Woodlands composition brought about by will be supported. SAC climatic change.

Such proposals may include the development of However, the policy is not wood fuel or other renewable energy sources, locational. Renewable energy and provision of low energy systems to serve could include the development of new and existing development. wind turbines. Barbastelle bats are considered by Natural England to be of medium risk to collision with turbines and at medium risk to the continuing viability of a population from resulting mortality. (Mitchell- Jones & Carlin, 2009)

It is assumed that ‘sustainable tourism’ will be of low scale

Wintering, Severn There is a risk of collision of bird migratory birds, Estuary SPA / species with wind turbines located waterfowl Ramsar at the eastern end of the WSDC Mortality from wind area turbine development

CC2 FLOOD RISK MANAGEMENT None likely None The policy is concerned with flood risk management only. Sites are Development proposals should be located and downstream of sensitive designed so as to mitigate against, and to avoid hydrological features within the increased flood risk to new and existing Exmoor and Quantocks SACs and development, whilst helping to provide for the therefore unlikely to effect them. development needs of the community.

Development must be designed to mitigate any adverse flooding impact which would arise from its implementation, and where possible should contribute towards the resolution of existing flooding issues.

68 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected CC3 COASTAL CHANGE MANAGEMENT AREA Wintering and Severn Potential for increased recreational Migratory Birds, Estuary SPA activity in coastal areas affecting Development within the coastal change Wildfowl bird features of the SPA particularly management areas, as defined on the proposals Disturbance to in the north east of the District map, will be limited to temporary, tourism related birds in coastal development. areas from increased access No development will be permitted within parts of the coastal change management area which are vulnerable to rapid coastal erosion.

Exceptionally, where the use of such development locations are necessary for sustainable development purposes, other types of development may be permitted where they would be protected by new or existing sea defences which are to be maintained in the long term.

CC4 COASTAL ZONE PROTECTION Wintering and Severn Measures to minimise and mitigate Migratory Birds, Estuary SPA are not sufficient as no significant Development within the coastal zone and outside Wildfowl effect is required of identified settlements will only be permitted for Disturbance to uses and activities for which birds in coastal areas from A coastal location is essential and they cannot increased access be located elsewhere. Account will be taken of:

• impact on the coastal environment, • scale of the development, • cumulative impact on surrounding land and property, and, • measures taken to minimise and mitigate these matters.

CC5 WATER EFFICIENCY None likely None The policy is concerned with the design of water efficiency within The design of development schemes which development only include measures to economise on the use of water supplies will be encouraged.

CC6 WATER MANAGEMENT None likely None The policy is for water management and may be Development that would have an adverse impact considered to afford protection to on: the hydrological requirements of the SACs. • the availability and use of existing water resources; • the existing water table level • accessibility to existing watercourses for maintenance and, • areas at cumulative risk of flooding by tidal, fluvial and/or surface water run-off will only be permitted if adequate and environmentally acceptable

Measures are incorporated that provide suitable protection and mitigation both on-site and through displacement to adjoining land.

69 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected NH1 HISTORIC ENVIRONMENT None likely None The policy is concerned with the historic environment only Proposals for development should safeguard and / or enhance the built and archaeological heritage of the district whilst contributing appropriately to the regeneration of the district’s communities.

NH2 LANDSCAPE CHARACTER PROTECTION None likely None The policy is concerned with the ascetics of landscape character Within identified landscape character areas, only development should be located and designed in such a way as to minimise adverse impact on the quality and integrity of that landscape.

NH3 NATURE CONSERVATION AND THE None likely None The policy is concerned with PROTECTION AND ENHANCEMENT OF biodiversity. However, the use of BIODIVERSITY the term biodiversity in mitigating all impacts of the plan on Natura Proposals for development should include 2000 sites is considered provision for the protection and, where possible, inadequate. Biodiversity refers to for the enhancement of biodiversity. all life forms including garden plants and agricultural crops.

NH4 GREEN INFRASTRUCTURE Barbastelle Bats Exmoor and The policy is non locational and Loss of feeding Quantocks therefore multi functional green The creation and enhancement of a green habitat and Oak infrastructure development, which infrastructure network will be supported severance of flight Woodlands may include walking routes and lines preventing SAC cycle ways requiring street lighting access to feeding may occur within the EZI of the areas SAC. Potential for impacts to ecologically supporting habitats Otters outside the designated sites Disturbance to holt sites including those used for breeding

70 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected NH5 PROTECTION OF BEST AND MOST Barbastelle Bats Exmoor and The policy is non locational and VERSATILE AGRICULTURAL LAND Loss of feeding Quantocks limits impacts on wildlife to habitat and Oak designated sites where as impacts Subject to a minimum threshold of 10, hectares severance of flight Woodlands on the SAC may occur within the the best and most versatile agricultural land lines preventing SAC EZI. Potential for impacts to (grades 1, 2 and 3a) will be protected from access to feeding ecologically supporting habitats significant development proposals. areas outside the designated sites

Planning permission for development affecting such land will only be granted exceptionally if the presumption in favour of sustainable development outweighs the need to protect it and either:

• sufficient land of a lower grade (grades 3b, 4 and 5) is unavailable in an appropriate location to provide sustainable development; or • available lower grade land has an environmental value recognised by a statutory or non-statutory wildlife, historic or archaeological designation which outweighs the agricultural considerations.

If best and most versatile land needs to be developed and there is a choice between sites in different grades, land of the lowest grade available should be used.

71 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected NH6 POLLUTION, CONTAMINATED LAND AND None likely None The policy is concerned with LAND INSTABILITY limiting pollution and land issues and although not specifically Development that generates atmospheric mentioned may benefit wildlife as emissions which would cause harm or offence to well. human health, senses or property will not be permitted and where such uses exist the local planning authority will not permit sensitive other uses within a reasonable distance of such uses.

Proposals for development involving potential noise nuisance to existing occupiers of land or buildings will only be permitted when measures to minimise the impact of noise likely to be generated are incorporated as part of the development.

Proposals for noise-sensitive developments, typically housing, hospitals and schools, will not be permitted where:

• An unacceptable level of nuisance arises from existing sources of noise (e.g. from road traffic, railways, industrial and commercial developments, recreational and sporting activities) • There is potential for an unacceptable level of nuisance by the increase in the existing level of noise, unless appropriate noise mitigation measures are incorporated in the design of the development.

All development proposals on or in proximity to land known to be, or which may be, contaminated will include measures designed to prevent an unacceptable risk to public health and the environment.

Development proposals will not be permitted on or in close proximity to land known to be, or which may be, unstable.

GT1 GYPSIES AND TRAVELLERS None likely None The policy identifies the need for gypsy and traveller pitches only Appropriate provision will be made to meet and in non locational. identified need for gypsy and traveller pitches.

72 Policy Brief Description Potential Impact Natura 2000 Comment on Natura 2000 sites Sites Potentially Affected ID1 INFRASTRUCTURE DELIVERY None likely None The policy is concerned with implementing infrastructure in such The planning and delivery of development should a way that it is sustainable ensure efficient and effective use of existing infrastructure and should provide for the delivery of an appropriate level of justified new or improved transport, education, health, cultural, sport, recreation and green infrastructure in relation to the development proposed.

The council will work in partnership with service providers, Neighbouring local planning authorities and Somerset County Council to identify necessary local infrastructure requirements for the fulfilment of the strategy

5.11 The following table provides a summary of potential significant effects due to plan policies. This is followed by analysis of the significance each of the potential impacts.

Table 9: Summary of Potential Impacts from the Plan Feature Affected Natura 2000 site Potential Impact Policies Causing Potential Impact Barbastelle Bats Exmoor and Quantocks Loss of feeding habitat EN1 Mitigation of Oak Woodlands SAC and severance of flight Impact of Hinkley Point lines preventing access New Nuclear Proposals to feeding areas MD2 Strategic Development Around Minehead

WI2 Strategic Development at Williton

OC1 Open Countryside Development

EC3 Greenfield Employment Generating Development

EC9 Tourism Outside of Settlements

TR1 Access to and from West Somerset

CF1 Maximising Access To Recreational Facilities

73 Feature Affected Natura 2000 site Potential Impact Policies Causing Potential Impact

NH4 Green Infrastructure

NH5 Protection of Best and Most Versatile Agricultural Land

Mortality from wind EN2 Mitigation of turbine development Impact of Major Energy Generating Proposals

EC11 Agriculture

CC1 Carbon Reduction

Disturbance due to MD2 Strategic increased human Development Around activity around roosts as Minehead part of recreational activity generated by WI2 Strategic new residential housing Development at Williton and /or increased tourism EC10 Gateway (also to Bechstein’s Settlements bat roosts)

Otters Exmoor and Quantocks Disturbance to holt sites MD2 Strategic Oak Woodlands SAC including those used for Development Around breeding Minehead

EC3 Greenfield Employment Generating Development

EC10 Gateway Settlements

NH4 Green Infrastructure

Heathland Habitats Exmoor Heaths SAC Degradation and /or MD2 Strategic loss of habitat due to Development Around Exmoor and Quantocks increased access Minehead Oak Woodlands SAC WA2 Strategic Development at Watchet

WI2 Strategic Development at Williton

EC9 Tourism Outside of Settlements

74 Feature Affected Natura 2000 site Potential Impact Policies Causing Potential Impact

EC10 Gateway Settlements

Degradation and /or MD2 Strategic loss of habitat due to Development Around decreased air quality Minehead

WA2 Strategic Development at Watchet

WI2 Strategic Development at Williton

EC9 Tourism Outside of Settlements

EC10 Gateway Settlements

Woodland Habitats Exmoor and Quantocks Degradation and /or MD2 Strategic Oak Woodlands SAC loss of habitat due to Development Around increased access Minehead

WA2 Strategic Development at Watchet

WI2 Strategic Development at Williton

EC9 Tourism Outside of Settlements

EC10 Gateway Settlements

Degradation and /or MD2 Strategic loss of habitat due to Development Around decreased air quality Minehead

WA2 Strategic Development at Watchet

WI2 Strategic Development at Williton

EC9 Tourism Outside of Settlements

EC10 Gateway

75 Feature Affected Natura 2000 site Potential Impact Policies Causing Potential Impact Settlements

Loss or degradation of TR1 Access to and from habitat due to road West Somerset improvements Wintering and Migratory Severn Estuary SPA / Disturbance to birds in EC9 Tourism Outside of Birds, Wildfowl Ramsar coastal areas from Settlements increased access CC3 Coastal Change Management Area

CC4 Coastal Zone Protection Mortality from wind EN2 Mitigation of turbine development Impact of Major Energy Generating Proposals

EC11 Agriculture

CC1 Carbon Reduction

Analysis of Potential Significant Effects on Features of Natura 2000 Sites

Barbastelle Bats

Loss or Degradation of Habitat 5.12 Barbastelle bats go out in groups from the roosting area then disperse to individual hunting grounds (Dietz et al, 2009; Greenway, 2001; Greenway, 2004; Zeale, 2009) The distance covered by the bat relies on darkened flight lines (Greenway, 2001 & 2004) Typically these are along vegetated rivers and streams or lines of trees and large hedgerows and paths. (Greenaway, 2004) When barbastelle bats are crossing open ground they will fly at low level (Greenaway, 2008).

5.13 An ideal example of breeding colony of barbastelle bats in the distant past would be of a small river catchment with dense woodland on its headwaters and wooded valleys leading to a wide zone of water meadows and finally reed beds and sand dunes before reaching the sea. The colony's territorial boundary would be the catchment area. In modified landscapes colony territories are difficult to define as now they often have unnatural access to new foraging possibilities in adjacent catchments - through plantations for example. (Greenaway, 2004)

5.14 There is one identified colony in Horner Wood in the Exmoor component and a likely roosting area within the Quantocks component of the SAC. The latter

76 assumption is based on surveys carried out near Holcombe by the Somerset Bat Group which due to their timing indicates that barbastelle roost sites are likely to be present nearby.

5.15 A number of policies (EN1, OC1, EC3, EC9, TR1, CF1, NH4 and NH5) which are non locational could potentially affect barbastelle flight lines, preventing or increasing the difficulty of access to feeding areas, and / or the feeding territories of individual bats themselves. These effects can occur at more than 9 kilometres from the roost and can be cumulative. The most likely area for these effects to occur is within the Ecological Zone of Influence (EZI), the methodology for which is described in a previous chapter.

5.16 Policy EN1 relates to the mitigation of impacts from the associated developments to the Hinkley power station new build. It should be noted that a Habitats Regulations Assessment for the site clearance works has already been carried out for effects on the Quantocks barbastelle bat population and a sum for offset habitat creation has been agreed7. However, this is not the case for other associated projects.

5.17 Policy MD2 specifically relates to the strategic location of development at Minehead. At Minehead the strategic sites which fall within the EZI and therefore host habitat that potentially support the maintenance of the Horner Wood barbastelle bat population include site numbers A4, A5 and A6. These lie on the edge of the EZI and are therefore, whilst severance to a large number of feeding territories is unlikely, they are potentially the feeding territories of individual bats along the woodland edge and along hedgerows towards the A39. This would need to be confirmed by survey but for the purpose of this assessment presence is assumed lacking evidence to the contrary and following the precautionary principle.

5.18 About 55 hectares of potential feeding area or prey producing habitat would be affected by the three proposed strategic site locations. Individual barbastelle bats have feeding territories of between 2 and 70 hectares (Boye & Dietz, 2005). Dietz et al (2009) report foraging areas of 8.8 hectares with single bats hunting each night in up to 10 separate areas. There is minimal overlap of individual core foraging areas and individual bats show site fidelity to these foraging patches both over the season and the years (Zeale, 2009). Therefore the sites could affect between 1 and, using 8.8 hectares as an average, 6 bats. There is no data available on the current population of barbastelle bats in Horner Wood. Generally barbastelle bat maternity colonies number less than 30 bats (Greenway, 2008). Therefore, up to 20% of the population may be affected at worst. However, it is likely to be more towards 3% or probably less given the data from radio tracking surveys carried out in 2000 (Billington, 2000)

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77 5.19 Policy WI2 specifically relates to the location of strategic sites around Williton. Barbastelle bat was recorded using the disused quarry in 2009 (SERC data). Potentially this bat could originate from roosts within the Quantocks oak woodlands component of the SAC. However, overall connectivity between the Quantocks and the quarry is poor and therefore it is considered unlikely that development would affect the likely local barbastelle population. It is assumed that the record is for a lone male bat.

5.20 Overall it is considered that a significant effect cannot be ruled out on loss or degradation of commuting and / or feeding habitat used by barbastelle bats as a result of polices in the Local Plan prior to counter-acting measures being applied.

Mortality from wind turbine development 5.21 Policies EN2, EC11 and CC1 make it possible for wind turbine development to occur within the District.

5.22 Natural England guidance suggests that barbastelle bats are of medium risk to collision with turbines and effects on population viability (Mitchell-Jones & Carlin 2009; Matthews et al, 2009). Barbastelle bats could be attracted to single large turbines as they potentially represent a significant tree(s) in the landscape close to features used for commuting. They are known to roost in a single tree in the middle of a field in Wellington 100 metres from the nearest covering habitat and are known to cross open spaces of up to 500 metres when dark (Zeale,2009).

5.23 There is some evidence that insects are attracted to the colour of wind turbines, white or light grey, and that highest bat mortality occurs at the time of insect migration (August – September) [Long et al, 2011; Rydell et al, 2010]. The insects attracted include moths (Long et al, 2011) the main food item of barbastelle bats (Zeale, 2009) It also eats small moths, few Diptera, small beetles and other flying insects (Dietz et al, 2009).

5.24 Cryan (2008) hypothesises that tree bats collide with turbines while engaging in mating behaviours that centre on the tallest trees in a landscape, and that such behaviour stems from two different mating systems (resource defence polygyny and lekking). Bats use vision to move across landscapes and might react to the visual stimulus of turbines as they do to tall trees. If mating bats are drawn to turbines, wind energy facilities may act as population sinks, which would be a risk that is hard to assess prior to the turbines being installed.

5.25 As there is potential for wind turbine development to occur anywhere including within the EZI of barbastelle bats from the SAC it is not possible to conclude that there would be no significant effect as a result of polices in the Local Plan prior to counter-acting measures being applied.

78 Recreational Disturbance at Roost Sites 5.26 A number of policies in the Local Plan increases and / or encourages recreational activity, which would include walking, cycling and other access to the countryside. Barbastelle bats are sensitive to disturbance at roosts (Zeale, 2009). One study considered them to be disturbed by human activity at 75 metres distance from a roost site in woodland (Bennett et al, 2009).

5.27 Roost sites in Horner Wood are not easily accessible by public right of way and not at all by vehicle. The site is 6 kilometres distant from proposed strategic housing sites in Minehead and unlikely to be visited by tourists. The woods are also in the care of the ’s . Therefore, it is considered that a significant effect is unlikely given the remoteness of the roosts. The same conclusion would apply to Bechstein’s bat roosts located in the same roosts.

5.28 Barbastelle bat roosts are also almost certainly present in the Quantocks component of the SAC in the area of Hodder’s Combe / Holford Valley, where no roost has been identified but flight activity has been recorded just after dusk indicates that they are likely to be nearby (Somerset Bat Group, pers. comm.).Although currently unknown it is likely that they are also undisturbed and remote or subject to local disturbance which does not affect the bats to a significant extent. The woods are over 6 kilometres from proposed strategic housing sites in Williton and unlikely to be visited by tourists.

5.29 It is concluded that there is unlikely to be significant effects from disturbance to bat roosts caused by policies in the Plan.

Otters

Disturbance to Holt Sites 5.30 Natal holts seem to be located away from main watercourses and from water altogether even being found 500 metres away. Most sites are within 3.5 metres of water although have been recorded 40 metres from a lake edge and 100 metres in a young conifer plantation. Breeding sites are generally located on but not restricted tributary streams (width 0.7 to 4 metres). (Chanin, 2003)

5.31 Otter breeding sites require security from disturbance; one of more potential natal den sites; play areas for cubs; no risk of flooding; and access to good food supply (Liles, 2003).

5.32 Anecdotal evidence suggests that otters are not seriously affected by disturbance from anglers, walkers and dogs. Otters do not appear to avoid houses, industry, roads and campsites. The response of otters to the sounds of anglers or walkers with dogs is to move to a position where they can see the source of disturbance, dive and swim underwater, then resurface and rest on the bank before resuming

79 their previous activity a short while later. Although individual otters do not appear to be influenced by short periods of disturbance there is a lack of information on how sustained levels of disturbance influences female otters with young. (McCafferty, n/d) Therefore it is assumed for the purposes of this assessment that increased activity around maternity holts would have a significant effect.

5.33 No data regarding the locations of maternity holts have been obtained at the time of writing this report although Exmoor National Park Authority are trying to source the information, which is thought to be held by Somerset Otter Group.

5.34 Outside of the National Park impacts from development in West Somerset is likely to occur in association with policies MD2 Strategic Development around Minehead, EC3 Greenfield Employment Generating Development and NH4 Green Infrastructure. Otters have been recorded making use of the and may be using Areas of Search B1 and B2 with a territory that is likely to include the upper reaches of the , which are just within the Exmoor and Quantocks Oak Woodlands SAC. However it is unlikely that any natal holts are present in this area.

5.35 Policy EC10 Gateway Settlements will encourage tourism and Policy MD2 is likely to increase recreational use of the National Park which could effect levels of disturbance along streams supporting otter holts.

5.36 Although public rights of way either cross or run alongside streams in areas where natal holts are likely to be located it is considered that current access along these paths is low and that they are away from tourist hotspots.

5.37 A number of popular walks are advertised on the internet along riverside paths8. The following are listed: 1. -Hillsford Bridge via Watersmeet 2. Withypool- via . 3. Simonsbath-Withypool via Cow Castle 4. Along the south of Exford below Room Hill Increase activity along these routes may affect natal holts if present. However, the amount of activity generated by Policy EC10 and recreational use resulting from development in West Somerset is unlikely to be significant, being sporadic and confined to day time hours only. Increased activity by dogs is also unlikely.

5.38 Tourist hotspots include locations such as Glen Lyn Gorge south of and Lynmouth, which includes the which is likely to be within the territory of otters recorded in Somerset or Devon (no records for Devon have been obtained although Exmoor National Park Authority are trying to source the data at the time of writing). However, given the current level of access it is

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80 unlikely that natal holts are present.

5.39 The Culbone Way national cycle route crosses several watercourses flowing north in to the and runs alongside the River at Oareford. This is part of a circular route which runs from Minehead to Lynton and Lynmouth and then south to Simonsbath, east to Weddon Cross, Raleigh’s Cross and Elworthy crossing otter used streams at Simonsbath, Exford and Luckwell Bridge. It is considered as the majority of these areas are merely crossing watercourses increased cycle activity is unlikely to disturb any natal sites. Where the watercourse runs alongside the cycle track at Oareford the surrounding land use is mostly agricultural with some broad-leaved woodland on slopes and the route itself is along the highway. Therefore it is considered that there are likely to be any effects on natal holts if present.

5.40 It is concluded that there is unlikely to be significant effects from disturbance to the natal holts of otters caused by policies in the Plan.

Heathland Habitats

Degradation and /or loss of habitat due to increased access 5.41 Policies MD”, WA2 and WI2 would increase the population of the District by about 20%. Policy EC9 states in its justification for the policy specifically states that Minehead will be emphasised as a visitor centre for Exmoor with an increased profile for outdoor pursuits.

5.42 Habitat deterioration and loss from trampling can cause dwarf shrubs to be reduced by 50% cover with less than 200 – 400 passages/year and nitrogen enrichment from dog fouling can change heath to grassland. Wet heath plants are more sensitive. (Penny Anderson Associates, 2009) Even light trampling can damage heathland invertebrate communities. Heathland species may be indirectly affected by lack of grazing pressure in disturbed areas. Impact will depend on current path network, visitor numbers, length of sward, slopes, etc. Tall sward and current paths may minimize impact as walkers are unlikely to walk through tall heather. Fire is a potential hazard on heath especially if on the edge of settlements. (Natural England, unpublished CRoW assessment)

5.43 Walking on or off paths resulting in repeated footprinting could result in localised trampling of habitat/plants, compaction of substrate or erosion of the peat surface, especially in areas of high use adjacent to honey-pot locations. Creation of new paths could have a similar result as above with trampling widths increasing in popular areas. Flushed areas are most sensitive along with sphagna communities, which can be destroyed by 50 to 80 passages. An increase in visitor pressure with area-wide access could result in damage to this sensitive habitat. The most sensitive times of year are when the plants are flowering and setting seed. Blanket bog with flushes and bog mosses are most vulnerable to access. (Natural England, unpublished CRoW assessment)

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5.44 The Exmoor Coastal Heaths SSSI is located to the west of Minehead and is accessible by public footpath. This makes it vulnerable to increased recreational pressure from development on the western edge of the town in Policy MD2 (Sites A1, A2 and A3). For example in the case of dog owners in the South West 29% of households own dogs. For the UK as a whole 22% of households own dogs in EC9 and EC10assuming a capacity of 1450 dwellings on sites A1, A2 and A3 and if only 20% of residents in the new development own dogs then there would be up to 290 new resident dog owners following completion of the developments. Dog walkers on average take 3 walks a day totaling 107 minutes in time, or approximately 36 minutes per walk, at an average speed of 6.44 kilometres per hour (Mail on line, 11/2/2011). The distance walked is therefore likely to be around 3 kilometres. Other access impacts would be from walkers and possibly mountain bikes.

5.45 There are numerous rights of way up from Minehead and then the Southwest Coastal path runs from North Hill to Bossington Hill with a couple of paths running north out of the area to join it. In addition the area is mapped as an ‘access area’ in the Exmoor National Park Management Plan 2007 – 20129. A statutory right of access on foot to open countryside, including moor and heath, for open-air recreation is provided by the Countryside and Rights of Way Act 2000.

5.46 Other heathland habitats in the SACs may also be affected by habitat degradation and / or loss due to recreational access resulting from an increased population (Policies MD1, WA2 and WI2) and tourism (Policies EC9 and EC10). The West and other rights of way are located within the SAC components and there are ‘access areas’ for recreation. However, a survey produced by the National Park on the recreational use of Exmoor’s Moorlands reported the moors were underused with the exception of Dunkery Beacon (within the dry heath area)10.

5.47 Overall visitor numbers to the National Park were falling up to 2005 although the current trend is unknown. In addition the National Park applies the Lord Sandford principle set out in 1974 Review of National Park Policies proposing that, where irreconcilable conflict arose between conservation and recreation, conservation should prevail. This is now incorporated in the Environment Act 1995. (Exmoor National Park Authority Management Plan 2007- 201211)

5.48 It is considered that there is unlikely to be a significant effect from the draft Local Plan policy on heathland habitat within the two SACs considering the

9 10 11

82 management is afforded by the Exmoor National Park Management Plan 2007 – 2012 and the provisions of the Environment Act 1995.

Degradation and /or loss of habitat due to decreased air quality 5.49 Air quality may be affected by transport emissions from increased vehicle movements resulting from new development proposed in the draft Local Plan (Policies MD1, WA2 and WI2) and tourism (Policies EC9 and EC10). Road transport is the source of a number of airborne pollutants. The impacts of nitrogen and nitrogen oxides deposition on vegetation growth are of particular concern. Nitrogen deposition from vehicles will cause eutrophication and lead to the heath to grassland. Transport produces other pollutants including sulphur dioxide, ozone and particulates. Air pollution has been linked to ill health amongst trees, particularly over mature specimens, and also a failure to regenerate, either from coppice, pollard or seed. In grassland nitrogen loving species will suppress sensitive flora. Lichens and bryophytes are particularly sensitive.

5.50 The Habitat Regulations Assessment of the draft Regional Spatial Strategy for the South West (2006) considered 200 metres as the outer distance from a road where nitrogen deposition is expected to occur. Bignall et al, (2004) consider that 150 metres air quality returns to background levels. The greater distance is used, as a precautionary approach is required.

5.51 No traffic modelling has been carried out for the draft Local Plan. Therefore, it is assumed that the majority of traffic generated as a result of policy (MD2, WA2 and WI2) would use the A39 east from Minehead to Williton where it would divide between along the A358 or continue along the A39 to Bridgwater. Similar road use would be made by tourist traffic generated by policy (EC9 and EC10) in the Plan.

5.52 It is considered that traffic levels from new residential development towards Exmoor would not be significant. Tourist traffic would concentrate on routes to car parks for visitor hotspots within the National Park. The A396 south from Dunster lies more than 200 metres from any heathland habitat. However, west of the A39 to Lynton and Lynmouth runs through or adjacent to the Exmoor Coastal Heaths and North Exmoor SSSI components of the Exmoor Heaths SAC where dwarf shrub heath and acid grassland is present. At Porlock Common nitrous oxide (NOx) concentrations for heathland are 7.0 µg, which is 23 µg below the -3 12 critical load of 30 µg NOx (as NO2) m . A concentration of 6.8 µg and 7.0 µg is given for Yenworthy Common for heathland and acid grassland respectively.

83 5.53 Elevated levels of nitrogen deposition enhance dwarf shrub heath growth, whilst lichens and bryophytes are negatively affected (Nordin et al, 2009). Nitrogen deposition above 30kg nitrogen per hectare per year (kg N/ha/year) initially increases heather biomass but after several decades, the heather loses its dominance. The timing of outbreaks of heather beetles strongly affects the balance between heather and grass species. Management intensity, and in particular the removal of dead plant material, modifies the long-term impact of nitrogen deposition. An increase in grass litter, which mineralises faster, sustains the competitive ability of grasses13. Resultant exceedences in nitrogen deposition is likely to result in transition from heather to grass dominance, decline in lichens, changes in plant biochemistry and increased sensitivity to abiotic stress14 .

5.54 In the UK a species loss has been shown to occur in acid grassland as a function of cumulative nitrogen deposition (Nordin et al, 2009)

5.55 At Yenworthy Common nitrogen deposition is 21.4 kg N/ha/year. This is an exceedance above the critical load for dry heaths of 11.4 to 1.4 kg N/ha/year and northern wet heath: Erica tetralix dominated wet heath 11.4 to 1.4 kg N/ha/year. The critical load is 10-20 kg N/ha/year.15

5.56 Annual average daily traffic using the road was 1500 vehicles per day in 2010; 1350 in 2009; 1250 in 2008; 1350 in 2007; and 1500 in 2006 (SCC data) showing a variable trend between 1250 and 1500 vehicles but no significant increase.

5.57 In 2007 transport’s contribution to nitrogen deposition was shown by APIS to be well below the critical load levels16. In addition, as road traffic’s influence is likely to be confined to within 200 metres of the road (HRA of SW RSS, 2006) and although there is likely to be a small increase in traffic from policy in the Local Plan it is considered that this would not be significant effect on heathland habitats

Woodland Habitats

Degradation and /or loss of habitat due to increased access 5.58 Policies MD”, WA2 and WI2 would increase the population of the District by about 20%. Policy EC10 states in its justification for the policy specifically states that Minehead will be emphasised as a visitor centre for Exmoor with an increased profile for outdoor pursuits and Williton for access to the Quantocks.

13 14 15

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5.59 Therefore, there is a risk that habitat deterioration and loss would occur due to increased leisure use from walkers, dogs, cyclists, horse riders and possibly off road vehicles arising from increased population due to proposed development as a result of Policies MD2, WA2 and WI2. In addition encouragement of tourism into Exmoor and the Quantocks through Policies EC9 and EC10 may also result in the same effect from increased use.

5.60 Habitat deterioration and loss from trampling can occur from passages as low as 40 to 50 per year. Bluebell (Hyachinthoides non-scripta) stands are damaged through first passages and 35 passages results in a path that is still visible one year after. Trampling can eliminate species, particularly those of low productivity and especially ancient woodland flora; lichens and some mosses. Trampling can affect species presence 10 metres or more off paths. Horse riders and mountain bikers increase the effect. (Penny Anderson Associates, 2009) Plant species on wet soils are more vulnerable and broad leaved plants disappear before grasses. Nitrogen enrichment from dog fouling can also cause species. (Footprint Ecology, 2009)

5.61 The North Exmoor component of the Exmoor and Quantocks Oak Woodlands SAC is located along the Horner Water and East Water valleys to the west of Luccombe 6 kilometres distant from proposed strategic housing sites in Minehead, further from Watchet and Williton and unlikely to be visited by tourists. The woods are also in the care of the National Trust’s Holnicote Estate. Access is restricted to the , a long distance footpath on Horner Hill. This trail is advertised17 and is likely to take most of any increased use. There is a right of way running through Horner Wood to the west of the site and other paths and tracks run through the woodland. However, it is considered that these would not be subject to significant numbers of extra visitors. Furthermore, tourists may stop at the car park within the SAC boundary to look at the views but it is considered that most of these will not venture far into the woodland.

5.62 The West Exmoor Coast & Woods, Watersmeet and Barle Valley components of the SAC lies over 16 kilometres away from proposed development in Minehead and are unlikely to attract significant additional numbers of residential visitors as a result of the draft Local Plan. Similarly it is not expected that tourists are likely to visit woodland sites away from hotspots in significant numbers. Tarr Steps is located on the edge of the Barle Valley component site but would be accessed to and from Liscombe to the east with little further penetration into the woodland. The Exe Valley Way path runs through the Barle Valley between Hawkridge and Dulverton. The Two Moors Way path runs from Lynmouth to Cheriton in the Watersmeet component site some of which is under the management of the National Trust. These woodlands along with the West Exmoor Coasts and Woods site are remote from casual tourists from a Minehead ‘gateway’ and are likely to be visited on with purpose before visiting the area.

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5.63 As afore stated overall visitor numbers to the National Park were falling up to 2005 although the current trend is unknown. In addition the National Park applies the Lord Sandford principle set out in 1974 Review of National Park Policies now incorporated in the Environment Act 1995. (Exmoor National Park Authority Management Plan 2007- 201218)

5.64 Quantock Hills AONB surveys indicate that substantial numbers of visitors are Somerset residents rather than tourists. In the Quantocks component of the SAC there is some erosion and fragmentation of habitats, almost entirely on rights of way - there is very little vehicle intrusion into the oak woods (Chris Edwards, Quantocks AONB manager, pers. comm.). Tourists are most likely to access the woodland through use of walking The Coleridge Way and the promoted The Greenway paths which run through the woodlands.

5.65 However, visitor patterns show that the majority of the heavy recreational use in the AONB continues to take place in the sensitive upland areas, based on parking locations on or adjacent to Quantock Common19. This includes southern sections of the SAC woodlands. Under Policy V2 of the Quantocks Hills AONB Management Plan 2009 – 2014 impacts from visitors are monitored and action includes re-routing and active restoration following damage.

5.66 It is considered that significant effects are unlikely as a result of increased recreational access from new residents and tourism due to the provisions for management from the National Park and AONB.

Degradation and /or loss of habitat due to decreased air quality 5.67 Air quality may be affected by transport emissions from increased vehicle movements resulting from policy in the draft Local Plan (Policies MD1, WA2 and WI2) and tourism (Policies EC9 and EC10) and in particular traffic commuting to Bridgwater along the A39. The A39 runs through the Quantocks component site.

5.68 Road transport is the source of a number of airborne pollutants. The impacts of nitrogen and nitrogen oxides deposition on vegetation growth are of particular concern. Transport produces other pollutants including sulphur dioxide, ozone and particulates. Air pollution has been linked to ill health amongst trees, particularly over mature specimens, and also a failure to regenerate, either from coppice, pollard or seed. Nitrogen deposition can lead to decreases in mycorrhiza, loss of epiphytic lichens and bryophytes, and changes in ground vegetation20. Traffic along the A39 may increase nitrogen deposition within 20021

18

19 20 21 200 metres is the distance from a road where nitrogen deposition is expected to occur in the Habitat Regulations Assessment of the draft Regional Spatial Strategy for the South West (2006). Bignall et al, (2004) consider that 150 metres air quality returns to background levels. The greater distance is used, as a precautionary approach is required.

86 metres of the road.

5.69 The Exmoor Oak Woodlands sites support extensive tracts of old sessile oak woods in conjunction with heath. They are rich in bryophytes, ferns (including Dryopteris aemula) and epiphytic lichens. In the summary of standards/factors that maintain site integrity it is stated that ‘…woodland habitats and associated moss and lichen communities are sensitive to air pollution’.

5.70 At Shervage Wood nitrogen deposition for the SAC currently exceeds critical loading by 25.6 to 20.6 kg N/ha/year. However, nitrogen oxides are well below -3 critical loads for the site – a concentration of 8.5 µg NOx (as NO2) m , 21.5 µg -3 -3 22 NOx (as NO2) m below the critical level of 30 µg NOx (as NO2) m . Over time continued exceedence of nitrogen deposition would in time cause nitrogen oxides to exceed critical loads as well in areas within 200 metres of main roads.

5.71 However, road transport contributes 7.2% to these pollutants23. Traffic levels on the A39 have been higher in the past following closure of the branch line to Minehead in the 1960s and before the opening of the M5 motorway. In addition sensitive plant species are located more than 200 metres away from the road within the woodland. (Natural England, pers. comm.) Therefore it is considered that increased traffic levels here is unlikely to have a significant effect on the SAC due to air pollution.

5.72 Other woodland components of the SAC are likely to be away from main commuting routes for the West Somerset District settlements and are more likely to be affected by increased tourist traffic. In particular the access road to the tourist hotspot of Dunkery Beacon runs for a short section along the eastern edge of the North Exmoor site. There is also a car park within the SAC boundary. -3 Here concentrations of nitrogen oxides are 7.2 µg NOx (as NO2) m but deposition exceeds critical loading by 13 to 23 kg N/ha/year.

5.73 Traffic may increase to Dunkery Beacon as a result of promotion of Exmoor at Minehead (Policies EC9 and EC10). However, access to and from the Beacon is more likely to be from the opposite direction via the B3224 at Wheddon Cross than from the steep road from Luccombe. There is unlikely to be significant rise in visitors to an already well known hotspot from a Minehead gateway using the Luccombe road and hence any increase in nitrous oxides being deposited would also be insignificant.

5.74 The A39 runs in a valley through the centre of the Watersmeet component of the woodland SAC. Here concentrations of nitrogen oxides are 6.8µg NOx (as NO2) m -3 but nitrogen deposition exceeds critical loading by 14.4 to 24.4 kg N/ha/year.

22

23

87 Lichens, which are sensitive to air pollution, are reported to be declining and the part of the site is in unfavourable condition with regard to this group24. However, it is not likely that a significant increase in tourist traffic due to the Minehead gateway would result from the Local Plan policies (Policies EC9 and EC10) and would be difficult to distinguish from tourists who would visit in any case .

5.75 The West Exmoor Coast & Woods and Barle Valley components of the SAC lies over 30 and 16 kilometres away from proposed development in Minehead respectively and are unlikely to attract significant additional numbers of residential visitors as a result of the draft Local Plan. Similarly it would be difficult to attribute tourists resulting from a Minehead gateway. The B3223 runs adjacent to part of the Barle Valley component site to the north of Dulverton. There are no roads, except a minor one crossing the SAC between Licscombe and Hawkridge. These are not heavily trafficked roads. The West Exmoor Coast & Woods also has only minor and often steep roads within the component site. Any roads within them are lightly trafficked. Hence it is considered that any resultant increased traffic from policy is likely to be minimal.

5.76 It is considered that there would not be a significant effect on air quality adversely affecting habitat quality. Apart from the Quantocks component site increased traffic levels are not likely to be significant from residential development and / or that generated by additional tourists from a Minehead gateway. In addition, as road traffic’s influence is likely to be confined to within 200 metres of the road (HRA of SW RSS, 2006) and that it forms a proportion of attributed total deposition.

Wintering and Migratory Birds and Wildfowl

Disturbance to birds in coastal areas from increased access 5.77 The Bridgwater Bay SSSI component of the Severn Estuary SPA / Ramsar is located on the coast at the eastern end of the District’s administrative area. Table 8 lists the bird species along the coast using inter tidal and terrestrial habitat from Bridgwater Bay to Hinkley Point25. Hinkley Point is within the ecological zone of influence of the SPA / Ramsar and the coastal habitat here supports the populations of birds within the designated site.

Table 8: Bird species present in Bridgwater Bay SSSI and at Hinkley Point in 2009

Species Bridgwater Bay Hinkley Point Bewick’s Swan 0 0 White-fronted Goose 0 0 Dunlin 26000 13

24 25

88 Species Bridgwater Bay Hinkley Point Redshank 20 1 Shelduck 2127 525 Gadwall 38 1 Assemblage Species Wigeon 4000 49 Teal 2250 111 Pintail 140 60 Pochard 5 0 Tufted Duck 30 0 Ringed Plover 2 39 Grey Plover 319 4 Curlew 1110 45 Whimbrel 168 5 Spotted Redshank 6 0

5.78 There is potential for tourist development outside settlements (Policies EC9 and CC3) within the District to generate increased visitor numbers to the coast so as to cause disturbance to birds. This may include a number of bird watchers. Policy CC4 may direct tourists specifically to this section of the coastline. Bridgwater Bay is a National Nature Reserve (NNR).

5.79 Birds are disturbed by human presence and particularly by dogs. Birds respond to disturbance by engaging in activity that is energetically expensive (e.g. flying) or that behaviour is affected in a way to reduce food intake (e.g. moving to a less preferred and less profitable feeding site; losing time loafing before resuming feeding). A number of studies have measured these costs, and show that they sometimes can be considerable. (Goss-Custard, 2005)

5.80 Whilst visitors will not affect the Hinkley Point section of the coastline due to the presence of the nuclear power station and diversion of the existing coastal path following construction of the new build.

5.81 Access to the NNR is via car parks at Dowell’s Farm and Wall Common and the goes out into the Steart Peninsula. There are about 2500 visitors annually.

5.82 Access to Steart Point is controlled by byelaws and Natural England guidance, for example recommending that visitors keep to way marked paths, dogs are kept under control and the use of a bird hide26.

5.83 Therefore, considering existing restrictions it is unlikely that there would be a significant from increased access due to policy in the draft Local Plan.

26

89 Mortality from wind turbine development 5.84 Policies EN2, EC11 and CC1 make it possible for wind turbine development to occur within the District.

5.85 Birds may suffer Injury and mortality from collision with the rotors of wind turbines or with other associated infrastructures, such as overhead cables. Although there is increasing evidence that collision risks are generally low in most cases, there are note-worthy exceptions which must nevertheless be considered, especially for rare species such as large-sized raptors that already under threat and where wind farm fatalities may be an additional factor. (European Commission, 2010)

5.86 Significant collision mortality risks are primarily related to topographical bottlenecks where migrating or local birds fly through a relatively confined area, for example mountain passes or land-bridges between water-bodies. Other susceptible locations include flight corridors between feeding areas, roosting sites or breeding sites. However, there is also increasing evidence among various species of active avoidance behaviour. (European Commission, 2010)

5.87 Peaks in mortality may also be seasonal, for instance during spring and autumn migration when bird concentrations tend to grow significantly. Other factors that could influence collision risks include the species flight height, flight type (migration or commuting flights to and from feeding areas through a wind farm), behaviour, weather conditions, topography and the scale and design of the wind turbines. However, potential increases in collision risk, e.g. during poor visibility, fog or rain, may also be partly offset by lower flight activity in such conditions. (European Commission, 2010)

5.88 The role of warning lights for aviation mounted on turbines is poorly understood though collisions of large numbers of migrants with illuminated structures, especially on overcast nights with fog or drizzle are well documented (Drewitt & Langston, 2006)

5.89 Species presence along the West Somerset coast is shown in Table 8 above. There is potentially some movement of birds between this coast and the and Moors, either as part of daily activity between roosts and feeding areas, as a result of adverse cold weather or on migration. This is likely to be duck species, such as wigeon, teal and pintail. For example teal are known to use separate habitats; roosting sites used during the day and foraging sites at night. Teal are most likely to leave roost sites and forage at night, i.e. commute. In the Carmargue they make flights of up to 15 kilometres between roost sites and feeding areas (Cramp, 1977; Legagneux et al, 2009)

5.90 Commuting and other flights are likely to be to the east and south east towards the Levels and Moors sites. This would probably mean that flights would overfly the district east of and wind farms in this area could possibly pose a risk to bird populations. Teal, wigeon and pintail have all been recorded in

90 significant numbers.

5.91 Studies of bird movements in response to offshore wind turbines have observed wildfowl taking avoiding action from a variety of distances, varying from 100 metres and 3000 metres (Christensen et al. 2004). However, such effects are not common to all birds; for example, Everaert et al (2002) recorded large numbers of birds regularly flying through wind farms. In southern Alberta it was observed that of 413 ducks (primarily mallards and northern pintails in flocks of up to 120 birds), 71.4% altered their course. Almost all (98.6%) flew over, and very few (1.4%) flew around turbines (Brown & Hamilton, 2006). Wigeon are considered to take long deflective flights to avoid wind turbines (Krijgsveld & Dirksen, 2006). It appears that most non breeding shelduck avoid wind turbines by 100 to 150 metres (Everaert, 2009). However, no data specifically relating teal behaviour has been sourced.

5.92 However, there remains uncertainty as there is no data relating to day, night and seasonal flight patterns over the eastern end of the West Somerset District area from the Severn Estuary to the Somerset Levels and Moors and vice versa. Stewart et al, 2005 noted, ‘Available evidence suggests that windfarms reduce the abundance of many bird species at the windfarm site. There is some evidence that Anseriformes (ducks) experience greater declines in abundance than other bird groups suggesting that a precautionary approach should be adopted to windfarm developments near aggregations of Anseriformes and to a lesser extent Charadriformes [such as lapwings] particularly in offshore and coastal locations. There is also some evidence that the impact of windfarms on bird abundance becomes more pronounced with time, suggesting that short term bird abundance studies do not provide robust indicators of the potentially deleterious impacts of windfarms on bird abundance.

‘… results should be interpreted with caution given the small sample sizes and variable quality data. More high quality research and monitoring is required, in particular, long term studies with independent controls and variance data. Pending further research, if impacts on bird abundance are to be avoided, the available evidence suggests that windfarms should not be sited near populations of birds of conservation importance, particularly Anseriformes’.

5.93 Therefore, it is concluded that a likely significant effect cannot be ruled out due to potential mortality on SPA / Ramsar bird populations from wind turbine developments.

91 6. Other Relevant Plans or Projects

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

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

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

Table 8: Assessment of Plans and Projects for In-Combination Effects Implications for West Somerset Likely Significant Effects Plan or Project District Council Local Plan Somerset Local New housing resulting from policy in Provisions in the Exmoor National Park Planning other district and borough council Core Management Plan and the Quantock Authorities’ Core Strategies or Local Plans could have in- Hills Management Plan should prevent Strategies or Local combination effects from increased increased recreational damage from Plans potential for recreational effects on increased visitor pressure. Green Natura 2000 sites. This is most likely to infrastructure provision within these occur at the Exmoor and Quantocks plans will also help to alleviate Oak Woodlands SAC and Exmoor pressure. Heaths SAC.

Traffic resulting from new housing and Alone it was considered that air quality encouragement of tourism could declines from traffic were either remote potentially cause a decrease in air or distant from sensitive locations or quality at sensitive sites. that levels or traffic was small.

There may be some increase in commuter traffic along the A39 from Bridgwater towards Minehead but elsewhere heavily trafficked main roads are away from sensitive sites. However, the Quantocks oak woodlands are less sensitive close to the road and traffic levels have been higher in the past. Similar conditions would apply to any increase from tourist traffic.

92 Implications for West Somerset Likely Significant Effects Plan or Project District Council Local Plan Exmoor National Policy and actions within the None predicted Park Management Management Plan avoid impacts on Plan SACs.

Quantocks AONB Policy and actions within the None predicted Management Plan Management Plan avoid impacts on SACs. Somerset Waste There is unlikely to be in combination None predicted Core Strategy effects as Somerset waste strategy is likely to focus growth on existing facilities.

Somerset Minerals The only quarry within the District is east None predicted Local Plan 1997 ­ of West Quantoxhead and is currently 2011 dormant.

Future Transport Major infrastructure schemes are The Forward Transport Plan Plan (Somerset concentrated within Taunton and other encourages sustainable transport. The County Council) policies work towards a reduction of A39 to Minehead and the B3224 across traffic using roads. There is a Freight Exmoor are designated as County Strategy, which directs HGV traffic onto Freight routes. Any increased freight certain routes through the County. traffic generated in the West Somerset There could be in-combination effects district is likely to use the A39 to where these routes run within 200 Minehead and would only affect the metres of sensitive Natura 2000 sites. Quantocks oak woodlands component site. However, the FTP seeks to implement alternative forms of freight transport. Therefore it is considered that there is unlikely to be a significant effect.

Rights of Way As there are potentially in-combination Provisions in the Exmoor National Park Improvement Plan impacts arising from increased Management Plan and the Quantock 2006 (Somerset recreational pressure where previously Hills Management Plan should prevent County Council) obstructed rights of way are opened up increased recreational damage from to or have improved access. increased visitor pressure.

Steart Coastal A wetland creation scheme in The scheme includes a new visitor Management compensation for that lost carrying out facilities run by the Wildfowl and Project flood defence works. It is forecast that Wetlands Trust and the RSPB (Environment the scheme would bring 45000 visitors especially to cater for bird watchers. Agency) per annum to the area and there is the Management measures should be in potential for in combination increases to place to secure non disturbance. disturbing wintering, migratory birds and waterfowl in the Severn Estuary SPA / Ramsar.

93 7. Counteracting Measures

Introduction 7.1 This chapter will set out counter-acting measures to any impact arising from implementation of the policy to negate the potential significant effect identified in the previous chapter. This may be in the form of policy wording and addition or amendment to supporting text, and / or changes or alterations to areas allocated for development.

7.2 Policies where counter-acting measures, at this stage, do not negate the potential for a significant effect need to be re-considered before bringing forward into the final stage of Local Plan development. These policies may require a Stage 2 ‘Appropriate Assessment’ if significant effects cannot be negated at this stage.

Identified Likely Significant Effects 7.3 Chapter 5 identified that likely significant effects were possible on the conservation objectives of the following feature of the Exmoor and Quantocks Oak Woodlands:

Barbastelle Bats

Non locational Loss or Degradation of Habitat A number of policies (EN1, OC1, EC3, EC9, TR1, CF1, NH4 and NH5) which are non locational could potentially affect barbastelle flight lines, preventing or increasing the difficulty of access to feeding areas, and / or the feeding territories of individual bats themselves. These effects can occur at more than 9 kilometres from the roost and can be cumulative.

Mortality from wind turbine development Policies EN2, EC11 and CC1 make it possible for wind turbine development to occur within the District. As there is potential for wind turbine development to occur anywhere including within the colonial territory of barbastelle bat populations from the SAC there is a potential risk of mortality that could affect the viability of the populations.

Minehead Strategic Sites Loss or Degradation of Habitat Policy MD2 specifically relates to the strategic location of development at Minehead. At Minehead the strategic sites which fall within the EZI and therefore host habitat that potentially support the maintenance of the Horner Wood barbastelle bat population include site numbers A4, A5 and A6.

94 Counteracting Measures

Exmoor and Quantocks Oak Woodlands SAC

Existing Policy 7.4 Policy NH3 on nature conservation and the protection and enhancement of biodiversity requires that development give protection to biodiversity. However, ‘biodiversity’ is a too generic term to afford protection specifically directed to the barbastelle bat feature of the Exmoor and Quantocks Oak Woodlands SAC in this case. Biodiversity includes the diversity of all forms of life and the mechanisms that support it, embraces all species and habitats, including those not afforded protection under legislation, and indeed also garden plants and arable crops.

7.4 In addition, as barbastelle bats are affected by changes to land use up to and beyond 9 kilometres from the designated site’s boundaries it is also considered that these effects will not necessarily be detected or be taken into account in the planning process. Therefore it is considered existing policy would not negate the potential of a significant effect occurring.

Non Locational Measures 7.5 Potential impacts on the viability of barbastelle bat populations have been identified through loss or degradation of habitat and risk of mortality from wind turbine installations.

7.5 To counteract any potential impacts occurring, a new policy should be included in the Local Plan specifically to ensure that these effects are unlikely to arise. The following policy is recommended:

Bat Consultation Zone The District hosts the Exmoor and Quantocks Oak Woodlands SAC Special Areas of Conservation (SAC), which has barbastelle bats as a one of its features. As ‘competent authority’ under the Conservation of Species and Habitats Regulations 2010 [the ‘Habitats Regulations’] West Somerset District Council is required to carry out a ‘test of likely significant effect’ on planning applications that potentially affect the conservation objectives of the site.

Barbastelle bats rely on a number of features in order to maintain their populations, the conservation objective of the SACs, including hedgerows as flight lines and trees used as night roosts, and loss or alteration to these features from removal, change in habitat, and the introduction of street lighting may result in permanently reducing the amount of habitat required to maintain the population.

95 Applications occurring within the Bat Consultation Zone which affect features used by barbastelle bats are likely to require the District Council to carry out a ‘test of significance’ under the Habitats Regulations, including consultation with Natural England. The Bat Consultation Zone marked on the Proposals Map are areas which barbastelle bats are likely to be regularly use for commuting and/or foraging and in night roosting, The mapping is drawn from activity surveys and aerial photographic interpretation of habitat used by bats, that are features of the SACs.

BAT CONSULTATION ZONE PLANNING APPLICATIONS FOR DEVELOPMENT ON SITES WITHIN THE BAT CONSULTATION ZONE MAY REQUIRE A ‘TEST OF SIGNIFICANCE’ UNDER THE HABITATS REGULATIONS TO BE CARRIED OUT. APPLICANTS MUST PROVIDE ALL NECESSARY INFORMATION TO ENABLE SUCH A TEST TO BE CONDUCTED, INCLUDING ANY NECESSARY SURVEY WORK, REPORTS AND AVOIDANCE / MITIGATION MEASURES WITH THE APPLICATION.

Purpose

o To secure the conservation objectives of the barbastelle bat feature of the Exmoor and Quantocks Oak Woodlands SAC from effects outside of its designated boundaries

Assumptions

o Barbastelle bat populations are affected by changes to land use up to and beyond 9 kilometres from the designated site’s boundaries. These effects will not necessarily be detected or be considered in the planning process.

Justification including any references

As ‘competent authority’ under the Conservation of Species and Habitats Regulations 2010 [the ‘Habitats Regulations’] West Somerset District Council is required to carry out a ‘test of likely significant effect’ on planning applications that potentially affect the conservation objectives of the site. The District Council is also responsible for ensuring that populations and distribution of European Protected Species are maintained at a ‘Favourable Conservation Status’ as defined in Article 1 of the Habitats Directive.

Outcome of the Habitats Regulations Assessment of the draft Local Plan. December 2011.

7.6 Map 3 below shows the Bat Consultation Zone for the geographic extent of West Somerset District Council. There are two areas, one related to the North Exmoor

96 component of the Exmoor and Quantocks Woodland SAC which occurs in a small area to the south of Minehead and another from the Quantocks component site which extends into areas of the Washford River valley and towards to east of the Quantock Hills towards Shurton and .

Map 3: West Somerset Bat Consultation Zone

Minehead Strategic Sites 7.7 It is considered existing policy with the draft Local Plan would not eliminate the potential impacts from development if sites A4, A5 and A6 on barbastelle bats. Policy MD1 states that development may give, ‘appropriate treatment to the town’s surroundings in the context of national designations’. In addition Policies for Landscape Character Protection (NH2) and Nature Conservation and the Protection and Enhancement of Biodiversity (NH3) are too generic to robustly prevent potential impacts.

7.7 To counteract the existing policy MD2 the policy needs to additionally specify the intended limit of the development area within the area of search for each site, A4, A5 and A6. The green dashed line in Map 4 indicates an approximate maximum extent of development towards the boundary of the National Park. This needs to be added to the Local Plan key diagram for Minehead Area of Search in Appendix A.

97 Map 4: Areas of Search Showing Development Limits

7.8 It is the intention of WSDC that the Master Planning process would be careful to ensure that the significant hedge lines and woodlands within the area were protected in order to maximise the retention of their habitat value. There are a number of small wooded valleys dividing this area. These should be retained as footpath and habitat corridors. However, neither Policy MD 2 nor Appendix 1 states this intention. Therefore, it is recommended that the policy should be modified as highlighted below:

Policy MD2: STRATEGIC DEVELOPMENT AROUND MINEHEAD PROVISION WILL BE MADE IN THE ENVIRONS OF MINEHEAD FOR A MIXED DEVELOPMENT INCLUDING A TOTAL OF ABOUT 1000 DWELLINGS WITHIN THE AREA TO THE SOUTH OF THE A39, MINEHEAD, AND TO THE NORTH EAST OF SEAWARD WAY, AND IN THE LONGER TERM, POST 2022 TO THE WEST OF DUNSTER MARSH, AS INDICATED ON THE KEY DIAGRAM.

98 Purpose • To provide for an appropriate additional amount of housing, commercial and community land uses in the most sustainable location available at Minehead. Assumptions • That the provision of a significant amount of housing development at Minehead will serve to maintain and strengthen Minehead’s role and function as a main service centre for the wider area and minimise the level of travel out of the local area to access facilities in more distant centres. • The provision of strategic development in these general locations will: • Help to minimise the risk from flooding • minimise the walking time from the new development into the town centre and to other local facilities. Justification The SHMAs confirm the need for at least the level of housing provision including which was included in the last version of the emerging RSS – namely any 2500 dwellings over the period to mid 2026. In order to meet this level of references provision in the most sustainable way – i.e.: • so that additional transport demand is minimised and access to non- private car transport modes is maximised (notwithstanding the recognised limitations of public transport in the area), it is essential to locate the largest part of it where the best range of services are available. Also Minehead is the main focus for public transport services in West Somerset. • so that flood risk within the area is appropriately managed, and especially that the potential for flood risk in the area to the north east of Seaward Way is addressed as part of any development. • so that impact on the landscape is managed appropriately. The land identified by this policy is unconstrained by flooding, landscape or nature conservation designations. Detailed design of schemes can address this issue. However, there are potentially impacts on the barbastelle bat feature of the outside of designated boundary the Exmoor and Quantocks Oak Woodlands SAC which nonetheless ecologically support its conservation objectives. • so that any impacts on the barbastelle bat feature of the Exmoor and Quantocks Oak Woodlands SAC can be offset within the Areas of Search (A4, A5 and A6). Biodiversity offsetting is likely to be required as a result of the assessment under the Habitats Regulations 2010 at a project level for these sites. • so that impact upon the natural and historic heritage is managed in an appropriate way • to avoid the provision of large amounts of new residential development in less well serviced parts of the District. • In the latter part of the plan period land to the west of Dunster Marsh can contribute to the development needs of the town following on from the implementation of development sites adjacent to the existing Minehead urban area.

99 7.9 Additional bullet points should be inserted into sites A4, A5 and A6 in the respective descriptions in Appendix A under ‘Ecology – limit development to the north of the development line to avoid due to potential impacts on the use of the landscape by barbastelle bats from the Exmoor and Quantocks Oak Woodlands SAC. Development sites will require biodiversity offsetting to ensure no net loss of supporting habitat.’

7.9 In addition the policy should explicitly state that biodiversity offsets will be calculated for the each of the sites so that any prey supporting habitat is robustly compensated for.

Severn Estuary SPA / Ramsar

Existing Policy 7.8 Policy NH3 on nature conservation and the protection and enhancement of biodiversity requires that development give protection to biodiversity. However, ‘biodiversity’ is a too generic term to afford protection specifically directed to the wintering and migratory bird and waterfowl features of the Severn Estuary SPA / Ramsar. Biodiversity includes the diversity of all forms of life and the mechanisms that support it, embraces all species and habitats, including those not afforded protection under legislation, and indeed also garden plants and arable crops.

7.9 In addition, as bird features are found outside the designated site’s boundaries, either commuting, resting or feeding it is also considered that these effects will not necessarily be detected or be taken into account in the planning process. Therefore it is considered existing policy would not negate the potential of a significant effect occurring.

Non Locational Measures 7.10 Potential impacts on the viability of wintering, migratory bird populations and the waterfowl assemblage have been identified through risk of mortality from wind turbine installations.

7.11 To counteract any potential impacts occurring, a new policy should be included in the Local Plan specifically to ensure that these effects are unlikely to arise. The following policy is recommended:

Wetland Bird Consultation Zone The Severn Estuary SPA / Ramsar site extends along the coast of West Somerset towards Hinkley Point. As ‘competent authority’ under the Conservation of Species and Habitats Regulations 2010 [the ‘Habitats Regulations’] the District Council is required to carry out a ‘test of likely significant effect’ on planning applications that potentially affect the

100 conservation objectives of the site.

Wintering and migratory birds and the waterfowl assemblage may be at risk to mortality from collision with wind turbines. .

Applications occurring within the Wetland Bird Consultation Zone are likely to require the District Council to carry out a ‘test of significance’ under the Habitats Regulations, including consultation with Natural England. The Wetland Bird Consultation Zone marked on the Proposals Map are areas which are likely to be used for commuting between the Severn Estuary and the Somerset Levels and Moors. The mapping consists of an area of the District that is likely to be over flown by the affected bird species taking into account a precautionary approach and lacking survey data.

WATERFOWL CONSULTATION ZONE PLANNING APPLICATIONS FOR WIND ENERGY DEVELOPMENT ON SITES WITHIN THE CONSULTATION ZONE MAY REQUIRE A ‘TEST OF SIGNIFICANCE’ UNDER THE HABITATS REGULATIONS TO BE CARRIED OUT. APPLICANTS MUST PROVIDE ALL NECESSARY INFORMATION TO ENABLE SUCH A TEST TO BE CONDUCTED, INCLUDING ANY NECESSARY SURVEY WORK, REPORTS AND AVOIDANCE / MITIGATION MEASURES WITH THE APPLICATION.

Purpose

o To secure the conservation objectives for wintering and migratory bird populations and waterfowl assemblage of the Severn Estuary SPA / Ramsar from effects outside of its designated boundaries

Assumptions

o Some species of commuting birds including swans, geese, ducks and waders are vulnerable to collision with wind turbines.

Justification including any references

As ‘competent authority’ under the Conservation of Species and Habitats Regulations 2010 [the ‘Habitats Regulations’] West Somerset District Council is required to carry out a ‘test of likely significant effect’ on planning applications that potentially affect the conservation objectives of the site.

Outcome of the Habitats Regulations Assessment of the draft Local Plan. December 2011.

101 7.9 Map 5 below shows the Wetland Bird Consultation Zone for the geographic extent of West Somerset District Council. The mapping is intended as a tool to alert planners and developers to the potential for an effect on the Severn Estuary SPA / Ramsar site. It is not based on survey data and therefore is not considered to be an accurate representation of bird movement. The formation of the zone is based on the relative positions of the two wetland areas. It is also intended that it can be up dated as a result of survey work and amended in reviews of the Local Plan.

Map 5: West Somerset Wetland Bird Consultation Zone

102 8. Conclusion

8.1 It is considered by West Somerset District Council that provided the counteracting measures as set out in Chapter 7 are incorporated into the final Local Plan that the plan is unlikely to have a significant effect on the conservation objectives of the Natura 2000 sites assessed at this stage of its development. These are:

• the inclusion of a Bat Consultation Zone policy; • the development limit is added to the key diagram for Minehead for sites A4, A5 and A6 • additional policy text under Policy MD2 and within Appendix 1 for strategic site numbers A4, A5 and A6 in Minehead to offset potential impacts on barbastelle bats; and • the inclusion of a Wetland Bird Consultation Zone policy.

8.2 However, if the above recommendations are incorporated into further development of the Local Plan no further stage of assessment under the Habitats Regulations would be required..

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