Land North of Road, / Regulations Assessment / Report for NPS Property Consultants

Land North of Norwich Road, Acle / Habitats Regulations Assessment / Report for NPS Property Consultants

10/17

/ 03/09/14 10 Date

Approved by Danny Thomas Tracy Simpson . www.ecologyconsultancy.co.uk .

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/ 6396 / Graham Hopkins (Hons) BSc PhD PGCE FRES CEnv MCIEEM 140961 Reviewed by Alex Prendergast RachelDr Saunders @ecologyconsultancy.co.uk @ecologyconsultancy.co.uk Property Consultants rachel

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Habitats Regulations Assessment NPS Land North of Norwich Road, Acle Road, Norwich of North Land Initial Revised Author No.Job 603 628408 628408 603 . 01

The Ecology Consultancy Thorpe House, 79 Thorpe Road, Norwich, NR1 1UA NR1 Norwich, Thorpe Road, 79 Thorpe House, Ecology Consultancy The T

Contents

Executive Summary 1 1 Introduction 4 2 Background HRAs 6 3 Disturbance Impacts and Visitor Origins 7 4 Available Recreation Resources Locally 13 5 Refined List of Scoped-In Sites and Footpaths 19 6 Stage 1: Tests of Likely Significant Effects 24 7 In-Combination Effects 27 References 28 Appendix 1: Legislation and Process 31 Appendix 2: Background Information 36 Appendix 3: Figures 41

LIABILITY The Ecology Consultancy has prepared this report for the sole use of the commissioning party in accordance with the agreement under which our services were performed. No warranty, express or implied, is made as to the advice in this report or any other service provided by us. This report may not be relied upon by any other party without the prior written permission of The Ecology Consultancy. The content of this report is, at least in part, based upon information provided by others and on the assumption that all relevant information has been provided by those parties from whom it has been requested. Information obtained from any third party has not been independently verified by The Ecology Consultancy, unless otherwise stated in the report.

COPYRIGHT © This report is the copyright of The Ecology Consultancy. Any unauthorised reproduction or usage by any person is prohibited. The Ecology Consultancy is the trading name of Ecology Consultancy Ltd. .

EXECUTIVE SUMMARY  As required by the Conservation of Habitats and Species Regulations 2010 (hereafter Habitats Regulations), before deciding to give consent or permission for a project which is likely to have a significant effect on a European site (either alone or in combination with other plans or projects) the competent authority is required to undertake an Appropriate Assessment of the implications for that site in view of that site’s conservation objectives. European sites are Special Areas of Conservation (SACs), Special Protection Areas (SPAs) and also include Ramsar Sites.

 The proposals are for a scheme of 140 dwellings and associated open space on land off Norwich Road Acle. The scheme gained outline planning consent in January 2015 and this report examines the proposals in relation to the requirements of the Regulations and updates the initial report produced in 2014 in light of the need to apply to renew the outline planning permission.

 With the exception of an additional area of off-site informal open space secured by way of a Section 106 agreement, the proposed scheme details have not altered since the first report was produced. The provision of 140 dwellings is still anticipated to result in a projected increase in the population (by 322 residents compared to a current population of 2824). This Habitats Regulations Assessment (HRA) considers the potential increase in visitor numbers and recreation pressure on European sites resulting from increased number of residents living in the proposed project (development).

 Previously, Natural England had objected to the project, raising specific concerns over increased recreation pressure over two Sites of Special Scientific Interest (SSSIs) (component sites of the European sites): Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI. At a plan level it was appreciated that green infrastructure and appropriate alternative greenspace could reduce the need for residents to visit European sites. As part of subsequent negotiations with the Local Planning Authority (LPA), in addition to the open space which was to be provided within the site itself, an additional area of land (1 hectare) is to be provided off-site.

 A review of visitor patterns is presented, based on a limited amount of available ‘postcode data’ for and then from the wider literature.

 As an initial scoping exercise a search radius of 6km is used, and within this the component sites of the European sites are identified and walking paths ‘promoted’ by local organisations or tourist books are identified.

 Literature evidence suggests that recreational visitors arriving on foot to countryside sites rarely travel more than 2km from home, thus 2km is used as a radius to refine the scoping area. Residents travelling by car would travel further, but with the large conurbations of

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Norwich and 12-15km distant then it would be expected that at many sites where car travel is necessary the numbers of visitors from these large conurbations would far outnumber those from the project.

 Four paths promoted locally are identified, two of which are close to SSSIs: the Weaver’s Way and a small circular route included as part of the Burlingham Woodland Walks but isolated from the larger western network of paths (this path is therefore called Roman and Damgate Woods Walk). The Weaver’s Way passes adjacent to both of the SSSIs of concern to Natural England, with this being a long distance path. The smaller ‘local’ Roman and Damgate Woods Walk only passess close to SSSIs along the sections of its length also designated as the Weaver’s Way. Furthermore, The Roman and Damgate Woods Walk passes near (as part of the Weaver’s Way) and the remainder of the Roman and Damgate Woods Walk does not come within 250m of Decoy Carr, Acle SSSI.

 Neither Decoy Carr, Acle SSSI nor Damgate Marshes, Acle SSSI have public footpaths. In addition, the latter is not designated for birds as part of the Special Protection Area, and as such, it is considered likely that disturbance of the qualifying features of this site is less likely. Across the two local SSSI the non-bird qualifying features are likely to be of low sensitivity to disturbance: two snails and stands of saw sedge which is likely to be wet and inhospitable to casual walkers. Marsh harriers are recorded locally but only once and as such the general area is considered to be of low importance to marsh harriers.

 Adjacent to the project site runs a path leading to the Burlingham Woodland Walks, which comprises a network of 21km of paths with circular routes and small loops. This is promoted locally for public use. The proximity and quality of this existing promoted walk and paths is considered to be high and it is considered to represent high quality alternative green space for walkers and dog walkers: it will be the main walking routes used by residents. Integral greenspace on the completed project will also serve to reduce off-site recreation somewhat.

 It is concluded that the proposed project will not result in more than very low numbers of visitors to designated sites or their component SSSIs of Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI. Any increase in visitors is likely to be minor and not apparent within the variation from visitors from other sources, such as larger nearby conurbations and tourists. It is therefore considered that there is sufficient confidence to conclude that the presence of 322 new residents to the west of Acle, within the completed project, will not result in more than relatively and absolutely minor increases in the numbers of visitors and therefore recreational disturbance to The Broads SAC, Broads Ramsar site and the Broadsland SPA and/or their individual component sites. There is sufficient confidence to conclude that there will be no impact on site integrity. As such an Appropriate Assessment is not required.

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 In combination with other housing schemes the arguments presented in this HRA are equally valid and it is concluded that there will be no in-combination effects on site integrity.

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1 INTRODUCTION

OVERVIEW 1.1 As required by the Conservation of Habitats and Species Regulations 2010 (hereafter Habitats Regulations), before deciding to give consent or permission for a project which is likely to have a significant effect on a European site (either alone or in combination with other plans or projects) the competent authority is required to make an Appropriate Assessment of the implications for that site in view of that site’s conservation objectives. The competent authority must consult the appropriate nature conservation body and have regard to any representations made by that body.

1.2 In response to the Broadland Site Allocations Development Plan Document, Natural England (2014a) had previously considered the site proposed for 140 new dwellings off Norwich Road in Acle, , to be ‘unsound' due to possible increases in recreational pressure on European sites from an increased local population. In response to the initial application for this project, Natural England expressed concerns regarding recreational impacts on The Broads Special Area of Conservation (SAC), Broadland Special Protection Area (SPA) and The Broads Ramsar site (Natural England, 2014b). As such they requested a Habitats Regulations Assessment (HRA) to determine whether the project is potentially likely to have a significant effect on the European sites. The Stage 1 HRA report was produced in 2014 (The Ecology Consultancy 2014).

1.3 The proposal for 140 dwellings has since gained outline planning consent (January 2015 (ref: 20141108)). A red-line boundary of the site is provided in Appendix 3: Figure 1. As part of subsequent negotiations with the Local Planning Authority (LPA) in relation to concerns raised by Natural England, in addition to the open space which was to be provided within the site itself, a further area of land (1 hectare) is to be provided off-site as informal open space. This is shown on Figure 2 (Appendix 3).

1.4 The applicant is now proposing to apply to renew the outline planning permission. As such, an update to the initial HRA report has been requested. The details of the scheme remain unchanged from those presented in the initial HRA report with the exception of the additional 1ha area of off-site land.

1.5 This update report is prepared on behalf of the applicant and is intended to form the first stage of the HRA process and provide the data for any subsequent Appropriate

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Assessment by providing relevant data and information with which the competent authority can then assess the risks of effects.

LEGISLATION & PLANNING POLICY 1.6 The need for an Appropriate Assessment originally arose under the requirements of the EC Habitats Directive (92/43/EEC) and its implementation in the UK under the Conservation (Natural Habitats &c.) Regulations 1994. The Conservation of Habitats and Species Regulations 2010 were published and consolidated the legislation, updated and incorporated the various amendments made to the Conservation (Natural Habitats, &c.) Regulations 1994 (the 1994 Regulations). No detailed review of the 1994 Regulations has taken place, and the 2010 Habitats Regulations make no substantive changes to existing policies or procedures. Additional details of legislation and the HRA process are provided in Appendix 1.

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2 BACKGROUND HRAS

OVERVIEW 2.1 A number of HRAs have been undertaken locally for housing plans, in relation to, for example, The Greater Norwich Area, Broads Authority Area and Great Yarmouth. In general these identify recreational pressure from increased housing as being issues for individual projects: for example, within the Broads Authority (2006) this is addressed within Core Strategy Policy (CSP) 2 which states: “the principle being that if attractive and accessible local opportunities for everyday recreational uses, such as dog walking, could be provided there would be a reduced need for residents to visit European sites”. Two sites (with multiple designations) were identified as possibly being at risk of impacts, namely: SPA and Ramsar Site (CSP 10); and The Broads SAC and Ramsar Site and the Broadland SPA (CSP 10, CSP 16 and CSP 17); for both sites CSP 2 is identified as the key policy for justifying site-by-site assessment of impacts.

THIS PROJECT 2.2 As mentioned, Natural England had previously considered this site unsound at a plan level and had objected at the project level.

2.3 At the plan level Natural England (2014a, p3) had stated: this site allocation “needs further consideration of recreation disturbance impacts through the HRA. We believe this policy unsound until this issue has been satisfactorily resolved”. Within local HRAs, as precied by Natural England, mitigation is seen as feasible provided enough suitable alternative greenspace is created to attract visitors away form European sites. However, although Natural England accept this in principle they express concern over the wider green infrastructure strategy locally and its status in terms of delivery and deliverability.

2.4 The component sites of particular concern are (Natural England, 2014b): Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI.

2.5 Since Natural England’s original comments, negotiations with the LPA have resulted in the inclusion of an additional 1ha of off-site land which is to be used as informal open space. This forms part of the consented development and is secured by way of a Section 106 agreement. For the purposes of the report, this additional open space is therefore regarded as an integral part of the proposed development.

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3 DISTURBANCE IMPACTS AND VISITOR ORIGINS

DISTURBANCE 3.1. The main potential impacts identified and considered here are recreational impacts resulting from increased numbers of local residents both in isolation and in combination with other schemes.

3.2. Potential impacts identified as being of principal importance to this assessment are:

 Trampling effects on vegetation, and

 Disturbance of birds.

3.3. The most visible impact on most habitats is direct trampling effects, destroying vegetation, preventing re-growth and compressing soils. Related mechanisms include nutrient enrichment from dog fouling and even directly irresponsible behaviour such as fires and littering.

3.4. Understanding the effects of disturbance on birds is difficult, but an extended discussion is included within the HRA for the Broadland District Council Development management Policies Document (Norfolk County Council, 2014, pp.18). Disturbance to birds may be as simple as birds flying away when disturbed, but there may also be complex interactions with factors such as conditions, weather and food availability in determining the significance of impacts. Alternately, effects could be more complex with birds avoiding areas of likely disturbance or even remaining in disturbed areas but with reduced feeding success due to increased vigilance.

VISITORS TO SITES IN THE COUNTRYSIDE 3.5. A key to understanding visitor numbers and by extension recreational disturbance in relation to local housing patterns, is understanding how far people will travel. In popular tourist destinations such as east Norfolk this pattern of local visitors interacts with visitors from wider afield. To understand why visitors go to particular sites, a partial review of visitor surveys in Norfolk and at other sites nationally was undertaken to try and determine the importance of travel distance on the usage of sites.

3.6. A partial review of the scientific and ‘grey’ literature was therefore undertaken to understand the motives for visiting particular sites. In the majority of questionnaire surveys, the responses to why visitors go to particular sites show proximity to be

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very important; examples of survey responses showing the importance of proximity are given below:

 What makes you come here specifically rather than another local site? Close to home (28%), attractive scenery (20%), right place for activity (11%), good for dog (10%), short travel from home (6%) good parking (5%) (data for the Solent; Fearnley et al., 2010).

 Main reasons for visiting? Close to home (36-42%, depending on season), like the countryside (14-17%), good for dogs (7-10%), ability to do different circuits (4-6%) (data for the Thames Basin heaths; Fearnley and Liley, 2013).

 Why visit the Sandlings rather than other local sites? Close to home (34%), good for dog (12%), (8%), attractive scenery (8%) (data for the Suffolk Sandlings; Cruickshanks et al., 2010).

3.7. The majority of sources suggest that the distances many people travel is generally small (Table 1) with high proportions of visitors travelling fewer than 5km and in cases such as the Dorset Heaths, the distances for walkers are very small (e.g. <500m for 75%). That said, it is acknowledged that in comparing sites differences such as geography, proximity of conurbations, long-distance tourist numbers and many other factors do make direct comparison difficult.

Table 1. Partial literature review of travel distances to sites. Location Travel to site Activity there Travel distance Travel All methods Travel distance by people who distance by dog walkers drove to a site people who walked to a site Solent Half of car Half within Half of dog (Fearnley et visitors more 0.7km walkers within al., 2010) than 4km Only 9% of 1.2km 80% of car foot visitors Half of walkers visitors more more than within 2.7km than 2km away 2km Country Park Average travel near Woking distance (incl. car (Fearnley, and foot) is 1.2km. (2011) 50% within 0.46km Dorset 75% live less 75% live Heaths than 5km distant within 500m (Clarke et al., 2010)

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Location Travel to site Activity there Travel distance Travel All methods Travel distance by people who distance by dog walkers drove to a site people who walked to a site North Denes, 69% travelled by 29% walked 50% within 2km, Great car 67% within 4km and Yarmouth 80% within 8.5km (Liley et al., 2009) New Forest 35% within 8km, with (Sharp et al., a high proportion 2008) (40%) being staying holidaymakers Suffolk Wide range for Wide range Medians Sandlings different sites, for different ranging from (Cruickshanks from 0-100% sites, from 0- 0.39-24km (but et al., 2010) travelled by car. 67% walked. not specified by For all sites, 50% For all sites, user) <5km 80% <1km

3.8. A 2015-2016 postcode survey in Norfolk (Panter et al., 2016) of visitors to seven sites with European protection in the Broads1 suggests that visitors travel widely to access the Broads with 46% of respondents being on holiday and the area ranking second highest in the study, after the coast, for the number of overseas visitors interviewed. The report concludes that the Broads may well draw visitors from well outside Norfolk due to its profile, status equivalent to a National Park, or the attractiveness of the location. That said, nearly 50% of visitors had travelled less than 6km from home with those travelling 2km or less forming the largest single group of visitors. Using only data from visitors travelling from home, the most frequent settlements where visitors came from to visit the Broads were (ranked highest first): Upton-Acle area, Norwich, Potter Heigham area and Horning area (Panter et al., 2016).

3.9. Across the Norfolk study area as a whole, ‘close to home’ was one of the main reasons people gave for choosing a particular site; however, in contrast to other areas of Norfolk, proximity to home was not the top ranking reason for visiting a particular site within the Broads, although it came second, after the free text response of ‘other’ (19.6% as opposed to 34.8%). These ‘other’ reasons often related to boating (private owners and those hiring) and wildlife events, such as to see swallowtail butterflies.

1 (S); Hickling Broad (N); Horning; How Hill; Ranworth; Strumpshaw Car Park; Upton Green

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3.10. Other visitor surveys in Norfolk were undertaken at several ‘honeypot’ sites in 2011 and these also appear to indicate that a large proportion of visitors to the area travel from the city of Norwich. Acle is within NR13 and three of these four honeypot sites (Strumpshaw, Ranworth and Hoveton) are within NR13: the data show that between 15-19% of visitors come from this postcode. No visitors from NR13 were recorded at Hickling. For comparison, data for the Norwich urban/suburban postcodes (including Thorpe St Andrew) of NR1-NR7 are shown: for all sites except Hickling the number of visitors from NR13 is higher than on average for individual city postcodes. When compared to the total numbers of visitors from the NR1-NR7 postcodes, almost twice as many visitors at Strumpshaw and Ranworth are from the city than NR13, and similar numbers are from the city as are from NR13 at Hoveton (Table 2, comparing columns 3 and 5). That is, the cumulative numbers from the city are often substantially larger than for visitors from smaller nearby villages.

Table 2. Summary of the visitor survey data by postcode, for the Acle postcode district (including Acle, Brundall, Reedham, Rackheath, Salhouse) and the total and individual numbers for the NR1-7 codes. Site Sample NR13 NR1 – NR7 postcodes size Number % Summed % Individual Individual of from number individual maximum minimum visitors NR13 of visitors mean Strumpshaw 116 19 16 37 5 16 1 Ranworth 198 30 15 59 4 10 1 Hickling 25 0 0 7 4 12 0 Hoveton 79 15 19 12 3 9 0

3.11. The reasons visitors go to different sites differ between sites. Generally, literature suggests dog walking and walking (without dogs) are key activities (Table 3) which is further borne out by the results of recent visitor surveys at Lammas Lands in Surrey, which showed that the primary purpose of the visit for 24% and 46% of respondents were for dog walking and walking respectively (Lake & Panter 2016), and at Berry Head, Devon whereby these figures were 41% and 31% respectively (Panter & Lake 2016). Dog walkers in particular use sites frequently, often daily and sometimes more than once a day (Sports Industry Research Centre, 2008). Again, this is borne out by the results of the Lammas Lands survey which showed that almost 63% of respondents visited daily to walk their dogs (Lake & Panter 2016).

Table 3. The main purposes of leisure visits to the Dorset Heaths, Thames Basin Heaths and the New Forest National Park (taken directly from Sharp et al., 2008). Purpose Dorset heaths (%) Thames Basin Heaths (%) New Forest (%) Dog walking 80 59 24 Walking 10 32 30 Jogging 2 4 0 Cycling 2 6 6

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Purpose Dorset heaths (%) Thames Basin Heaths (%) New Forest (%) Horse-riding 1 2 1 Other 5 10 39

3.12. Contrary to the above, however, Panter et al., (2016) suggest that the main reason for visiting The Broads specifically, was, in fact, wildlife watching/viewing scenery (29%), closely followed by boating activities (22%) and walking (21%). Tally counts at selected sites across the county suggested the proportion of visitors with dogs was particularly low at just 6% and that of these, the proportion kept on a lead was the highest of all sites surveyed at 86%. In terms of frequency of visits, the Broads interview data at virtually all of the Broads survey locations reflected a low proportion of daily visitors, this being regardless of the average distance travelled.

RESIDENTS AND VISITORS TO EAST NORFOLK 3.13. East Norfolk is a popular tourist destination, and for the popular tourist destinations of Norwich and Great Yarmouth, the visitor numbers are:

 Great Yarmouth, with 1.1 million staying visitors and 3.9 million day-visitors annually (Great Yarmouth Tourist Authority 2013).

 Norwich, with 430,000 staying tourists a year (Visit England, 2012).

3.14. The Broads itself is a large and very complex area, with numerous protected sites, honeypot tourist attractions including nature reserves, significant boating activity including a fleet of over 885 hire craft and private motor cruisers outnumbering these by approximately 7 to 1, these numbers increasing slightly between 2010 and 2015 (The Tourism Company 2016). When total boat movement figures in the 2014 Boat Census are compared to 2010 figures, it is evident that there has been slight increase in boat movements within the Broads river system on the census days with a total of 11,933 vessels noted by the end of play on the third day compared to 11,728 in 2010.

3.15. The 2014 census also shows that whilst there has been a drop in the number of hired motor cruisers recorded, there has been an increase in hired outboard dinghies and launches as well as smaller non-powered craft such as canoes and row boats, whose usage has increased by over 60% in the last four years.

3.16. Estimates of tourist numbers to The Broads and its immediate environs (the area “under the influence of The Broads”) are in the region of 6.9 million per annum of which 84% are day visitors (Broads Authority, 2011, p20). That said, it is well known

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generally that the numbers of holidaymakers varies from year-to-year, with, for example, 2016 showing declines compared to 2015 in the numbers of holidaymakers likely to stay in the UK and also book holidays at weather dependent destinations (BDRC, 2016). Numbers at specific sites from Visit England data:

 168k at BeWILDerwood, an adventure park for children with a national profile; accessible by road only (www.bewilderwood.co.uk) (Visit England 2012)

 33.5k at Fairhaven Garden Trust, ornamental gardens and garden centre; accessible by road only (www.fairhavengarden.co.uk) (Visit England 2016)

 27k at Toad Hall, a small cottage museum run by the Broads Authority and located on How Hill National Nature Reserve (Visit England 2016).

 28k at RPSB Strumpshaw, a flagship reserve accessible by car and rail (Visit England 2012).

 4k at RSPB Berney Marshes, a reserve with difficult road and rail access (Visit England 2012).

3.17. Compared to these numbers of visitors, the population sizes of the small villages and towns of the Broads area are low (Table 4).

Table 4. Summary of 2011 census data for Acle and local population centres (principally wards, unless stated). Smaller villages such as Ranworth or Ludham are included within wards named after other villages. Population centre Population size Acle 2,824 Flegburgh 2,424 Brundall 5,794 Hemsby 2,973 Caister (north and south combined) 9,066 Reedham 1,596 (2001 census) Blofield with South Walsham 5,609 Hoveton 1,942 Wroxham 5,081 Horning 259 (2001 census) Stalham with Sutton 4318 Catfield 499 (2001 census) Hickling 1869 (2001 census) Norwich 132k Great Yarmouth 97k Broadland DC 125k North Norfolk DC 101k

3.18. The majority of visitors interviewed as part of the 2015-2016 Norfolk visitor survey arrived at sites by car (77%), followed by those arriving on foot (18%) and those by boat (3%). Within the Broads area, the proportion arriving by car was even higher at c. 85% (Panter et al., 2016)

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4 AVAILABLE RECREATION RESOURCES LOCALLY

RADIUS OF EFFECTS 4.1. As a preliminary exploration of the distribution of recreation/walking routes around the site, it is considered that the initial scoping for sites should be a 6km radius from the proposed development site. This is based on:

 The small distances most visitors travel to sites from home (e.g. not on holiday), with many studies showing most visitors travel far less than 6km (see below for further details; this figure is refined later).

 The proximity of other towns, with 6km being roughly half the distances to Hoveton and a little less than half the distances to the large conurbations of Norwich and Great Yarmouth. This project is very small compared to these conurbations.

4.2. Within 6km of the development site the European sites are (Appendix 3: Figure 3):

 The Broads SAC, with all component sites listed in Appendix 2: Table 2 but with the component sites within 6km being Stalham Dyke and Marshes, Thurn SSSI; Damgate Marshes, Acle SSSI; Decoy Carr, Acle SSSI; SSSI; SSSI; Yare Broad and Marshes SSSI, Marshes, SSSI; and Burgh Common and Muckfleet Marshes SSSI.

 The Broads Ramsar site, as above.

 Broadland SPA, as above but excluding Damgate Marshes, Acle SSSI.

INTEGRAL MITIGATION 4.3. The project site is on the western edge of Acle. Acle itself has a population of 2824, and 1,285 households. With 140 additional dwellings, as proposed by this development, and an average occupation rate of 2.3 people per dwelling (based on 2011 Census) there will be an increase in the population by 11%, to 3146.

4.4. The project includes on-site and off-site public open space as an intrinsic component, i.e. mitigation. This comprises open space of 0.66ha and then play space of 0.36ha, both of which are within the development site boundaries. In addition, it includes 1ha of off-site land to be used as informal open space. This lies to the west of the development site within c. 50m.

4.5. At least some of the recreational activity of residents will be on-site; although this is difficult to quantify as many of the expected activities are likely to be similar to those

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undertaken in the wider countryside. From a review of activities by users of urban greenspace, Handley et al. (2003) list the following as important:  Going for a walk  Beach activities (e.g. swimming, paddling)  Walking a dog  Sailing, boating or power boating  Recreational cycling  Visiting an attraction  Bird/nature watching  Sightseeing  Picnicking

RECREATION AND NEARBY SITES 4.6. It must be assumed that a proportion of new residents of the Acle scheme will access off-site habitats not provided by the development for recreational purposes and that, given the proximity of the scheme to designated sites, that some of these will access on foot.

4.7. In assessing the significance of footpaths to the HRA, they could potentially act to reduce impacts, by facilitating access as alternative green space and essentially providing the green infrastructure required as mitigation, or increase impacts by facilitating access to sensitive sites.

4.8. It is recognised that residents will walk both with and without dogs off-site, and residents may walk or drive to recreation sites to do so. In understanding any impact on European sites there needs to be consideration of two functions:

 The availability of existing walking routes, and

 Whether walking routes affect European sites.

4.9. An extensive review and search was undertaken of published guides and websites promoting walking routes in Norfolk (see Appendix 2, Table 10). Seven routes widely promoted locally are identified as relevant. For simplicity the routes under the umbrella of Burlingham Woodland Walks as promoted locally (Norfolk County Council, undated; Appendix 3: Figure 6) are split into two portions: the much larger series of paths west of the site (hereafter Burlingham Woodland Walks (West)) and the eastern portion connecting to the Weaver’s Way (hereafter Roman and Damgate Walks). The nearby paths considered are therefore (see Appendix 3: Figure 5):

 Burlingham Woodland Walks (West),

 Roman and Damgate Woods Walks,

 Weaver’s Way Circular (North),

 Weaver’s Way Long Distance Path,

 Halvergate,

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 Upton Circular, and

 Burgh Common.

WALKING ROUTES NEAR SSSI (EUROPEAN SITES) Weaver’s Way 4.10. In the immediate vicinity (<2km) the Weaver’s Way is the only route that passes through or close to a SSSI, forming the boundary between Decoy Carr, Acle SSSI and Damgate Marshes, Acle SSSI. Small portions of the Roman and Damgate Walks run along the Weaver’s Way adjacent to Damgate Marshes, Acle SSSI. Both of these sites were specifically named by Natural England pre-planning consent (2014b) as being of concern in relation to any increase in visitors from this project.

4.11. While the Weaver’s Way is promoted very widely no data have been found on the current level of use. Examples of its promotions include the websites of: Long Distance Walkers Association2, Ramblefest3, GPS Cycle and Walking Routes4, Tour Norfolk5, Broadland District Council6, Norfolk County Council7, Enjoy the Broads8, among many others.

Roman and Damgate Woods Walks 4.12. This route is a small portion of the Burlingham Woodland Walks, as promoted by local organisations (e.g. Norfolk County Council, undated), but because it is on the other side of Acle to the project site it is treated separately. The portion of the Roman and Damgate Woods Walks which runs towards the Weaver’s Way does not pass near any SSSI and is separated by Damgate Lane and some residential housing. It is recognised that the Roman and Damgate Woods Walks forms a loop which may be attractive for residents wishing to undertake a brief walk and there are two factors reducing the attractiveness of this route as a circular walk :

 To access it requires walking through central Acle, and then

2 http://www.ldwa.org.uk/ldp/members/show_path.php?path_name=Weavers'+Way+(Norfolk) 3 http://www.ramblefest.com/locations/acle-accommodation/ 4 http://www.gps-routes.co.uk/routes/home.nsf/RoutesLinksWalks/weavers-way-walking-route 5 http://www.tournorfolk.co.uk/walking.html 6 https://www.broadland.gov.uk/downloads/download/42/cycling_and_walking 7 https://www.norfolk.gov.uk/out-and-about-in-norfolk/norfolk-trails 8 http://www.enjoythebroads.com/things-to-do/halvergate-marshes-and-weavers-way-0

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 The crossing of the A47 Acle Straights and the Old Road A1064, both of which are difficult to cross at peak times and at other times with a lot of fast traffic, with dogs needing to be on leads and children closely supervised.

4.13. As noted again later, the only part of this route near to a SSSI is the north section of the Weaver’s Way. As understood there is no public access directly onto Damgate Marshes, Acle SSSI. Access into Decoy Carr, Acle SSSI is difficult: a public footpath runs south from Damgate Lane to its north edge. There are no public paths inside or otherwise around the wood but it is understood there is potential informal access from this public footpath and from Carter’s Loke (a track some 50m south). The interior contains a lot of wet terrain and vegetation that is probably unappealing to casual visitors and dog walkers especially in winter.

Halvergate 4.14. This route is not shown on Appendix 3: Figure 5 but can be reached from Acle via the Weaver’s Way; however, to walk there requires a walk of >6km. It starts in Halvergate and travels east into SSSI. The routes from Halvergate receive some promotion in walking guides.

Upton Circular 4.15. This is not a defined and promoted route but can be accessed from Acle on foot after a journey of around 3km, passing along public footpaths and along the top of flood defence walls. Part of a possible circular route passes through Upton Broad and Marshes SSSI. These paths are served by car park in Upton and this is used by organised groups of walkers (GW Hopkins, pers obs).

Burgh Common 4.16. A series of footpaths go around Burgh Common and Muckfleet Marshes, but not through the Common. To reach these from Acle requires a journey on foot in excess of 7km on footpaths. This route is not apparently promoted for public use and is not shown on Appendix 3: Figure 5.

WALKS NOT NEAR SSSI Weaver’s Way Circular 4.17. This is an established path running as a circular route along part of the Weaver’s Way north-east of Acle alongside the Bure, then cutting on to the south (right) bank through marshland and then farmland back to Acle. As a circular walk this requires crossing the fast and busy A1064 Old Road at two locations. Although this route

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does not pass within any SSSI (at its nearest point it is some 900m from Upton Broads and Marshes SSSI) it does traverse habitat within The Broads National Park. Parts of the route are used for mooring pleasure craft on the banks of the and within a small marina, and as such is likely to be subject to an existing level of disturbance.

Burlingham Woodland Walks (West) 4.18. Burlingham Woodland Walks receive significant promotion locally, for example with an attractive colour brochure (Norfolk County Council, undated). The route includes a link directly passing the north of the site boundary then running west to connect with a small network of paths including several loops and circular walks. Part of this route including the section past the project site forms part of the orbital cycling route in the Broads (www.thebroadsbybike.org.uk). Adjacent to the west boundary of the project is a length of permissive footpath alongside a hedgerow, and this is to be retained by the project. The possible routes from this access point extend to nearly 21km with various short circuits and ‘loops’.

OTHER PUBLIC FOOTPATHS 4.19. Within the general area are a series of other footpaths across farmland outside of the Broads but they do not appear to connect to create potential walking paths for recreational use, as they frequently require travel along public roads. Within the Broads there are routes alongside the Bure on public footpaths, but these are apparently not promoted for public use.

REFINEMENT OF SCOPING-IN OF PATHS 4.20. The project includes some integral mitigation for potential recreation impacts, with public open space and play space. Adjacent to the site is an attractive walking and cycle route leading to a network of paths and circular walking routes, i.e. the Burlingham Woodland Walks (West) is considered to offer a significant amount of alternative recreation green space.

4.21. Walking routes locally (within the 6km radius) are listed below (Table 5) with those defined as ‘promoted’ being advertised or otherwise publicised in relevant literature or websites (see Appendix 2: Table 10).

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Table 5. Summary of nearby paths and walking routes. Path Promoted Location Description Relationship to for use SSSIs Burlingham Yes Adjacent to and A network of paths Not near Woodland west of project and circular walks Walks (West) site widely promoted. Up to 21km in use Roman and Yes East of the Acle Promoted as part of Part of route along Damgate conurbation the Burlingham Weaver’s Way Woods 900m east of Woodland Walks. which runs Walks. the site Forms a circular route adjacent to but requiring the Damgate crossing of two busy Marshes, Acle roads. Circular route of SSSI 3km Weaver’s Yes North of the Circular route Not near Way Circular project site, promoted locally, (North) approximately length of 6.5km 400m Weaver’s Yes East of Acle Long distance path, Runs adjacent to Way Long potentially over 50km Damgate Distance Marshes, Acle Path SSSI and Decoy Carr, Acle SSSI Halvergate Yes East of Acle, via Various routes Passes though Weaver’s Way including circular Halvergate options, approximately Marshes SSSI 10km but connecting to much longer footpaths Upton No North-west of Various routes Upton Broad and Circular Acle including circular Marshes SSSI options, 3-6km Burgh No North-east of Circular routes, 3- Burgh Common Common Acle 10km and Muckfleet Marshes SSSI

4.22. For the purposes of the HRA, the routes to be scoped-in are those readily accessible by foot from Acle, and requiring a walking journey of less than 2km to access. This is in excess of the distance travelled on foot by visitors to many sites as identified in the literature, where such detail was given, for example:

 Solent, 92% of foot visitors walked <2km to access sites; and

 Suffolk Sandlings, where 80% come from within <1km

4.23. Journeys longer than this are presumed to be by car and as so affected sites will also be within range of car visitors from conurbation Great Yarmouth, Norwich and to a lesser extent Hoveton/Wroxham.

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5 REFINED LIST OF SCOPED-IN SITES AND FOOTPATHS

SCOPED-IN SITES 5.1. Based on the radius of 2km, taken as the upper limit for which residents would walk to access site, the following European sites with their component SSSIs are scoped- in:

 The Broads SAC, with the component sites of Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI.

 The Broads Ramsar Site, with the component sites of Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI.

 Broadland SPA, with the single component site of Decoy Carr, Acle SSSI.

5.2. The lists of qualifying features for the European and Ramsar sites in the Broads are long and complex (Natural England 2014 c, d) but a simplified summary is provided below (Table 6).

Table 6. Summary of the distribution of qualifying features. Feature SPA SAC Ramsar Fen vegetation types   Aquatic vegetation   Woodland   Rare plants   Fen orchid   Rare invertebrates   Otter   Raptors    Waders    Wildfowl including swans    Bittern   

5.3. A data search commissioned from the Norfolk biodiversity Information Service (NBIS) in September 2017 identified seven species named as qualifying criteria in the Acle area (Table 7). Of these, harriers are most sensitive to disturbance while breeding and roosting, whereas Bewick’s and whooper swans are more susceptible whilst foraging. Otters are most sensitive to disturbance whilst rearing young but will be deterred from foraging and commuting habitat, particularly by human and companion animal activity. The two invertebrates (snails) species are of low sensitivity.

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Table 7. NBIS data search results for named species listed as qualifying features for The Broads SAC, Broads Ramsar site and Broadland SPA in the vicinity of Acle. Feature Site Location Ecology Sensitivity to disturbance Otter Lutra Broads Acle, A47, Moderate size Low-moderate, mostly lutra SAC Acle mammal, feeding nocturnal but likely to be Broads Bridge, on fish in ditches, able to find quiet areas for Ramsar rivers and lakes breeding irrespective of site numbers of visitors on footpaths Marsh harrier Broads Acle, Raptor requiring High, adults deterred by Circus Ramsar without open marshland, walkers. Presence at roost aeruginosus site additional often nesting in sites from dusk onwards, Broadland detail reedbeds typically in wetter, less SPA accessible areas. Hen harrier Broads Acle, Non-breeding High, adults deterred by Circus Ramsar without presence in the walkers; however, species cyaneus site additional lowlands only. does not nest in lowlands Broadland detail Ground roosting, and only mechanism for SPA often communally impact is the indirect effects and with other of residents away from harrier species. development. Presence at roost sites from dusk onwards, typically in wetter, less accessible areas. Bewick’s Broads Acle, Non-breeding High within foraging swan Ramsar without presence in grounds. Deterred by Cygnus site additional England only. walkers. bewickii Broadland detail Feed in fields and SPA grassland. Whooper Broads Non-breeding High within foraging swan Ramsar presence in grounds. Deterred by Cygnus site England only. walkers. cygnus Broadland Feed in fields and SPA grassland. Desmoulin’s Broads Decoy Small snail found Low, habitat unlikely to be whorl snail SAC Carr, Acle in permanently attractive to walkers Vertigo Broads SSSI wet and often tall moulinsiana Ramsar fen vegetation site Little whirpool Broads Damgate Small snail found Low, habitat unlikely to be snail SAC Marshes, in ditches attractive to walkers ramshorn Broads Acle SSSI Anisus Ramsar vorticulus site

5.4. Only two records of marsh harrier were returned, which at least suggests they are scarce locally compared to other sites such as Buckenham and Buckenham Marshes with 60 records of marsh harrier. Marsh harriers are now considered to be a fairly common resident, summer visitor and passage migrant and ‘increasingly common throughout’ Norfolk and as overwintering continental birds (NNNS, 2014). The typical nesting habitats for marsh harriers are reedbeds and other tall fen vegetation. Gamauf and Preleuthner (1996), working in Austria, showed that although marsh harriers tended to nest in areas with little disturbance, the foraging adults were

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vulnerable to disturbance and avoided busy footpaths and cycle ways to a distance of 120m either side; they attribute recreational disturbance as having an impact on the provision of food to nestlings. Fernandez and Azkona (1993), working in Spain, reported foraging birds were possibly disturbed at up to distances of 500m, and although fledgling success was not affected by disturbance the nutritional condition of young birds was less in disturbed sites.

5.5. Winter communal harrier roosts can be found at a small number of traditionally used locations across southern England. The key roost site in the Broadland area can be viewed from the ’s Hickling Broad, were viewing facilities are provided at a safe distance from the roost location. Harriers of both species (marsh and hen) will arrive around dusk and roost on the ground, typically within wetter areas that may provide a deterrent to mammalian predators. Such traditionally used roosts are also invariably present in undisturbed locations with little or no public access.

5.6. The likelihood that a very small percentage increase in Broadland residents, within a development that contains a provision of green infrastructure, would result in harrier roosts being disturbed has been excluded. For disturbance to occur, residents would have to travel to a harrier roost before trespassing after dark in very difficult terrain.

5.7. Five separate counts of Bewick’s swan were returned from the data search within the Acle area. This is, by comparison, very low, when compared to other areas locally, for example, St Benet’s Abbey (54) and Halvergate (29) and, in addition, numbers of birds within each count or flock were generally much lower (median count of 50 ranging from 10 to 143. The levels around St Benet’s Abbey appear to be of significance locally for Bewick’s swan with a peak count as high as 734 (median value 120 ranging from 4 – 734).

5.8. Two separate counts of whooper swan were returned from the data search within the Acle area, one comprising a single bird and the other of two individuals only. As above, this is low in comparison with other sites such as St Benet’s Abbey (15 counts) and Cantley (10). Numbers of this species within a count are lower than for Bewick’s swan with a peak count of 155 at St Benet’s Abbey on one occasion but more typically under 30.

5.9. Bewick’s and whooper swans typically winter on shallow freshwater lakes and marshes near or adjacent to extensive grasslands liable to flooding. Over the last 50

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years or so the incidence of agricultural land being used for foraging by large numbers has increased with birds feeding on waste root crops, grain stubbles and winter cereals. It is considered that the terrain away from the existing footpath network is unlikely to be particularly attractive to visitors given that it is either low- lying grassland, liable to flooding, or intensively managed agricultural land with limited public access and thus, impacts through disturbance is likely to be low.

5.10. The likelihood that a very small percentage increase in Broadland residents, within a development that contains a provision of green infrastructure, would result in swan foraging grounds being disturbed has been excluded. For significant disturbance to occur, residents would have to travel to areas outside Acle in numbers and venture off footpaths onto wet ground or managed arable fields.

5.11. Eight records of otter were returned from the Acle area, far fewer than other sites in the search radius such as South Walsham Broad with nearer 75 but comparable with and Strumpshaw. Although otters are sensitive to disturbance, particularly pregnant females, it is considered that provided sufficient quiet places are available to construct holts then the population impact of disturbance will be low (Jefferies, 1987).

5.12. Data on vegetation types, specifically Annex I habitats, was not available from NBIS, but based on Doarkes (1995) it is understood that Decoy Carr, Acle SSSI supports one type of such habitat, namely:

 Calcareous fens with Cladium mariscus and species of the Caricion davallianae.

5.13. Saw sedge Cladium mariscus forms tall dense stands with the fronds having sharp edges capable of cutting skin, and as such it is unpleasant to walk through and unlikely to be used by visitors. That is, it is at low risk of trampling damage.

SCOPED-IN FOOTPATHS 5.14. Two promoted paths within this 2km radius pass through or near European sites, namely:

 Roman and Damgate Woods Walks, and

 Weaver’s Way Long Distance Path.

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5.15. Two other promoted paths within 2km do not pass near European sites (although Weaver’s Way Circular (North) does pass through grazing marsh along with other paths around Upton), namely:

 Burlingham Woodland Walks (west), and

 Weaver’s Way Circular (north).

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6 STAGE 1: TESTS OF LIKELY SIGNIFICANT EFFECTS

KEY FEATURES 6.1. This HRA considers the potential increase in visitor numbers and recreation pressure on European sites resulting from an increased number of residents living in Acle resulting from the proposed project (development).

6.2. Key points are the project’s small size in absolute terms (with a projected 322 residents) and then relative terms (to the conurbations of Great Yarmouth, Norwich and to a lesser extent Hoveton/Wroxham) as well as the provision of on and off-site open space. The distance visitors travelling from home may travel is considered to be less than 2km, based explicitly on this figure being the upper limit to which residents would be expected to walk to access sites for recreation. Above this distance residents would be expected to mostly drive and as such the increase at sites would be expected to be minor compared to the numbers from Norwich and Great Yarmouth. As noted earlier, the total numbers of visitors form Norwich (NR1-7) can often be at least double the numbers locally (NR13).

6.3. Within this distance the walking routes of relevance to European sites are:

 East of Acle south of the A47, using the Weaver’s Way or part of the Weaver’s Way to create a circular walk (via Roman and Damgate Woods). Both of these routes are considered to be used by only small numbers of visitors from the project site, as it would require: (i) a walk of approximately 900m to access the walking route, passing through the Acle conurbation, and also (ii) traversing two busy roads (A47 Acle Straights and the A1064 Old Road), neither of which could be crossed with dogs ‘on the loose’ or unsupervised children. The sections of the circular route not on the Weaver’s Way do not pass though or within 250m of Decoy Carr, Acle SSSI.

6.4. Specifically in the case of Damgate Marshes, Acle SSSI, it is not within the Broadland SPA, and as such is not designated for birds. Although it is recognised that birds of relevance to the Broadland SPA may use the site it is considered likely that it is of lower relevance as it is the only SSSI in the Broads that is not a component site of the SPA. As it is of lower importance for birds it can be considered that the significance of disturbance on this site is lower with respect to walkers on the Weaver’s Way. Neither Damgate Marshes, Acle SSSI nor Decoy Carr, Acle SSSI have public footpaths.

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6.5. Conversely, the walking route adjacent to the site is heavily promoted as a community resource (Norfolk County Council, undated; Appendix 3: Figure 6) and does not pass near to any European sites but has some significant features to make it attractive for residents:

 It connects directly with the North Burlingham Woodland Walks, leading to 21km of paths mostly off-road or on quiet roads or crossing quiet roads (with the exception of a small section running to Lingwood and crossing the A47), with varied circular routes.

 It can be accessed directly from the development site and the 1ha area of off- site open space sits directly to the north and south of two footpaths and/or bridleways linking the development site with the woodland walks.

6.6. The Weaver’s Way North route is circular but does not pass within or near a European site. That said, marsh harriers and Bewick’s swans frequently nest or forage respectively outside of the boundaries of the designated sites, but the paucity and distribution of records returned from the NBIS data search suggests that they are not frequent locally or at least the area is not particularly important for the species. Further, parts of the route are used for mooring by pleasure craft on the banks of the River Bure and within a small marina, and as such is likely to be subject to a significant amount of disturbance already.

CONCLUSION 6.7. It is concluded that the proposed project will not result in more than very low numbers of additional visitors to European sites or their component SSSIs of Damgate marshes, Acle SSSI and Decoy Carr, Acle SSSI. Any increase in visitors is likely to be at most minor and not apparent within the variation from visitors from other sources, such as larger nearby conurbations and tourists, or day-to-day differences driven by weather (cf Temple et al., 2011).

6.8. Of the walking routes east of Acle most likely to be used by visitors (notwithstanding the comments regarding their lower attractiveness for walkers), the route which lies near a component SSSIs is part of the larger Weaver’s Way and also only passes the Damgate Marshes, Acle SSSI which is not a component of the Broadland SPA. That is, it passes a site of lower value for birds and as such is of lower sensitivity to disturbance from passing walkers.

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6.9. It is therefore considered that there is sufficient confidence to conclude that the presence of 322 new residents to the west of Acle, within the completed project, will not result in more than relatively and absolutely minor increases in the numbers of visitors and therefore negligible recreational disturbance to The Broads SAC, Broads Ramsar site and the Broadland SPA and/or their individual component sites. There is sufficient confidence to conclude that there will be no impact on site integrity. As such an Appropriate Assessment is not required.

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7 IN-COMBINATION EFFECTS

7.1. Given that the expected increase in numbers at Damgate Marshes, Acle SSSI and Decoy Carr, Acle SSSI is expected to be very low, it is considered that in- combination effects will not occur. This is not to say that other projects may not cause increases in the numbers of visitors, but in such instances those increases would not be as a result of in-combination effects with this scheme. At more distant sites to where visitors may drive, the numbers arriving as a result of this project are expected to be trivial when compared to the numbers arriving from schemes such as urban extensions to Norwich, which in many instances will be at similar driving distances and times.

7.2. As such it is consider that no in-combination effects involving to this project will result, and as such it is concluded that an in-combination Appropriate Assessment is not required.

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REFERENCES

BDRC Continental (2016) Holiday Trends 2016. Available from: https://coastaltourismacademy.co.uk/uploads/BDRC_UK-Holiday-Trends-2016-FV- NXPowerLite-Copy1.pdf

Broads Authority (2006) Appropriate Assessment of the Core Strategy - Submission Report. Under the Conservation (Natural Habitats, &C) (Amendment) (England and Wales) Regulations 2006. September 2006. Available from: http://www.broads- authority.gov.uk/authority/consultations/core-strategy/submission-core-strategy-dpd- consultation.html

Broads Authority (2014) Broads Boat Census. Broads Authority, Norwich.

Broads Authority (2011) A Strategy and Action Plan for Sustainable Tourism in the Broads 2011 – 2015. Broads Authority, Norwich.

Cruickshanks, K., Liley, D. & Hoskin, R. (2010) Suffolk Sandlings Visitor Survey Report. Footprint Ecology, Dorset.

Doarkes, C. (1995) Fen Mangement Strategy. English Nature, Norwich.

Fearnley, H. (2011) Results of On-site Visitor Survey Work at Brookwood Country Park, Woking. Footprint Ecology, Dorset.

Fearnley, H. and Liley, D. (2013) 2012/13 Vsitor survey on the Thames Basin Heaths Special Protection Area (SPA). Natural England Commissioned Reports, Number 136. Footprint Ecology, Dorset.

Fernandez, C. and Azkona, P. (1993) Human disturbance affects parental care of marsh harriers and nutritional status of nestlings. The Journal of Wildlife Management 57, 602- 607.

Gamauf, A. and Preleuthner, M. (1996) Influence of tourism on the Marsh Harrier (Circus aeruginosus) in the "National Park Neusiedlersee-Seewinkel" (Austria). Abhandlungen der Zoologisch-Botanischen Gesellschaft in Österreich 29, 173-193 (English abstract)

Great Yarmouth Tourist Authority (2013) Great Yarmouth Tourism Strategy 2013-2018 Available from: http://www.great-yarmouth.gov.uk/CHttpHandler.ashx?id=980&p=0

Handley, J., Pauleit, S., Slinn, P., Barber, A., Baker, B., Jones, C. & Lindley, S. (2003) English Nature Research Reports. Number 526. Accessible Natural Green Space Standards in Towns and Cities: A Review and Toolkit for their Implementation. English Nature, Peterborough.

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Jefferies, D.J. (1987) The effects of angling interests on otters, with particular reference to disturbance. In Angling and Widlife in Freshwaters, P.S. Maitland and A.L. Turner (eds) pp 23-30. Institute of Terrestrial Ecology, Edinburgh.

Lake, S. & Panter, C. (2016) Lammas Lands Visitor Survey 2016. Footprint Ecology, Dorset.

Liley, D., Jackson, D.B. & Underhill-Day, J.C. (2006) Visitor Access Patterns on the Thames Basin Heaths. English Nature, Peterborough.

Liley, D., Hoskin, R., Lake, S. and Underhill-Day, J. (2009) Habitats Regulations Assessment of the Great Yarmouth Core Strategy. Footprint Ecology, Dorset.

Natural England (2014a) Letter Regarding: Publication of Site Allocation Development Plan Document (DPD) and Development management – Proposed Submission (Reg 19) Versions. 30 May 2014. Natural England, unpublished letter.

Natural England (2014b) Letter Regarding: Planning consultation: Residential Development of up to 140 Dwellings and Associated Works (Outline).15 August 2014. Natural England, unpublished letter.

Natural England (2014c) European Site Conservation Objectives for Broadland Special Protection Area Site Code: UK9009253. Available from: http://publications.naturalengland.org.uk/file/6019037926522880.

Natural England (2014d) European Site Conservation Objectives for The Broads SAC (UK0013577). Available from: http://publications.naturalengland.org.uk/publication/6190476679970816

NNNS (2014) Bird and Mammal Report 2013. Norfolk and Norwich Naturalists’ Society, Norwich.

Norfolk County Council (undated) Burlingham Woodland Walks. Available from: https://www.norfolk.gov.uk/out-and-about-in-norfolk/norfolk-trails

Norfolk County Council (2014) HRA of Development Management Policies Document. For Broadland DC. March 2014. Proposed Submission Stage. Norfolk County Council, Norwich.

Panter, C. & Lake, S. (2016) Berry Head Visitor Survey Summer 2016. Foorprint Ecology, Dorset.

Panter, C., Liley, D. & Lowen, S. (2016) Visitor surveys at European protected sites across Norfolk in 2015 and 2016.

Sharp, J., Lowen, J. and Liley, D. (2008) Changing Patterns of Visitor Numbers within the

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New Forest National Park, with Particular Reference to the New Forest SPA. Footprint Ecology, Dorset.

Sports Industry Research Centre (2008) Assessment of Perceptions, Behaviours and Understanding of Walkers with Dogs in the Countryside. Sports Industry Research Centre, Sheffield.

Temple, V., Rhodes, R. and Higgins, J.W. (2011) Unleashing physical activity: an observational study of park use, dog walking and physical activity. Journal of Physical Activity and Health, 8, 766 -774.

The Ecology Consultancy (2014) Land North of Norwich Road, Acle, Habitats Regulations Assessment. Report to NPS.

The Tourism Company (2016) Sustainable Tourism in the Broads 2016 – 2020: A Tourism Strategy and Destination Management Plan for the Broads National Park DRAFT. Jan 2016.

Visit England (2011) Annual Survey of Visits to Visitor Attractions. Available from: http://www.visitengland.org/insight-statistics/major-tourism- surveys/attractions/Annual_Survey/index.aspx

Visit England (2012) Top Towns 2011. Available from: http://www.visitengland.org/Images/Top%20Towns%202011_tcm30-33056.pdf

Visit England (2016) Annual Survey of Visits to Visitor Attractions: Latest results https://www.visitbritain.org/annual-survey-visits-visitor-attractions-latest-results

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APPENDIX 1: LEGISLATION AND PROCESS

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Within the Conservation (Natural Habitats &c.) Regulations 1994, Regulation 61(5) states that ‘In the light of the conclusions of the assessment, and subject to regulation 62 (considerations of overriding public interest), the competent authority may agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the European site or the European offshore marine site (as the case may be)’. Regulation 61(6) also states ‘In considering whether a plan or project will adversely affect the integrity of the site, the authority must have regard to the manner in which it is proposed to be carried out or to any conditions or restrictions subject to which they propose that the consent, permission or other authorisation should be given.’

The Habitats Regulations Assessment relates to Special Protection Areas (SPAs), Special Areas of Conservation (SAC) and Ramsar Sites. SPAs are sites classified in accordance with Article 4 of the EC Directive on the conservation of wild birds (79/409/EEC), more commonly known as the Birds Directive. They are classified for rare and vulnerable birds, listed in Annex I to the Birds Directive, and for regularly occurring migratory species.

SACs are classified in accordance with EC Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). Article 3 of this Directive requires the establishment of a European network of important high-quality conservation sites that will make a significant contribution to conserving the 189 habitat types and 788 species identified in Annexes I and II of the Directive.

These sites are known as the Natura 2000 network and are commonly referred to as European sites. Ramsar Sites are qualifying under the International Convention on Wetlands of International Importance especially as Waterfowl Habitat (the Ramsar Convention, Iran 1971 and amended by the Paris Protocol 1992). Although Ramsar Sites are not protected in law by the Birds and Habitats Directives as a matter of policy, government – reiterated in the National Planning Policy Framework (DfCLG, 2012) has decreed that, unless otherwise specified, procedures relating to SPAs and SACs will also apply to Ramsar Sites. The term ‘international sites’ is used in this report to refer to all three of these qualifying sites.

An appropriate assessment is a decision by a 'competent authority', in this case Broadland District Council, as to whether the proposed plan or project can be determined as not having an adverse effect on the integrity of any European sites. An

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adverse effect on integrity is likely to be one that prevents the site from maintaining the same contribution to favourable status for the relevant feature(s), as it did when the site was qualifying. Only where a plan or project can be determined by the competent authority as not having an adverse effect on site integrity can it be allowed to proceed.

The favourable conservation status of the site is defined through the site's conservation objectives and it is against these objectives that the effects of the plan or project must be assessed. Regulation 61(2) requires that a person applying for any such consent, permission or other authorisation must provide such information as the competent authority may reasonably require for the purposes of the assessment or to enable them to determine whether an appropriate assessment is required.

PROCESS The Appropriate Assessment process is outlined in Table 8, presented for illustrative purposes, outlining the steps required to be undertaken by the competent authority when considering projects that may impact on European sites.

Table 8. The stages of the Appropriate Assessment. Task Requirements Evidence Collation of documentation relating to the project. Gathering Collecting information on relevant European sites, their conservation objectives and characteristics. Stage 1 The ‘test of likely significant effect’. Establishing whether a plan is ‘likely to have a significant effect’ on a European site, and therefore requiring the Appropriate Assessment. Stage 2 Assessment of whether there is an effect on site integrity. This is potentially a two-stage process, with a consideration of whether there are likely to be effects, followed if necessary by a detailed consideration of site-specific factors. Stage 3 If there is an effect on site integrity then the project should be re- assessed with the inclusion of compensation and a repeat of stage 2.

An important part of this HRA is the significance of mitigation and compensation; these are defined below (Mitigation Versus Compensatory Measures). Following Tyldesley (2011) it is considered that compensatory measures may be proposed if the project is permitted under the provisions of regulations 49 and 53, but rather than forming part of the Appropriate Assessment they are included in Stage 3; in contrast, mitigation measures may form part of the Appropriate Assessment (i.e Stage 2).

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SITE INTEGRITY Following English Nature (2004) and based on definitions within Article 1 of the Habitats Directive, site integrity is defined below.

For habitats:  Their range and area must be stable or increasing;  The species structure and functions necessary for long-term maintenance exist and are likely to continue to exist for the foreseeable future; and  The status of the typical species is considered to be favourable.

For species:  The population dynamics data on the species indicate that it is maintaining itself on a long-term basis as a viable component of its natural habitats; and  The natural range is stable and likely to continue to be, and there is and will probably continue to be a sufficiently large habitat to maintain its population on a long term basis.

English Nature (19999, 200410) proposes a checklist of questions as a pragmatic approach to identifying likely effects and to potential mechanisms that may affect site integrity. Where each answer is ‘yes’, then it can be concluded that there are no adverse effects. Thus, for the assessment to conclude that there are no adverse effects then it is required to show that:  The area of Annex I habitats (or composite features) will not be reduced;  There will be no direct effect on the population of the species for which the site was Qualifying or classified;  There will be no indirect effects on the populations of species for which the site was Qualifying or classified due to loss or degradation of their habitat (quantity/quality);  There will be no changes to the composition of the habitats for which the site was Qualifying (e.g. reduction in species structure, abundance or diversity that comprises the habitat over time); and  That there will be no interruption or degradation of the physical, chemical or biological processes that support habitats and species for which the site was Qualifying or classified.

9 English Nature (1999) Habitats Regulations Guidance Note. English Nature, Peterborough. 10 English Nature (1999) Habitats Regulations Guidance Note. English Nature, Peterborough.

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If the answer is ‘no’ to any of these or if there is uncertainty, then it is necessary to consider further site-specific factors in order to reach a decision.

As presented by English Nature (2004), the key site-specific factors that need to be considered when forming judgments on site integrity are:  Scale of impact,  Long term effects and sustainability,  Duration of impact and recovery/reversibility,  Dynamic systems,  Conflicting feature requirements,  Off-site impacts, and  Uncertainty in cause and effect relationships and a precautionary approach.

MITIGATION VERSUS COMPENSATORY MEASURES There are three types of counteracting measures to reduce impacts: avoidance and reduction (which are grouped together as mitigation) and then compensatory measures. “Mitigation (avoidance and reduction) measures (are) built into the project and form(ing) part of the project as proposed or applied for”; compensatory measures are those which “do not already form part of the project but may be applied as additional conditions or restrictions (Tyldesley, 201111; pp13)

The distinction is:

 Mitigation measures are those measures which aim to minimise, or even cancel, the negative impacts on a site that are likely to arise as a result of the implementation of a plan or project. These measures are an integral part of the specifications of a plan or project (see section 4.5 of the leaflet "Managing Natura 2000 sites. The provisions of Article 6 of the Habitats Directive"), and

 Compensatory measures in the strict sense are independent of the project (including any associated mitigation measures). They are intended to offset the negative effects of the plan or project so that the overall ecological coherence of the Natura 2000 Network is maintained.”

11 Tyldesley, D. (2011) Assessing projects under the Habitats Directive: Guidance for Competent Authorities. Report to the Countryside Council for Wales, Bangor.

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APPENDIX 2: BACKGROUND INFORMATION

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Table 9. Component SSSIs of The Broads SAC, The Broads Ramsar site and Broadland SPA. SSSI Component Natural England Citation of SAC/SPA Alderfen SPA/SAC Classic succession from open water to carr woodland. Broad Nesting environment for a range of breeding birds. Several species of water plant. Ant Broads SPA/SAC Flood plain supporting extensive undeveloped, unpolluted and primary fen. Nationally important carr woodland and only Marshes known site for several plant communities. Wide range of breeding birds and wintering wildfowl. Nationally important assemblage of fenland invertebrates. Barnby SPA/SAC Open water, carr woodland, fen, grazing marsh and dykes. Broad and Threatened communities confined to Norfolk and Suffolk. Marshes Outstanding assemblages of rare plants, birds and invertebrates. Broad Fen, SPA/SAC Fen, fen meadow, carr woodland and open water. Species Dilham rich vegetation as a result of regular cutting of reeds. Range of breeding and wintering bird species. Bure SPA/SAC Wetland site of national and international importance. Broads Excellent example of unreclaimed marshland, supporting a and range of typical Broadland plant communities, including Marshes probably the finest example of swamp alder carr in Britain. Diverse and rare plants due to regular cutting for reed, sedge and marsh hay. Restoration efforts have succeeded in returning water plants to the broad. Supports rare marshland birds and relict fen invertebrates. Burgh SPA/SAC Important unreclaimed wetland, managed by traditional Common mowing and grazing regimes. Wide range of floristically rich and habitats present including fen meadows. Site is also of Muckfleet entomological and ontological interest. Marshes Calthorpe SPA/SAC Small, isolated broad having a low nutrient input and Broad retaining a diverse and productive aquatic flora and fauna. Cantley SPA/SAC Primarily an improved grazing marsh, with areas of species Marshes rich grassland and fen meadow. A range of soil types supports a range of plant communities, dykes support a rich and diverse aquatic flora and fauna, including two nationally rare dragonflies. Marshes support an internationally important population of wintering widgeon, and nationally important populations of other wintering and breeding bird species. Crostwick SPA/SAC Excellent example of unimproved valley meadow, supporting Marsh a range of plant communities and marshland bird species. Damgate SAC One of the richest areas of traditionally manages grazing Marshes, marsh and dykes in Broadland. The relatively nutrient poor Acle dykes support a rich aquatic flora and fauna, including several uncommon species. Decoy SPA/SAC Wetland community characteristic of the region. Rare Arctic- Carr, Acle alpine mosses indicative of plant communities being undisturbed since post-glacial times. Sedge and reedbeds support uncommon fenland flora, and dyke networks support a range of aquatic plants. Ducan’s SPA/SAC Species rich fen and grassland communities maintained by Marsh, traditional management support many notable plant species. Claxton

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SSSI Component Natural England Citation of SAC/SPA Geldeston SPA/SAC A diverse flora resulting from traditional management, Meadows graduated water table and range of soil types. System of drainage dykes supports a diverse aquatic flora. Site supports typical grazing-march bird species. Hall Farm SPA/SAC Unimproved fen grassland with system of dykes. Supports Fen, plant communities favouring both acidic and calcareous Hemsby conditions, resulting in high plant diversity. Dykes support a range of aquatic flora and fauna, including a nationally rare species of water snail. Halvergate SPA/SAC The largest expanse of traditionally grazed marshes in Marshes Broadland. A diverse habitat including well-developed woodland, unimproved pasture, wet fen meadow, reedbed and alder carr. Ditches represent a wide range of water conditions with associated diverse aquatic flora and fauna, including outstanding invertebrate assemblages. Site supports populations of nationally and internationally important wintering waterfowl. Hardley SPA Area of shallow lagoons and reedbeds with exposed soft Flood muds at low tide. Reedbeds support nesting nationally important wildfowl and soft muds attract a range of wading birds. Three rare species of fly have been recorded at the site. Limpenhoe SPA/SAC Large area of unimproved fen grassland with dykes. Meadows Maintained by summer grazing, the fen grassland is exceptionally diverse due to emerging springs. Dyke network supports a range of emergent and aquatic plants, including nationally rare and local species. Ludham- SPA/SAC One of the richest areas of grazing marsh remaining in Potter Broadland. Drainage dykes are of particular importance, Heigham supporting several rare aquatic plants and a rich invertebrate Marshes assemblage. Poplar SPA/SAC Small, spring-fed calcareous fen, with exceptionally diverse Farm meadows. Dykes contain clear spring waters and support a Meadows, rich aquatic flora. Langley Priory SPA/SAC An area of permanent grassland on damp, acidic peat. Meadows, Traditional annual hay-cut maintains an exceptionally rich Hickling and varied flora. Acidic plant communities are rare in Broadland. Drainage dykes support a rich aquatic flora. Shallam SPA/SAC Area of semi-improved pasture. Tussocky, undisturbed Dyke grassland provides a habitat for several nesting wetland Marshes, birds. Site is considered the most important area of grazing Thurne march for waders in Broadland. Clearwater drainage dykes support a diverse aquatic flora. Smallburgh SPA/SAC Small, spring-fed valley fen of exceptional ecological interest. Fen Diverse plant community including a number of rare and local species. Sprat's SPA/SAC Spring-fed mixed fen, open water, alder carr and grazing Water and marsh. Fen community typical of Broadland. Rich floral Marshes, diversity due to high summer water levels, seasonal grazing Carlton and reed cutting. Area also has high ornithological interest. Colville

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SSSI Component Natural England Citation of SAC/SPA Stanley SPA/SAC The only extensive area of regularly flooded alder carr and and Alder fen in the Waveney Valley. Site acts as a ‘wash’ in periods of Carrs, high river flow and supports a range of plants characteristic Aldeby to Broadland. Site has a rich invertebrate fauna and breeding bird community, and part of the site is Qualifying as a conservation area for otters. Trinity SAC A series of five shallow inter-connected lakes with fringing Broads reedswamp, wet woodland and fen. Isolation from the main River Bure allows to sustain a superior water quality and associated aquatic floral diversity. It is one of the few systems clear enough to sustain a charophyte flora. Open water areas support nationally important populations of breeding and wintering wildfowl. The site also supports a rich invertebrate diversity, and otters are regularly recorded here. Upper SPA/SAC The site comprises open water, woodland, grazing marsh, Thurne marginal swamp and fen and is one of the best examples of Broads an unreclaimed wetland complex in Britain. Associated and broads and marshes support flora and fauna of national Marshes importance. The site includes two of only four broads which have not suffered significant deterioration in water quality and offers an important site for research into the history and conservation of the Norfolk Broads. Upton SPA/SAC One of only four broads that retain clear water and abundant Broad and water plants, due to an isolated position preventing nutrient Marshes enrichment and recreational over-use. Clear waters support nationally rare water plants. Site has a rich invertebrate assemblage and supports grass snakes and harriers. Yare SPA/SAC Nationally important wetland site consisting of extensive Broads unreclaimed fen, carr woodland, open water and grazing fen. and Site supports high botanical and ornithological diversity Marshes

Table 10. Summary of promoted or advertised walking and cycling routes in the vicinity of the scoped-in area. Source Summary Access from the project 50 Walks in Norfolk One relevant walk, starting in the Nearby, requiring a short (<5 by Riffenburgh and centre of Acle minute) walk form the Cruwys (2008) Five other walks identified in The project to the nominated Broads. start point A Boot Up the Only 1 walk within 6km, at St Benet’s Requiring a car trip of 13km Norfolk Broads by Abbey. This walk goes through (22 minutes), using the Acle Rothe (2011) marshland alongside the Rivers Ant Bridge over the River Bure and Bure for much of its 2.2mile length Norfolk. A Dog 3 walks listed in The Broads, none Requiring a car trip of 7.1km Walker’s Guide by near within 6km (12 minutes) Youngman (2014) 20 walks listed across Norfolk Norfolk Walks by 1 walk within 2km starting close to Requiring a car trip of 7.1km Kelsall and Kelsall the edge of the 6km radius in (12 minutes) (2013) Halvergate and runs eastwards through Halvergate Marshes SSSI and along Breydon Water SSSI Two other walks in The Broads and 28 in total in Norfolk

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Source Summary Access from the project Walking In Norfolk, One route within 6km following a website circular route through north Acle and then along the south bank of the River Bure towards Upton and then back across farmland Second route from Halvergate village following a circular route through marshland but not as far as Breydon Water SSSI 70 routes in Norwich and the Broads North Burlingham Various routes connecting woodland Community parcels east of North Burlingham but Woodland, with one path adjacent to the site promoted by running west Norfolk County Council (undated a) Weaver’s Way long Runs north-south to the east of Acle. Accessible only on foot from distance path, This is a long distance footpath Acle, this does require the promoted by through the Broads, accessible crossing of the ‘Old Road’ Norfolk Country A1064, which can be Council (undated b) difficult at busy times. and several other organsiation Broads by Bike, The path along the north of the site is website on the ‘Broads Orbital Route’, using bridleways as with the North Burlingham waslks. Griffmonsters Great Approximately twelve walks in the Walks (undated) Broads Over 60 walks listed throughout Norfolk Broads by Bike website (undated) Available from http://www.thebroadsbybike.org.uk/ Griffmonsters Great Walks (undated) Available from: http://griffmonster- walks.blogspot.co.uk/ Kelsall, D. and Kelsall, J. (2013) Norfolk Walks. Crimson Publishing, London. Norfolk County Council (undated a) Burlingham Woodland Walks. Available from: https://www.norfolk.gov.uk/out-and-about-in-norfolk/norfolk-trails Norfolk County Council (undated b) Weaver’s Way. Available from: https://www.norfolk.gov.uk/out-and-about-in-norfolk/norfolk-trails Riffenburgh, B. and Cruwys, L. (2008) 50 Walks in Norfolk. AA, Hampshire. Rothe, T. (2011) The Norfolk Broads. Book One. PiXZ Books, Somersset. Youngman, A. (2014) Norfolk A Dog Walker's Guide. Countryside Books, Berkshire.

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APPENDIX 3: FIGURES

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Figure 1. Red line boundary of site

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Figure 2. Location of additional off-site green space (in yellow). The development site lies to the east on the outskirts of Acle town

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Figure 3. Designated sites within 6km of site

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Figure 4. Radii at 2km intervals around the site with SSSIs.

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Figure 5. Walking routes around Acle as named in text (within 2km).

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Figure 6. Example of promotional activity for the Burlingham Woodland Walks, including Roman and Damgate Walks (see text).

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