Coggeshall Neighbourhood Plan HRA Final

Coggeshall Neighbourhood Plan

Regulation 14 Submission

Habitats Regulations Assessment

Coggeshall Neighbourhood Plan Group

Project number: 60571087

June 2019

Coggeshall Neighbourhood Plan HRA Coggeshall Neighbourhood Plan Group

Project number: 60571087

Quality information

Prepared by Checked by Verified by Approved by

Amelia Kent James Riley James Riley Consultant Ecologist Technical Director Technical Director ACIEEM MCIEEM CEnv MCIEEM CEnv

Revision History

Revision Revision date Details Authorized Name Position 0 12/06/19 Draft JR James Riley Technical Director

1 10/07/19 Updates based on JR James Riley Technical Director comments from Locality

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Coggeshall Neighbourhood Plan HRA Coggeshall Neighbourhood Plan Group

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

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Table of Contents

1. Introduction ...... 6 Background to the Project ...... 6 Legislation ...... 6 Report Layout...... 7 2. Methodology ...... 8 Introduction ...... 8 A Proportionate Assessment ...... 8 The Process of HRA ...... 9 Task One: Test of Likely Significant Effect ...... 10 Task Two: Appropriate Assessment ...... 10 The Scope ...... 11 The ‘in Combination’ Scope ...... 12 3. Pathways of Impact ...... 14 Recreational Pressure ...... 14 Breeding birds (February to August) ...... 14 Non-breeding birds (September to January) ...... 14 Mechanical/abrasive damage and nutrient enrichment ...... 16 Water Quality ...... 17 Atmospheric Pollution (Atmospheric Nitrogen Deposition) ...... 17 Local Air Pollution ...... 19 4. Test of Likely Significance ...... 20 Introduction ...... 20 Summary of Test of Likely Significance ‘In Combination’ ...... 20 Policy Screening Summary ...... 20 European Site Vulnerabilities ...... 21 Potential Impact Pathways ...... 21 5. Appropriate Assessment ...... 23 Recreational Pressure ‘in Combination’ ...... 23 6. Conclusions and Recommendations ...... 26 Appendix A European Site Background Information ...... 27 Abberton Reservoir SPA and Ramsar ...... 27 Blackwater Estuary (Mid Essex Coast Phase 4) SPA and Ramsar ...... 29 Colne Estuary (Mid Essex Coast Phase 2) SPA and Ramsar ...... 31 Essex Estuaries SAC ...... 33 Appendix B Policy Screening ...... 35 Appendix C Maps ...... 56

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Plates Plate 1. Traffic contribution to concentrations of pollutants at different distances from a road (Source: DfT) ...... 19

Tables Table 1: Physical Scope of the HRA ...... 11 Table 2: Main sources and effects of air pollutants on habitats and species ...... 17

Figures Figure 1: The legislative basis for Appropriate Assessment ...... 6 Figure 2: Tiering in HRA of Land Use Plans ...... 9 Figure 3: Four-Stage Approach to Habitats Regulations Assessment ...... 10

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1. Introduction Background to the Project 1.1 AECOM has been appointed by Coggeshall Neighbourhood Plan Group to assist in producing a report to inform Braintree District Council’s Habitats Regulations Assessment (HRA) of the potential effects of Coggeshall Neighbourhood Plan on the Natura 2000 Network and Ramsar sites. The objectives of the assessment are to:

• Identify any aspects of the Neighbourhood Plan that would cause an adverse effect on the integrity of Natura 2000 sites, otherwise known as European sites (Special Areas of Conservation (SACs), Special Protection Areas (SPAs), protected SPAs (pSPAs) and, as a matter of Government policy, Ramsar sites), either alone or in combination with other plans and projects; and

• To advise on appropriate policy mechanisms for delivering mitigation where such effects were identified.

1.2 The HRA of the Coggeshall Neighbourhood Plan is required to determine if there are any realistic linking pathways present between a European site and the Neighbourhood Plan and where Likely Significant Effects cannot be screened out, an analysis to inform Appropriate Assessment to be undertaken to determine if adverse effects on the integrity of the European sites will occur as a result of the Neighbourhood Plan alone or in combination. Legislation 1.3 The need for HRA is set out within Article 6 of the EC Habitats Directive 1992 and interpreted into British law by the Conservation of Habitats & Species Regulations 2017 (Figure 1). The ultimate aim of the Habitats Directive is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates to habitats and species, not the European sites themselves, although the sites have a significant role in delivering favourable conservation status. European sites (also called Natura 2000 sites) can be defined as actual or proposed/candidate Special Areas of Conservation (SAC) or Special Protection Areas (SPA). It is also Government policy for sites designated under the Convention on Wetlands of International Importance (Ramsar sites) to be treated as having equivalent status to Natura 2000 sites.

Figure 1: The legislative basis for Appropriate Assessment

Habitats Directive 1992

Article 6 (3) states that: “Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives.”

Conservation of Habitats and Species Regulations 2017 (as amended)

With specific reference to Neighbourhood Plans, Regulation 106(1) states that: ‘A qualifying body which submits a proposal for a neighbourhood development plan must provide such information as the competent authority [the Local Planning Authority] may reasonably require for the purposes of the assessment under regulation 105 [which sets out the formal process for determination of ‘likely significant effects’ and the ‘appropriate assessment’]…’.

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1.4 It is therefore important to note that this report has two purposes:

• To assist the Qualifying Body (the Neighbourhood Plan Group) in preparing their plan by recommending (where necessary) any adjustments required to protect European sites, thus making it more likely their plan will be deemed compliant with the Conservation of Habitats and Species Regulations 2017 (as amended); and

• On behalf of the Qualifying Body, to assist the Local Planning Authority to discharge their duty under Regulation 105 (in their role as ‘plan-making authority’ within the meaning of that regulation) and Regulation 106 (in their role as ‘competent authority’).

1.5 As ‘competent authority’, the legal responsibility for ensuring that a decision of ‘likely significant effects’ is made, for ensuring an ‘appropriate assessment’ (where required) is undertaken, and for ensuring Natural England are consulted, falls on the local planning authority and the Neighbourhood Plan examiner. However, they are entitled to request from the Qualifying Body the necessary information on which to base their judgment and that is a key purpose of this report.

1.6 The Habitats Regulations applies the precautionary principle to Natura 2000 sites (SAC and SPA). As a matter of UK Government policy, Ramsar sites are given equivalent status. For the purposes of this assessment candidate SACs (cSACs), proposed SPAs (pSPAs) and proposed Ramsar (pRamsar) sites are all treated as fully designated sites. In this report we use the term “European designated sites” to refer collectively to the sites listed in this paragraph.

1.7 Plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. This contrasts with the SEA Directive which does not prescribe how plan or programme proponents should respond to the findings of an environmental assessment; merely that the assessment findings (as documented in the ‘environmental report’) should be ‘taken into account’ during preparation of the plan or programme. In the case of the Habitats Directive, plans and projects may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead. In such cases, compensation would be necessary to ensure the overall integrity of the site network.

1.8 In 2018, the ‘People Over Wind’ European Court of Justice (ECJ) ruling1 determined that ‘mitigation’ (i.e. measures that are specifically introduced to avoid or reduce the harmful effects of a plan or project on European sites) should not be taken into account when forming a view on likely significant effects. Mitigation should instead only be considered at the appropriate assessment stage. Appropriate assessment is not a technical term: it simply means ‘an assessment that is appropriate’ for the plan or project in question. As such, the law purposely does not prescribe what it should consist of or how it should be presented; these are decisions to be made on a case by case basis by the competent authority. An amendment was made to the Neighbourhood Planning Regulations in late 2018 which permitted Neighbourhood Plans to be made if they required appropriate assessment.

1.9 Over the years the phrase ‘Habitats Regulations Assessment’ has come into wide currency to describe the overall process set out in the Conservation of Habitats and Species Regulations from screening through to Imperative Reasons of Overriding Public Interest (IROPI). This has arisen in order to distinguish the process from the individual stage described in the law as an ‘Appropriate Assessment’. Throughout this report we use the term Habitats Regulations Assessment for the overall process. Report Layout 1.10 Chapter 2 of this report explains the process by which the HRA has been carried out. Chapter 3 explores the relevant pathways of impact. Chapter 4 summarises the Test of Likely Significant Effects of the policies and site allocations of the Plan considered ‘alone’ and ‘in-combination. (The Test of Likely Significant Effects itself is undertaken in Appendix B). Chapter 5 contains the Appropriate Assessment for any linking impact pathways that could not be screened out from potentially resulting in a Likely Significant Effect. Chapter 6 contains the conclusion and a summary of recommendations.

1 Case C-323/17

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2. Methodology Introduction 2.1 This section sets out the approach and methodology for undertaking the Habitats Regulations Assessment (HRA). HRA itself operates independently from the Planning Policy system, being a legal requirement of a discrete Statutory Instrument. Therefore, there is no direct relationship to the National Planning Policy Framework (NPPF) and the ‘Tests of Soundness’. A Proportionate Assessment 2.2 Project-related HRA often requires bespoke survey work and novel data generation in order to accurately determine the significance of effects. In other words, to look beyond the risk of an effect to a justified prediction of the actual likely effect and to the development of avoidance or mitigation measures.

2.3 However, the draft MHCLG guidance2 (described in greater detail later in this chapter) makes it clear that when implementing HRA of land-use plans, the Appropriate Assessment (AA) should be undertaken at a level of detail that is appropriate and proportional to the level of detail provided within the plan itself:

2.4 “The comprehensiveness of the [Appropriate] assessment work undertaken should be proportionate to the geographical scope of the option and the nature and extent of any effects identified. An AA need not be done in any more detail, or using more resources, than is useful for its purpose. It would be inappropriate and impracticable to assess the effects [of a strategic land use plan] in the degree of detail that would normally be required for the Environmental Impact Assessment (EIA) of a project.”

2.5 More recently, the Court of Appeal3 ruled that providing the Council (competent authority) was duly satisfied that proposed mitigation could be “achieved in practice” then this would suffice to meet the requirements of the Habitat Regulations. This ruling has since been applied to a planning permission (rather than a Plan document)4. In this case the High Court ruled that for “a multistage process, so long as there is sufficient information at any particular stage to enable the authority to be satisfied that the proposed mitigation can be achieved in practice it is not necessary for all matters concerning mitigation to be fully resolved before a decision maker is able to conclude that a development will satisfy the requirements of reg 61 of the Habitats Regulations”.

2.6 In other words, there is a tacit acceptance that AA can be tiered and that all impacts are not necessarily appropriate for consideration to the same degree of detail at all tiers as illustrated in Figure 2.

2 MHCLG (2006) Planning for the Protection of European Sites, Consultation Paper 3 No Adastral New Town Ltd (NANT) v Suffolk Coastal District Council Court of Appeal, 17th February 2015 4 High Court case of R (Devon Wildlife Trust) v Teignbridge District Council, 28 July 2015

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Figure 2: Tiering in HRA of Land Use Plans

2.7 For a plan the level of detail concerning the developments that will be delivered is usually insufficient to make a highly detailed assessment of significance of effects. For example, precise and full determination of the impacts and significant effects of a new settlement will require extensive details concerning the design of the new housing sites, including layout of greenspace and type of development to be delivered in particular locations, yet these data will not be decided until subsequent stages.

2.8 The most robust and defensible approach to the absence of fine grain detail at this level is to make use of the precautionary principle. In other words, the plan is never given the benefit of the doubt (within the limits of reasonableness); it must be assumed that a policy/measure is likely to have an impact leading to a significant adverse effect upon an internationally designated site unless it can be clearly established otherwise. The Process of HRA 2.9 The HRA is being carried out in the continuing absence of formal central Government guidance. The former DCLG (now MHCLG) released a consultation paper on AA of Plans in 20065. As yet, no further formal guidance has emerged from MHCLG. However, Natural England has produced its own informal internal guidance and Natural Resources Wales has produced guidance for Welsh authorities on “the appraisal of plans under the Habitats Regulations” as a separate guidance document aimed at complementing and supplementing the guidance/advice provided within Technical Advice Note 5: Nature Conservation and Planning6.

2.10 Figure 3 outlines the stages of HRA according to the draft MHCLG guidance (which, as government guidance applicable to English authorities is considered to take precedence over other sources of guidance). The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no likely significant effects remain.

5 MHCLG (2006) Planning for the Protection of European Sites, Consultation Paper 6 Welsh Government. Technical Advice Note 5, Nature Conservation and Planning (2009) http://gov.wales/topics/planning/policy/tans/tan5/?lang=en [accessed 01/12/2016]

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Figure 3: Four-Stage Approach to Habitats Regulations Assessment

2.11 The following process has been adopted for carrying out the subsequent stages of the HRA.

Task One: Test of Likely Significant Effect 2.12 The first stage of any Habitats Regulations Assessment is a test of Likely Significant Effect - essentially a high-level assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:

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

2.14 In evaluating significance, AECOM have relied on professional judgment and experience of working with the other local authorities on similar issues. The level of detail concerning developments that will be permitted under land use plans is rarely sufficient to make a detailed quantification of effects. Therefore, a precautionary approach has been taken (in the absence of more precise data) assuming as the default position that if a likely significant effect (LSE) cannot be confidently ruled out, then the assessment must be taken the next level of assessment Task Two: Appropriate Assessment. This is in line with the April 2018 court ruling relating to ‘People Over Wind’ where mitigation and avoidance measures are to be included at the next stage of assessment.

Task Two: Appropriate Assessment 2.15 European Site(s) which have been ‘screened in’ during the previous Task have a detailed assessment undertaken on the effect of the policies on the European site(s) site integrity. Avoidance and mitigation measures to avoid adverse significant effects are taken into account or recommended where necessary.

2.16 As established by case law, ‘appropriate assessment’ is not a technical term; it simply means whatever further assessment is necessary to confirm whether there would be adverse effects on the integrity of any European sites that have not been dismissed at screening. Since it is not a technical term it has no firmly established methodology except that it essentially involves repeating the analysis for the likely significant effects stage, but to a greater level of detail on a smaller number of policies and sites, this time with a view to determining if there would be adverse effects on integrity.

2.17 One of the key considerations during Appropriate Assessment is whether there is available mitigation that would entirely address the potential effect. In practice, the Appropriate Assessment takes any policies or allocations that could not be dismissed following the high-level Screening analysis and analyse the potential

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for an effect in more detail, with a view to concluding whether there would actually be an adverse effect on integrity (in other words, disruption of the coherent structure and function of the European site(s)). The Scope 2.18 There is no guidance that dictates the physical scope of an HRA of a plan. Therefore, in considering the physical scope of the assessment we were guided primarily by the identified impact pathways rather than by arbitrary “zones”, i.e. a source-pathway-receptor approach. Current guidance suggests that the following European sites be included in the scope of assessment:

• All sites within the Neighbourhood Area (the area covered by the Neighbourhood Plan); and

• Other sites shown to be linked to development within the Neighbourhood Area through a known “pathway” (discussed below).

2.19 Briefly defined, pathways are routes by which a change in activity within the plan area can lead to an effect upon a European site. In terms of the second category of European site listed above, MHCLG guidance states that the AA should be “proportionate to the geographical scope of the [plan policy]” and that “an AA need not be done in any more detail, or using more resources, than is useful for its purpose” (MHCLG, 2006, p.6).

2.20 Locations of European designated sites are illustrated in Appendix A, Map 1, and full details of all European designated sites discussed in this document can be found in Appendix B. specifying their qualifying features, conservation objectives and threats to integrity. Table 1 below lists all those European designated sites included in this HRA.

Note that the inclusion of a European sites or pathway below does not indicate that an effect is expected but rather that these are pathways that will be investigated.

Table 1: Physical Scope of the HRA

European Location Reason for Inclusion/ Other site Designated Site Exclusion (pressures/ threats7 vulnerabilities associated with the European site that could link to the Plan.)

Abberton Reservoir At its closest 9.4 km SE of the - Public access / disturbance - Siltation SPA and Ramsar Neighbourhood Area - Planning permission: - Water pollution general - Changes in species - Air pollution: risk of atmospheric distribution nitrogen deposition - Bird strike

Blackwater Estuary At its closest 12.1 km SE of the - Public access / disturbance - Coastal squeeze (Mid-Essex Coast Neighbourhood Area Phase 4) SPA and Ramsar - Air pollution: risk of atmospheric - Planning permission: nitrogen deposition general

- Change in species distribution

- Invasive species

- Fisheries: recreational marine and estuarine

- Fisheries: commercial marine and estuarine

Essex Estuaries SAC At its closest 12.1 km SE of the - Public access / disturbance - Coastal squeeze Neighbourhood Area

7 As identified in the Site Improvement Plans or RAMS for European sites.

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- Air pollution: risk of atmospheric - Planning permission: nitrogen deposition general

- Change in species distribution

- Invasive species

- Fisheries: recreational marine and estuarine

- Fisheries: commercial marine and estuarine

Colne Estuary (Mid- At its closest 14.7 km SE of the - Public access / disturbance - Coastal squeeze Essex Coast Phase 2) Neighbourhood Area SPA and Ramsar - Air pollution: risk of atmospheric - Planning permission: nitrogen deposition general

- Change in species distribution

- Invasive species

- Fisheries: recreational marine and estuarine

- Fisheries: commercial marine and estuarine

The ‘in Combination’ Scope 2.21 It is a requirement of the Regulations that the impacts and effects of any land use plan being assessed are not considered in isolation but in combination with other plans and projects that may also be affecting the European designated site(s) in question.

2.22 When undertaking this part of the assessment it is essential to bear in mind the principal intention behind the legislation i.e. to ensure that those projects or plans which in themselves have minor impacts are not simply dismissed on that basis, but are evaluated for any cumulative contribution they may make to an overall significant effect. In practice, in combination assessment is therefore of greatest relevance when the plan would otherwise be screened out because its individual contribution is inconsequential. The overall approach is to exclude the risk of there being unassessed likely significant effects in accordance with the precautionary principle. This was first established in the seminal Waddenzee8 case.

2.23 For the purposes of this assessment, we have determined that, due to the nature of the identified impacts, the key other plans and projects with potential for in combination likely significant effects are those schemes that have the following impact pathways: Disturbance (including urbanisation and recreational pressure), changes in hydraulic conditions and loss of functionally linked land. The following plans have been assessed for their in combination impact to interact with the Neighbourhood Plan:

• Braintree District Local Plan (Publication Draft) 2017-2033

• Colchester Borough Local Plan (Submission Draft) 2017-2033

• Maldon District Local Development Plan 2014-2033

• Chelmsford District Local Plan (Publication Draft) to 2036

• Uttlesford District Local Plan (Publication Draft) to 2033

8 Waddenzee case (Case C-127/02, [2004] ECR-I 7405)

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• Joint Babergh and Mid-Suffolk Local Development Scheme (Draft Local Plan)

• Anglian Water Draft Drought Plan 2019

• Essex Transport Strategy: The Local Transport Plan for Essex 2011

• Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS) 2018 – 2038

o Participating local authorities: Basildon Borough Council, Braintree District Council, Brentwood Borough Council, Castle Point Borough Council, Chelmsford City Council, Colchester Borough Council, Maldon District Council, Rochford District Council, Southend Borough Council, Tendring District Council, Thurrock Borough Council.

2.24 It should be noted that, while the broad potential impacts of these other projects and plans will be considered, we do not propose carrying out full HRA on each of these plans – we will however draw upon existing HRA that have been carried out for surrounding regions and plans.

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3. Pathways of Impact

3.1 The HRA of the Braintree Local Plan (2017) has been referenced in producing this HRA and identifying the potential pathways of impact. The following pathways of impact are considered relevant to the HRA of the Plan:

• Recreational pressure

• Water quality

• Atmospheric pollution from atmospheric nitrogen deposition

Recreational Pressure 3.2 Recreational use of a European site has the potential to:

• Cause disturbance to sensitive species, particularly ground-nesting birds and (where relevant) wintering wildfowl;

• Cause damage through erosion and fragmentation;

• Cause eutrophication as a result of dog fouling; and

• Prevent appropriate management or exacerbate existing management difficulties.

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

3.4 It should be emphasised that recreational use is not inevitably a problem. Many European sites also contain nature reserves managed for conservation and public appreciation of nature.

3.5 HRAs of Local Plans tend to focus on recreational sources of disturbance as a result of new residents9.

Breeding birds (February to August) 3.6 Concern regarding the effects of disturbance on birds stems from the fact that they are expending energy unnecessarily and the time they spend responding to disturbance is time that is not spent feeding (this will apply all year round)10. Disturbance therefore risks increasing energetic output while reducing energetic input, which can adversely affect the ‘condition’ and ultimately survival of the birds. In addition, displacement of birds from one feeding site to others can increase the pressure on the resources available within the remaining sites, as they have to sustain a greater number of birds11. Moreover, the more time a breeding bird spends disturbed from its nest, the more its eggs are likely to cool and the more vulnerable they, or any nestlings, are to predators.

Non-breeding birds (September to January) 3.7 The potential for disturbance may be different in winter than in summer, in that there are often a smaller number of recreational users. In addition, the consequences of disturbance at a population level may be reduced because birds are not breeding. However, activity outside of the summer months can still cause important disturbance, especially as birds are particularly vulnerable at this time of year due to food shortages. Disturbance which results in abandonment of suitable feeding areas can have severe consequences for those birds involved and their ability to find alternative feeding areas. Evans &

9 The RTPI report ‘Planning for an Ageing Population‘(2004) which states that ‘From being a marginalised group in society, the elderly are now a force to be reckoned with and increasingly seen as a market to be wooed by the leisure and tourist industries. There are more of them and generally they have more time and more money.’ It also states that ‘Participation in most physical activities shows a significant decline after the age of 50. The exceptions to this are walking, golf, bowls and sailing, where participation rates hold up well into the 70s’. 10 Riddington, R. et al. 1996. The impact of disturbance on the behaviour and energy budgets of Brent geese. Bird Study 43:269-279 11 Gill, J.A., Sutherland, W.J. & Norris, K. 1998. The consequences of human disturbance for estuarine birds. RSPB Conservation Review 12: 67-72

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Warrington12 found that on Sundays total water bird numbers (including shoveler and gadwall) were 19% higher on Stocker’s Lake LNR in Hertfordshire, and attributed this to observed greater recreational activity on surrounding water bodies at weekends relative to week days displacing birds into the LNR. However, recreational activity was not quantified in detail in this study and individual recreational activities were not evaluated separately. Tuite et al13 used a large (379 site), long-term (10-year) dataset (September – March species counts) to correlate seasonal changes in wildfowl abundance with the presence of various recreational activities. They found that shoveler was one of the most sensitive species to disturbance. The greatest impact on wildfowl numbers during these months was associated with sailing/windsurfing and rowing. Underhill et al14 counted waterfowl and all disturbance events on 54 water bodies within the South West London Water Bodies Special Protection Area and clearly correlated disturbance with a decrease in bird numbers at weekends in smaller sites and with the movement of birds within larger sites from disturbed to less disturbed areas.

3.8 More recent research has established that human activity including recreational activity can be linked to disturbance of wintering waterfowl populations15 16.

3.9 Human activity can affect birds either directly (e.g. through causing them to flee) or indirectly (e.g. through damaging their habitat or reducing their fitness in less obvious ways e.g. stress). The most obvious direct effect is that of immediate mortality such as death by shooting, but human activity can also lead to behavioural changes (e.g. alterations in feeding behaviour, avoidance of certain areas and use of sub optimal areas etc.) and physiological changes (e.g. an increase in heart rate) that, although less noticeable, may ultimately result in major population-level effects by altering the balance between immigration/birth and emigration/death17.

3.10 The degree of impact that varying levels of noise will have on different species of bird is poorly understood except that a number of studies have found that an increase in traffic levels on roads does lead to a reduction in the bird abundance within adjacent hedgerows - Reijnen et al (1995) examined the distribution of 43 passerine species (i.e. ‘songbirds’), of which 60% had a lower density closer to the roadside than further away. By controlling vehicle usage they also found that the density generally was lower along busier roads than quieter roads18. A study on Holt Heath noted reduced levels of fitness due to occupation of sub optimal habitats alongside roads amongst heathland species.

3.11 A recent study on recreational disturbance on the Humber19 assesses different types of noise disturbance on waterfowl referring to studies relating to aircraft (see Drewitt 199920), traffic (Reijnen, Foppen, & Veenbaas 1997)21, dogs (Lord, Waas, & Innes 199722; Banks & Bryant 200723) and machinery (Delaney et al. 1999; Tempel & Gutierrez 2003). These studies identified that there is still relatively little work on the effects of different types of water based craft and the impacts from jet skis, kite surfers, windsurfers etc. (see Kirby et al. 200424 for a review). Some types of disturbance are clearly likely to invoke different responses. In very general terms, both distance from the source of disturbance and the scale of the disturbance (noise level, group size) will both influence the response (Delaney et al. 199925; Beale &

12 Evans, D.M. & Warrington, S. 1997. The effects of recreational disturbance on wintering waterbirds on a mature gravel pitlake near London. International Journal of Environmental Studies 53: 167-182 13 Tuite, C.H., Hanson, P.R. & Owen, M. 1984. Some ecological factors affecting winter wildfowl distribution on inland waters in England and Wales and the influence of water-based recreation. Journal of Applied Ecology 21: 41-62 14 Underhill, M.C. et al. 1993. Use of Waterbodies in South West London by Waterfowl. An Investigation of the Factors Affecting Distribution, Abundance and Community Structure. Report to Thames Water Utilities Ltd. and English Nature. Wetlands Advisory Service, Slimbridge 15 Footprint Ecology. 2010. Recreational Disturbance to Birds on the Humber Estuary 16 Footprint Ecology, Jonathan Cox Associates & Bournemouth University. 2010. Solent disturbance and mitigation project – various reports. 17 Riley, J. 2003. Review of Recreational Disturbance Research on Selected Wildlife in Scotland. Scottish Natural Heritage. 18 Reijnen, R. et al. 1995. The effects of car traffic on breeding bird populations in woodland. III. Reduction of density in relation to the proximity of main roads. Journal of Applied Ecology 32: 187-202 19 Helen Fearnley Durwyn Liley and Katie Cruickshanks (2012) Results of Recreational Visitor Survey across the Humber Estuary produced by Footprint Ecology 20 Drewitt, A. (1999) Disturbance effects of aircraft on birds. English Nature, Peterborough. 21 Reijnen, R., Foppen, R. & Veenbaas, G. (1997) Disturbance by traffic of breeding birds: evaluation of the effect and considerations in planning and managing road corridors. Biodiversity and Conservation, 6, 567-581. 22 Lord, A., Waas, J.R. & Innes, J. (1997) Effects of human activity on the behaviour of northern New Zealand dotterel Charadrius obscurus aquilonius chicks. Biological Conservation, 82,15-20. 23 Banks, P.B. & Bryant, J.V. (2007) Four-legged friend of foe? Dog-walking displaces native birds from natural areas. Biology Letters, 3, 611-613. 24 Kirby, J.S., Clee, C. & Seager, V. (1993) Impact and extent of recreational disturbance to wader roosts on the Dee estuary: some preliminary results. Wader Study Group Bulletin, 68, 53-58. 25 Delaney, D.K., Grubb, T.G., Beier, P., Pater, L.L.M. & Reiser, H. (1999) Effects of Helicopter Noise on Mexican Spotted Owls. The Journal of Wildlife Management, 63, 60-76.

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Monaghan 200526). On UK estuaries and coastal sites, a review of WeBS data showed that, among the volunteer WeBS surveyors, driving of motor vehicles and shooting were the two activities most perceived to cause disturbance (Robinson & Pollitt 2002)27.

Mechanical/abrasive damage and nutrient enrichment 3.12 Most types of aquatic or terrestrial European site can be affected by trampling, which in turn causes soil compaction and erosion:

• Wilson & Seney (1994)28 examined the degree of track erosion caused by hikers, motorcycles, horses and cyclists from 108 plots along tracks in the Gallatin National Forest, Montana. Although the results proved difficult to interpret, it was concluded that horses and hikers disturbed more sediment on wet tracks, and therefore caused more erosion, than motorcycles and bicycles.

• Cole et al (1995a, b)29 conducted experimental off-track trampling in 18 closed forest, dwarf scrub and meadow & grassland communities (each tramped between 0 – 500 times) over five mountain regions in the US. Vegetation cover was assessed two weeks and one year after trampling, and an inverse relationship with trampling intensity was discovered, although this relationship was weaker after one year than two weeks indicating some recovery of the vegetation. Differences in plant morphological characteristics were found to explain more variation in response between different vegetation types than soil and topographic factors. Low-growing, mat-forming grasses regained their cover best after two weeks and were considered most resistant to trampling, while tall forbs (non-woody vascular plants other than grasses, sedges, rushes and ferns) were considered least resistant. Cover of hemicryptophytes and geophytes (plants with buds below the soil surface) was heavily reduced after two weeks, but had recovered well after one year and as such these were considered most resilient to trampling. Chamaephytes (plants with buds above the soil surface) were least resilient to trampling. It was concluded that these would be the least tolerant of a regular cycle of disturbance.

• Cole (1995c)30 conducted a follow-up study (in 4 vegetation types) in which shoe type (trainers or walking boots) and trampler weight were varied. Although immediate damage was greater with walking boots, there was no significant difference after one year. Heavier tramplers caused a greater reduction in vegetation height than lighter tramplers, but there was no difference in effect on cover.

• Cole & Spildie (1998)31 experimentally compared the effects of off-track trampling by hiker and horse (at two intensities – 25 and 150 passes) in two woodland vegetation types (one with an erect forb understorey and one with a low shrub understorey). Horse traffic was found to cause the largest reduction in vegetation cover. The forb-dominated vegetation suffered greatest disturbance, but recovered rapidly. Higher trampling intensities caused more disturbance. 3.13 Walkers with dogs contribute to pressure on sites through nutrient enrichment via dog fouling and also cause greater disturbance to fauna as dogs are less likely to keep to marked footpaths and also tend to move in a more erratic manner. Sites being managed by nature conservation bodies and local authorities frequently resort to hardening eroded paths to restrict erosion but at the same time they are losing the habitats formerly used by sand lizards and burrowing invertebrates. Motorcycle scrambling and off-road vehicle use can cause more serious erosion, as well as disturbance to sensitive species. Cycling and horse riding also contribute to mechanical abrasion and disturbance; however, dog walkers, due to their prevalence and

26 Beale, C.M. & Monaghan, P. (2005) Modeling the Effects of Limiting the Number of Visitors on Failure Rates of Seabird Nests. Conservation Biology, 19, 2015-2019. 27 Robinson, J.A. & Pollitt, M.S. (2002) Sources and extent of human disturbance to waterbirds in the UK: an analysis of Wetland Bird Survey data, 1995/96 to 1998/99: Less than 32% of counters record disturbance at their site, with differences in causes between coastal and inland sites. Bird Study, 49, 205. 28 Wilson, J.P. & J.P. Seney. 1994. Erosional impact of hikers, horses, motorcycles and off road bicycles on mountain trails in Montana. Mountain Research and Development 14:77-88 29 Cole, D.N. 1995a. Experimental trampling of vegetation. I. Relationship between trampling intensity and vegetation response. Journal of Applied Ecology 32: 203-214 Cole, D.N. 1995b. Experimental trampling of vegetation. II. Predictors of resistance and resilience. Journal of Applied Ecology 32: 215-224 30 Cole, D.N. 1995c. Recreational trampling experiments: effects of trampler weight and shoe type. Research Note INT-RN- 425. U.S. Forest Service, Intermountain Research Station, Utah. 31 Cole, D.N., Spildie, D.R. 1998. Hiker, horse and llama trampling effects on native vegetation in Montana, USA. Journal of Environmental Management 53: 61-71

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motor vehicles cause the greatest impact. Boats can cause some mechanical damage to intertidal habitats through grounding as well as anchor and anchor line damage. Water Quality 3.14 Increased amounts of housing or business development can lead to reduced water quality of rivers and estuarine environments. Sewage and industrial effluent discharges can contribute to increased nutrients on European sites leading to unfavourable conditions. In addition, diffuse pollution, partly from urban runoff has been identified during an Environment Agency Review of Consents process and a joint Environment Agency and Natural England evidence review, as being a major factor in causing unfavourable condition of European sites.

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

• At high levels, toxic chemicals and metals can result in immediate death of aquatic life, and can have detrimental effects even at lower levels, including increased vulnerability to disease and changes in wildlife behaviour. Eutrophication, the enrichment of plant nutrients in water, increases plant growth and consequently results in oxygen depletion. Algal blooms, which commonly result from eutrophication, increase turbidity and decrease light penetration. The decomposition of organic wastes that often accompanies eutrophication deoxygenates water further, augmenting the oxygen depleting effects of eutrophication. In the marine environment, nitrogen is the limiting plant nutrient and so eutrophication is associated with discharges containing available nitrogen; • Some pesticides, industrial chemicals, and components of sewage effluent are suspected to interfere with the functioning of the endocrine system, possibly having negative effects on the reproduction and development of aquatic life; and • Increased discharge of treated sewage effluent can result both in high levels of macroalgal growth, which can smother the mudflats of value to SPA birds and in greater scour (as a result of greater flow volumes). 3.16 At sewage treatment works, additional residential development increases the risk of effluent escape into aquatic environments in addition to consented discharges to the catchment. In many urban areas, sewage treatment and surface water drainage systems are combined, and therefore a predicted increase in flood and storm events could increase pollution risk. Atmospheric Pollution (Atmospheric Nitrogen Deposition)

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

Table 2: Main sources and effects of air pollutants on habitats and species

Pollutant Source Effects on habitats and species

Acid deposition SO2, NOx and ammonia all contribute to acid Can affect habitats and species through both deposition. Although future trends in S emissions wet (acid rain) and dry deposition. Some sites and subsequent deposition to terrestrial and aquatic will be more at risk than others depending on ecosystems will continue to decline, it is likely that soil type, bed rock geology, weathering rate increased nitrogen emissions may cancel out any and buffering capacity. gains produced by reduced suplhur levels.

Ammonia (NH3) Ammonia is released following decomposition and Adverse effects are as a result of nitrogen volatilisation of animal wastes. It is a naturally deposition leading to eutrophication. As occurring trace gas, but levels have increased emissions mostly occur at ground level in the

considerably with expansion in numbers of rural environment and NH3 is rapidly deposited,

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agricultural livestock. Ammonia reacts with acid some of the most acute problems of NH3

pollutants such as the products of SO2 and NOX deposition are for small relict nature reserves + emissions to produce fine ammonium (NH4 ) located in intensive agricultural landscapes. containing aerosol which may be transferred much longer distances (can therefore be a significant trans-boundary issue.) Nitrogen oxides Nitrogen oxides are mostly produced in combustion Deposition of nitrogen compounds (nitrates

NOx processes. About one quarter of the UK’s emissions (NO3), nitrogen dioxide (NO2) and nitric acid

are from power stations. (HNO3)) can lead to both soil and freshwater

acidification. In addition, NOx can cause eutrophication of soils and water. This alters the species composition of plant communities and can eliminate sensitive species. Nitrogen (N) The pollutants that contribute to nitrogen deposition Species-rich plant communities with relatively deposition derive mainly from NOX and NH3 emissions. These high proportions of slow-growing perennial pollutants cause acidification (see also acid species and bryophytes are most at risk from N deposition) as well as eutrophication. eutrophication, due to its promotion of competitive and invasive species which can respond readily to elevated levels of N. N deposition can also increase the risk of damage from abiotic factors, e.g. drought and frost.

Ozone (O3) A secondary pollutant generated by photochemical Concentrations of O3 above 40 ppb can be toxic

reactions from NOx and volatile organic compounds to humans and wildlife, and can affect (VOCs). These are mainly released by the buildings. Increased ozone concentrations may combustion of fossil fuels. The increase in lead to a reduction in growth of agricultural combustion of fossil fuels in the UK has led to a large crops, decreased forest production and altered increase in background ozone concentration, species composition in semi-natural plant leading to an increased number of days when levels communities. across the region are above 40ppb. Reducing ozone pollution is believed to require action at international level to reduce levels of the precursors that form ozone.

Sulphur Dioxide Main sources of SO2 emissions are electricity Wet and dry deposition of SO2 acidifies soils

SO2 generation, industry and domestic fuel combustion. and freshwater, and alters the species May also arise from shipping and increased composition of plant and associated animal atmospheric concentrations in busy ports. Total communities. The significance of impacts

SO2 emissions have decreased substantially in the depends on levels of deposition and the UK since the 1980s. buffering capacity of soils.

3.18 Sulphur dioxide emissions are overwhelmingly influenced by the output of power stations and industrial processes that require the combustion of coal and oil. Ammonia emissions are dominated by agriculture, with some chemical processes also making notable contributions. As such, it is unlikely that material increases in SO2 or NH3 emissions will be associated with Local Plans or Neighbourhood Plans. NOx emissions, however, are dominated by the output of vehicle exhausts. Within a ‘typical’ housing development, by far the largest contribution to NOx (92%) will be made by the associated road traffic. Other 32 sources, although relevant, are of minor importance (8%) in comparison . Emissions of NOx could therefore be reasonably expected to increase as a result of greater vehicle use as an indirect effect of the Neighbourhood Plan.

3.19 According to the World Health Organisation, the critical NOx concentration (critical threshold) for the protection of vegetation is 30 µgm-3; the threshold for sulphur dioxide is 20 µgm-3. In addition, ecological 33 studies have determined ‘Critical Loads’ of atmospheric nitrogen deposition (that is, NOx combined with ammonia NH3) for key habitats within European sites.

32 Proportions calculated based upon data presented in Dore CJ et al. 2005. UK Emissions of Air Pollutants 1970 – 2003. UK National Atmospheric Emissions Inventory. http://www.airquality.co.uk/archive/index.php 33 The Critical Load is the rate of deposition beyond which research indicates that adverse effects can reasonably be expected to occur

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Local Air Pollution 3.20 According to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”34.

Plate 1. Traffic contribution to concentrations of pollutants at different distances from a road (Source: DfT)

3.21 This is therefore the distance that has been used throughout this HRA in order to determine whether European sites are likely to be significantly affected by development under the Neighbourhood Plan.

34 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf

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4. Test of Likely Significance Introduction 4.1 The initial scoping of European designated sites illustrated in Table 1 identifies that some site are potentially vulnerable to:

• Recreational pressure

• Water quality

• Atmospheric pollution from atmospheric nitrogen deposition

4.2 The full test of Likely Significant Effects for the Coggeshall Neighbourhood Plan is presented in Appendix B. The assessment took into consideration the above potential vulnerabilities of the European sites included in Table 1.

4.3 After an initial investigation into linking impact pathways the following European sites have been screened in as having one or more linking impact pathways:

• Abberton Reservoir SPA and Ramsar

• Blackwater Estuary (Mid-Essex Coast Phase 4) SPA and Ramsar

• Colne Estuary (Mix-Essex Coast Phase 2) SPA and Ramsar

• Essex Estuaries SAC

4.4 None of these European sites are present within the Neighbourhood Area and therefore will not cause likely significant effects upon the European sites alone. Therefore, the following sections will focus on the ‘in combination’ effects. Summary of Test of Likely Significance ‘In Combination’ Policy Screening Summary 4.5 Of the 19 Neighbourhood Plan policies, five policies, were considered to have the potential to result in a likely significant effect in combination:

• Policy P1 – Meeting the Housing Need - this policy allocates four sites for residential development within the Neighbourhood Area.

• Policy P2 -Tey Road – this policy is one of the sites allocated within Policy P1. This site is allocated for around 10 residential dwellings.

• Policy P3 – The Dutch Nursery – This policy is one of the sites allocated within Policy P1. This site is allocated for around 60 residential dwellings.

• Policy P4 – Cook Field, East Street – This policy is one of the sites allocated within Policy P1. This site is allocated for around 15 residential dwellings.

• Policy P5 – Land North of Colchester Road – This policy is one of the sites allocated within Policy P1. This site is allocated for around 300 residential dwellings.

• Policy P6 – Meeting Business Needs – This policy does not allocate a quantum of business nor sites. However, it does promote new businesses and enhanced tourism facilities within the Neighbourhood Area.

4.6 The above policies provide for the following realistic potential linking impact pathways that could result in likely significant effects on European sites in combination:

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• Recreational pressure: as a result of new residential dwellings increasing the number of visitors within the European Sites. (Policies: P1 to P5)

• Air quality: as a result of increased journeys to work and increased local residents driving to European sites. (Policies: P1 to P6)

• Water quality: increased effluent as a result of increased residential dwellings and business development. (Policies: P1 to P6).

4.7 All remaining policies are development management policies that do not provide impact pathways that could potentially link to European sites.

European Site Vulnerabilities Abberton Reservoir SPA and Ramsar

4.8 Abberton Reservoir SPA and Ramsar is a large water storage reservoir close to the Essex Coast. The European site at its closest is approximately 9.4km South East of the Neighbourhood Area. The site has been identified to be vulnerable to increased disturbance through recreational pressure, water pollution and air pollution through increases in atmospheric nitrogen deposition. Blackwater Estuary (Mid-Essex Phase 4) SPA and Ramsar

4.9 Blackwater Estuary SPA and Ramsar is a coastal plain estuarine system with open coast mudflats and sand banks. The European site at its closest is approximately 12.1 km south of the Neighbourhood Area. The site has been identified to be vulnerable to increased disturbance through recreational pressure, and air pollution through increases in atmospheric nitrogen deposition. Colne Estuary (Mid-Essex Phase 2) SPA and Ramsar

4.10 Colne Estuary SPA and Ramsar is a coastal plain estuarine system with open coast mudflats and sand banks. The European site at its closest is approximately 14.7 km south of the Neighbourhood Area. The site has been identified to be vulnerable to increased disturbance through recreational pressure, and air pollution through increases in atmospheric nitrogen deposition. Essex Estuaries SAC

4.11 Essex Estuaries SAC is a coastal plain estuarine system with open coast mudflats and sand banks. The European site at its closest is approximately 12.1 km south of the Neighbourhood Area. The site has been identified to be vulnerable to increased disturbance through recreational pressure, and air pollution through increases in atmospheric nitrogen deposition.

Potential Impact Pathways 4.12 Having discussed European site vulnerabilities this section of the report discusses the potential for impacts through each pathway identified. Recreational Pressure

4.13 Recreational pressure is a known impact pathway upon the Essex Coastal European Sites and has been highlighted and discussed within the Braintree District Local Plan and its HRA. As mitigation cannot be taken into consideration at the Screening Stage of the HRA process, Recreational pressure will be discussed further within the Appropriate Assessment in Chapter 5 of this report. Water Quality

4.14 Increased amounts of housing or business development can lead to reduced water quality of rivers and estuarine environments. Sewage and industrial effluent discharges can contribute to increased nutrients on European sites leading to unfavourable conditions. In addition, diffuse pollution, partly from urban run-ff has been identified during an Environment Agency Review of Consents process and a joint Environment Agency

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and Natural England evidence review, as being a major factor in causing unfavourable conditions of European Sites.

4.15 Abberton reservoir is one of two water storage reservoirs that supplies drinking water to Essex. It is known to be vulnerable to decreases in water quality. The reservoir is filled through water being pumped from the River Stour via two large underground pipelines35. The site improvement plan for Abberton Reservoir states that the reservoir high in nutrients (eutrophic)36, however this is mainly from the catchment area of the River Stour being intensively farmed and therefore the nutrients deriving from agricultural processes. In addition to this, Coggeshall Parish is approximately 11 km south of the River Stour and does not form part of the Stour’s catchment area. Coggeshall Parish is instead part of the River Blackwater’s catchment which drains to the Blackwater Estuary. However, the Blackwater Estuary is not vulnerable to water quality issues to the same extent as the build-up of smothering algal blooms from eutrophication is far reduced by the cooler water temperatures, higher wave action and higher sediment loading of coastal waters on the east coast of the UK.

4.16 Therefore, water quality impacts can be screened out of further discussion as there are no linking impact pathways to sensitive European sites. Air Pollution

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

4.18 The Essex Coast European sites are vulnerable to nitrogen deposition. According to the SIP37, at these sites’ nitrogen deposition exceeds the relevant critical loads for coastal dune habitats, which are used by breeding terns, a qualifying feature of the SPA. However, on the Essex estuaries the decline in the number of breeding terns appear to be due mainly to erosion of a man-made cockle-shingle bank at Foulness and to disturbance elsewhere, rather than to over-vegetation of breeding areas caused by nitrogen deposition.

4.19 In addition to this, according to the Department of Transport’s Transport Analysis Guidance, “Beyond 200m, the contribution of vehicle emissions from the roadside to local pollution levels is not significant”38. The HRA for the 2017 Braintree Local Plan concluded that “None of the strategic roads running from or through Braintree District are within 200m of the identified European sites… [and] in particular, commuting journeys are more likely to be contained within the District…, or associated with large settlements such as Colchester and Chelmsford, neither of which are within 200m of the European sites.” Air pollution was for this reason, concluded within the context of the Braintree District Local Plan, not to cause a likely significant effect.

4.20 As this impact pathway has been screened out for the District as a whole within the Local Plan, it can therefore be concluded that air pollution impacts arising from the Neighbourhood Area, can be screened out of further discussion as there are no linking impact pathways to the European sites.

35 https://www.eswater.co.uk/your-home/leisure/Abberton-Reservoir.aspx [Accessed 6 June 2019] 36 http://publications.naturalengland.org.uk/publication/5195034185957376 [Accessed 6 June 2019] 37 http://publications.naturalengland.org.uk/publication/5459956190937088 [Accessed 6 June 2019] 38 www.webtag.org.uk/archive/feb04/pdf/feb04-333.pdf

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5. Appropriate Assessment

5.1 No linking impact pathways were identified for ‘alone’ effects therefore the following impact pathways will be focused on ‘in combination’ effects. Recreational Pressure ‘in Combination’ 5.2 The submitted Braintree District Local Plan is proposing to deliver 14,320 new homes over the plan period up to 2033, as stated in Policy LPP 17 – Housing Provision and Delivery. A single site, in Coggeshall Parish, has been allocated for residential development within the Braintree District Local Plan; The Dutch Nursery (Policy LPP27). However, the site did not have a quantum of housing allocated at the Local Plan level; the plan merely identified that comprehensive redevelopment including housing was identified as being necessary.

5.3 Within the Neighbourhood Plan, four sites have been allocated for residential development. These are:

• Policy P2 -Tey Road – This site is allocated for around 10 residential dwellings.

• Policy P3 – The Dutch Nursery – This site is allocated for around 60 residential dwellings.

• Policy P4 – Cook Field, East Street – This site is allocated for around 15 residential dwellings.

• Policy P5 – Land North of Colchester Road – This site is allocated for around 300 residential dwellings.

5.4 The total quantum of residential development being allocated within the Coggeshall Neighbourhood Plan is therefore around 385 dwellings.

5.5 Policy P1 – Meeting Housing Need also states “In addition to the sites listed above, the Parish Council will support the development of brown-field land and infill opportunities within the settlement boundaries for residential use”. Enhanced tourist facilities are also encouraged by Policy P6 – Meeting Business Need.

5.6 The policies discussed above have the potential in combination with other plans and projects to increase recreational pressure within European sites with increased recreational pressure listed as a vulnerability within the Site Improvement Plan (SIP). All European sites discussed within this HRA are vulnerable to increased recreational pressure. These are:

• Abberton Reservoir SPA and Ramsar

• Blackwater Estuary (Mid-Essex Coast Phase 4) SPA and Ramsar

• Colne Estuary (Mix-Essex Coast Phase 2) SPA and Ramsar

• Essex Estuaries SAC

5.7 Policy LPP68 in the Braintree District Local Plan 2033 provides protection to European sites as follows; “Proposals likely to have an adverse effect will require a full assessment in line with European Legislation”. Visitor surveys of the Essex coast European sites were undertaken by Colchester District Council39 in order to highlight visitor numbers and patterns to allow for appropriate mitigation measures to be sought.

5.8 One of the areas surveyed was Abberton Reservoir, which is a large reservoir manage by Essex and Suffolk Water. It is one of the most important reservoirs in the country for overwintering waterfowl and also supports substantial aggregations of moulting birds in early autumn and a large colony of tree-nesting cormorants. The reservoir itself has no public access, however there are several footpaths around the reserve which lead to bird hides which can be used for bird watching. In addition, no dogs are allowed to be walked on the reserve. A visitor study was undertaken at Abberton during the winter of 2011 and 2012 which showed that 57% of all visitors travelled 16km or less to get to the European Site. This places the Neighbourhood Area well within the core catchment of the site. However, of the 33 groups interviewed in November 2012 only two of the groups came from within Coggeshall Parish. In terms of frequency of the 33 groups, 25 groups

39 Colchester Borough Council (November 2012) Habitats Regulations Assessment Survey and Monitoring. Year 3 Interim Report.

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visited the site 2-3 times a month or fewer and none visited the site daily. These statistics show that, although Abberton Reservoir is regularly visited, the number from within the Neighbourhood Area is small.

5.9 Compared to the district as a whole the relatively small increase of 385 dwellings and enhancement of tourist facilities within the Neighbourhood Area is only likely to cause a minimal increase in visitor numbers at the site. Restrictions are also in place to minimise the disturbance caused by visitors including access around the reservoir being restricted, dogs banned from the site and hides provided to cover those watching the bird interest on the reservoir.

5.10 The reserve is a strictly access controlled site due to its use as a water source for Essex, which in itself reduces the recreational pressure on the site. The site is also managed by the RSPB where they have utilised screening and hides upon designated pathways on the edges of the reserve for public visitors to the site. This allows those wishing to utilise the site to be screened from the qualifying species and reducing the disturbance levels within the SPA and Ramsar. There is also a visitor centre which provides education on the site. This site is therefore managed to promote visitors while ensuring disturbance to the site is kept to a minimum. Within the Site Improvement Plan for Abberton Reservoir it also states “Disturbance at ground level is well controlled by Essex & Suffolk Water, though there is occasional trespassing. Disturbance from the air by low-flying civilian and military aircraft occurs several times each year and is more difficult to manage”. The SIP highlights that recreational pressure from visitors on foot is well managed and with the addition of the mitigation already being provided and managed by the RSBP at the site. For the aforementioned reasons the HRA of Braintree District Council Local Plan 2017, concluded no adverse impact upon Abberton Reservoir and therefore it can be concluded that the Coggeshall Neighbourhood Plan will not have an adverse effect upon the integrity of the European site.

5.11 The Blackwater Estuary area is a typical, undeveloped, coastal plain estuarine system with associated open coast mudflats and sandbanks. Sub-tidal areas have a rich invertebrate fauna and there are extensive intertidal mudflats and sandflats. Four different saltmarsh features of European importance are represented as well as large areas of grazing marsh. The site is one of the most important areas for overwintering water birds in the UK and is of international importance for several breeding bird species.

5.12 Two areas within the SPA and Ramsar site were surveyed for visitors, the first Old Hall Marshes and the second Strood Channel. Both have a small carpark; however the majority of visitors walked to the site. This indicates that the sites are mostly used by locals. A single person of the six groups interviewed in 2012 over both sites was from Coggeshall Parish and was visiting the site to bird watch. All four groups at the Strood site were dog walkers and lived locally. The other person from Old Hall Marshes lived locally and was exploring the local footpaths. These areas have relatively low visitor pressure, possibly due to the area being remote and a lack of facilities.

5.13 It is unlikely that the relatively small increase in dwellings within the Neighbourhood Plan will increase the visitor pressure upon areas within the SPA and Ramsar such as those surveyed by Colchester District Council in 2012, if considered on its own. Due to the relative remoteness, small parking areas and lack of visitor facilities, it is likely that the site is self-regulating and may therefore not see a large increase in visitor numbers. Should an increase be seen it is likely that visitors from Coggeshall Parish will only be a very small percentage of this increase.

5.14 The Colne Estuary area is a typical, undeveloped, coastal plain estuarine system with associated open coast mudflats and sandbanks. Sub-tidal areas have a rich invertebrate fauna and there are extensive intertidal mudflats and sandflats. Four different saltmarsh features of European importance are represented as well as large areas of grazing marsh. The site is one of the most important areas for overwintering water birds in the UK and is of international importance for several breeding bird species.

5.15 Two areas within the SPA and Ramsar site were surveyed for visitors in the winter of 2011 and 2012. These areas were Cudmore Grove (a country park adjacent to the SPA) and Brightlingsea Marshes. A total of 43 groups were interviewed at Cudmore and 76 groups at Brightlingsea. The major draw at both sites was dog walking. However, the majority of people at these sites lived close to the site at Cudmore the majority of groups lived in the close village of Mersea or the town of Colchester and at Brightlingsea Marshes the majority lived in Brightlingsea village (45 of 76 groups) and 11 groups in Colchester. Very few visitors came from the Braintree district and no visitors came from the Coggeshall Parish. Although recreational activities are high in this area, the percentage from the Braintree District is very small and from Coggeshall Parish would likely be de minimis.

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5.16 However, recreational pressure is a much wider issue than solely for the Coggeshall Parish and therefore strategic planning to mitigate its effects must be undertaken at higher level. Essex County Council have undertaken the production of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy40 (RAMS) in conjunction with 11 Local Planning Authorities, including Braintree District, in order to mitigate against the ‘in combination’ effects of increased dwellings within the county between 2018 and 2038, upon the coastal European sites e.g. Blackwater estuary SPA & Ramsar, Colne Estuary SPA & Ramsar and the Essex Coast SAC.

5.17 The RAMS sets out measures which will mitigate the effects of the increased recreational disturbance, such as; fencing/waymarking/screening – directing visitors away from sensitive areas and/or providing a screen to minimise impacts; pedestrian and dog access – zoning, prohibited areas and restricted times of access; and the provision of Rangers and Water Rangers to enforce restrictions etc. As well as monitoring through bird and visitor surveys to review effectiveness of the measures.

5.18 These mitigation measures are funded through developer contributions from developments within the Zone of Influence (ZoI). As Coggeshall Parish is within the ZoI the developers of the allocated sites will be required to pay a tariff per dwelling of £122.30 towards funding the strategic mitigation measures for the coastal European sites.

5.19 Policy P19 within the Neighbourhood Plan states that “Financial contributions will be sought for all residential development, which falls within the zone of influence, towards a package of measures to avoid and mitigate likely significant adverse effects” upon the Essex coast European sites.

5.20 In addition, it is also required by Braintree District Council that residential development sites provide access to natural greenspace. The Braintree Local Plan Policy LPP 53 gives protection to and provision for open space for sport and recreation. A table within the supporting text sets out “what type and when provision would be required on site”. The table states that any development site with 20 or more dwellings will be required to provide amenity/natural green space on site; however, the Policy also state “For small sites where on-site provision is impractical, consideration will be given to opportunities for off-site provision or improvements within the ward or an adjacent ward”. The Local Plan does not, however, prescribe a specific rate of natural greenspace provision within the policy.

5.21 The HRA of the submitted Local Plan (dated May 2017) recommends inclusion of reference to the role of open space and green infrastructure providing alternatives to European sites and it is therefore recommended that wording be inserted into Policy P11 Open Space to comply with the Policy LPP 53 and this recommendation. Recommended wording below:

• Sites developing 20 or more dwellings will be required to provide amenity/natural green space in line with Policy LPP 53 of the Braintree District Local Plan and recommendations of the May 2017 Local Plan Section 2 HRA, as an alternative to European sites. The provision of natural green space is recommended within site where possible. However, where this is impractical provision of the natural green space can be provided off site at a suitable location. This should be undertaken through developer contributions in line with Policy P18 which states “any residential development proposals will be required to contribute towards provision of local infrastructure such as public open space” through the Community Infrastructure Levy (CIL).

5.22 With this text included within the Coggeshall Neighbourhood Plan it can be concluded that for the Essex Coast European sites that the Neighbourhood Plan will not result in adverse effects on the integrity of the European site.

40 Essex County Council, March 2019. Essex Coast Recreational Disturbance Avoidance and Mitigation Strategy (RAMS). Habitats Regulations Assessment Strategy Document 2018 – 2038. Essex County Council

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6. Conclusions and Recommendations

6.1 This assessment undertook both Screening and Appropriate Assessment of the policies and any allocations within the Coggeshall Neighbourhood Plan.

6.2 The European designated sites considered within the Appropriate Assessment for impact pathways that could not be screened out at the screening stage were:

• Abberton Reservoir SPA and Ramsar

• Blackwater Estuary (Mid-Essex Coast Phase 4) SPA and Ramsar

• Colne Estuary (Mix-Essex Coast Phase 2) SPA and Ramsar

• Essex Estuaries SAC

6.3 Impact pathways considered during the screening were: recreational pressure, water quality and air pollution. Water quality and air pollution were screened out at the Screening stage due to a lack of linking impact pathways. Recreational pressure could not be screened out at the Screening stage and was therefore further discussed within the Appropriate Assessment.

6.4 In relation to the discussions of recreational pressure within the Appropriate assessment it was recommended that, in line with the recommendations of most recent HRA of the Braintree District Local Plan and Local Plan Policy 53 that some text providing reference to the role of open space and green infrastructure be added into Policy P11 Open Space. The recommended wording is below:

6.5 Provided the above recommendations are included within the Neighbourhood Plan it can be concluded that the Plan document will not result in an adverse effect on the integrity of any European sites either alone or in combination.

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Appendix A European Site Background Information Abberton Reservoir SPA and Ramsar Introduction

Abberton Reservoir is a large water storage reservoir close to the Essex coast. It is one of the most important reservoirs in the country for overwintering waterfowl and also supports substantial aggregations of moulting birds in early autumn and a large colony of tree-nesting cormorants. Causeways divide the reservoir into three sections. Currently the water level of the main, eastern section is being raised by 3 metres to increase storage capacity. As part of the level-raising scheme, the original concrete banks have been removed and the shoreline re-profiled, creating extensive new areas of shallow wetland habitat for the site’s waterfowl.

Conservation Objectives41

With regard to the SPA and the individual species and/or assemblage of species for which the site has been classified (the ‘Qualifying Features’ listed below), and subject to natural change;

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

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

Qualifying Features

The features for which the site is designated as a SPA42 are:

This site qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive:

Over winter;

• Golden Plover Pluvialis apricaria, 3,714 individuals representing at least 1.5% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6)

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European importance of the following migratory species:

During the breeding season;

• Cormorant Phalacrocorax carbo, 490 pairs representing at least 1.2% of the breeding Northwestern Europe population (5 year mean, 1993-1997)

Over winter;

• Gadwall Anas strepera, 518 individuals representing at least 1.7% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6) • Shoveler Anas clypeata, 654 individuals representing at least 1.6% of the wintering Northwestern/Central Europe population (5 year peak mean 1991/2 - 1995/6)

41 http://publications.naturalengland.org.uk/publication/5673002612031488 [Accessed 24 May 2019] 42 http://jncc.defra.gov.uk/page-2013 [Accessed 24 May 2019]

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• Teal Anas crecca, 5,326 individuals representing at least 1.3% of the wintering Northwestern Europe population

Assemblage qualification: A wetland of international importance.

The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000 waterfowl

Over winter, the area regularly supports 39,155 individual waterfowl (5 year peak mean 1991/2 - 1995/6) including: Black-tailed Godwit Limosa limosa islandica, Lapwing Vanellus vanellus, Coot Fulica atra, Goldeneye Bucephala clangula, Tufted Duck Aythya fuligula, Pochard Aythya ferina, Pintail Anas acuta, Wigeon Anas penelope, Cormorant Phalacrocorax carbo, Great Crested Grebe Podiceps cristatus, Shoveler Anas clypeata, Teal Anas crecca, Gadwall Anas strepera, Golden Plover Pluvialis apricaria.

The features for which the site is designated as a Ramsar43 are:

Ramsar Criterion 5

Assemblage of International importance:

Species with peak counts in the winter:

• 23,787 waterfowl (5 year peak mean 1998/99 – 2002/03)

Ramsar Criterion 6 – Species / populations occurring at levels of international importance

Qualifying species / populations (as identified at designation):

Species with peak counts in spring / autumn:

• Gadwall (Anas Strepera strepera), NE Europe. 550 individuals, representing an average of 3.2% of the GB population (5 year peak mean 1998/99 – 2002/03) • Northern Shoveler (Anas clypeata), NW & C Europe. 377 individuals, representing an average of 2.5% of the GB population (5 year peak mean 1998/99 – 2002/03)

Species with peak counts in winter:

• Eurasian wigeon (Anas penelope), NW Europe. 2,888 individuals, representing an average of 1.6% of the population (5 year peak means 1991/92 – 1995/96)

Species / populations identified subsequent to designation for possible future consideration under Criterion 6/

Species with peak counts in the spring / autum:

• Mute swan (Cygna olor), Britain. 387 individuals, representing an average of 1% of the population (5 year peak mean 1998/99 – 2002/03) • Common pochard (Anas ferina), NE & NW Europe. 4,373 individuals, representing an average of 1.2% of the population (5 year peak mean 1998/99 – 2002/03)

Environmental vulnerabilities related to the Plan44

• Siltation • Public access / disturbance • Planning permission: general • Changes in species distribution • Bird strike • Water pollution • Air pollution: risk of atmospheric nitrogen deposition

43 http://jncc.defra.gov.uk/pdf/RIS/UK11001.pdf [Accessed 24 May 2019] 44 http://publications.naturalengland.org.uk/publication/5195034185957376 [Accessed 24 May 2019]

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Blackwater Estuary (Mid Essex Coast Phase 4) SPA and Ramsar Introduction

The area is a typical, undeveloped, coastal plain estuarine system with associated open coast mudflats and sandbanks. Sub-tidal areas have a rich invertebrate fauna and there are extensive intertidal mudflats and sandflats. Four different saltmarsh features of European importance are represented as well as large areas of grazing marsh. The site is one of the most important areas for overwintering waterbirds in the UK and is of international importance for several breeding bird species.

Conservation Objectives45

With regard to the SPA and the individual species and/or assemblage of species for which the site has been classified (the ‘Qualifying Features’ listed below), and subject to natural change;

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

Qualifying Features

The features for which the site is designated as a SPA46 are:

This site qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive:

During the breeding season;

• Little Tern Sterna albifrons, 36 pairs representing at least 1.5% of the breeding population in Great Britain (Count as at 1997)

Over winter;

• Avocet Recurvirostra avosetta, 76 individuals representing at least 6.0% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6) • Golden Plover Pluvialis apricaria, 7,247 individuals representing at least 2.9% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6) • Hen Harrier Circus cyaneus, 4 individuals representing up to 0.5% of the wintering population in Great Britain (5 year mean, 1993/94-94/95, 1996/7-98/99) • Ruff Philomachus pugnax, 51 individuals representing up to 7.3% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6)

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European importance of the following migratory species:

On passage;

• Ringed Plover Charadrius hiaticula, 955 individuals representing up to 1.9% of the Europe/Northern Africa - wintering population (5 year peak mean 1991/2 - 1995/6)

45 http://publications.naturalengland.org.uk/publication/4888693533835264 [Accessed 24 May 2019] 46 http://jncc.defra.gov.uk/default.aspx?page=2020 [Accessed 24 May 2019]

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Over winter;

• Black-tailed Godwit Limosa limosa islandica, 1,280 individuals representing up to 1.8% of the wintering Iceland - breeding population (5 year peak mean 1991/2 - 1995/6) • Dark-bellied Brent Goose Branta bernicla bernicla, 15,392 individuals representing up to 5.1% of the wintering Western Siberia/Western Europe population (5 year peak mean 1991/2 - 1995/6) • Dunlin Calidris alpina alpina, 33,267 individuals representing up to 2.4% of the wintering Northern Siberia/Europe/Western Africa population (5 year peak mean 1991/2 - 1995/6) • Grey Plover Pluvialis squatarola, 5,090 individuals representing up to 3.4% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6) • Redshank Tringa totanus, 4,015 individuals representing up to 2.7% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6) • Ringed Plover Charadrius hiaticula, 600 individuals representing up to 1.2% of the wintering Europe/Northern Africa - wintering population (WeBS/Peter Clement) • Shelduck Tadorna tadorna, 4,594 individuals representing up to 1.5% of the wintering Northwestern Europe population (5 year peak mean 1991/2 - 1995/6)

Assemblage qualification: A wetland of international importance.

The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000 waterfowl

Over winter, the area regularly supports 109,815 individual waterfowl (5 year peak mean 1991/2 - 1995/6) including: Great Crested Grebe Podiceps cristatus, Golden Plover Pluvialis apricaria, Ruff Philomachus pugnax, Dark-bellied Brent Goose Branta bernicla bernicla, Shelduck Tadorna tadorna, Ringed Plover Charadrius hiaticula, Grey Plover Pluvialis squatarola, Dunlin Calidris alpina alpina, Avocet Recurvirostra avosetta, Redshank Tringa totanus, Curlew Numenius arquata, Cormorant Phalacrocorax carbo, Wigeon Anas penelope, Teal Anas crecca, Pintail Anas acuta, Shoveler Anas clypeata, Goldeneye Bucephala clangula, Red-breasted Merganser Mergus serrator, Lapwing Vanellus vanellus, Black-tailed Godwit Limosa limosa islandica.

The features for which the site is designated as a Ramsar47 are:

Criterion 1

Qualifies by virtue of the extent and diversity of saltmarsh habitat present. This site, and the four others in the Mid- Essex Coast complex, includes a total of 3,237 ha that represent 70% of the saltmarsh habitat in Essex and 7% of the total area of saltmarsh in Britain.

Criterion 2

The invertebrate fauna is well represented and includes at least 16 British Red Data Book species. In descending order of rarity these are: Endangered: a water beetle Paracymus aeneus; Vulnerable: a damselfly Lestes dryas, the flies Aedes flavescens, Erioptera bivittata, Hybomitra expollicata and the spiders Heliophanus auratus and Trichopterna cito; Rare: the beetles Baris scolopacea, Philonthus punctus, Graptodytes bilineatus and Malachius vulneratus, the flies Campsicemus magius and Myopites eximia, the moths Idaea ochrata and Malacosoma castrensis and the spider Euophrys.

Criterion 3

This site supports a full and representative sequences of saltmarsh plant communities covering the range of variation in Britain.

Criterion 5

Assemblage of international importance:

Species with peak counts in the winter:

• 105,061 waterfowl (5 year peak mean 1998/99 – 2002/03)

47 http://jncc.defra.gov.uk/pdf/RIS/UK11007.pdf [Accessed 24 May 2019]

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Criterion 6 – Species / populations occurring at levels of international importance

Qualifying species with peak counts in winter:

• Dark-belled brent goose (Branta bernicla bernicla). 8,689 individuals, representing an average of 4% of the population (5 year peak mean 1998/99 – 2002/03) • Grey plover (Pluvialis squatarola) E Atlantic/W Africa – wintering. 4,215 individuals, representing an average of 1.7% of the population (5 year peak mean 1998/99 -2002/03) • Dunlin (Calisdris alpina alpina) W Siberia/W Europe. 27,655 individuals, representing an average of 2% of the population (5 year peak mean 1998/99 – 2002/03) • Black-tailed godwit (Limosa limosa islandica) Iceland/W Europe. 2,174 individuals, representing an average of 6.2% of the population (5 year peak mean 1998/99 – 2002/03)

Species populations identified subsequent to designation for possible future consideration under Criterion 6

Species with peak count in winter:

• Common shelduck (Tadorna tadorna) NW Europe. 3,141 individuals, representing an average of 1% of the population (5 year peak mean 1998/99 – 2002/03) • European golden plover (Pluvialis apricaria apricaria) P. a. altifrons Iceland & Faroes/E Atlantic. 16,083 individuals, representing an average of 1.7% of the populations (5 year peak mean 1998/99 – 2002/03) • Common redshank (Tringa tetanus totanus). 4,169 individuals, representing an average of 1/6% of the population (5 year peak mean 1998/99 – 2002/03)

Environmental vulnerabilities related to the Plan48

• Coastal squeeze • Public access / disturbance • Planning permission: general • Change in species distributions • Invasive species • Fisheries: recreational marine and estuarine • Fisheries: commercial marine and estuarine • Air pollution: risk of atmospheric nitrogen deposition

Colne Estuary (Mid Essex Coast Phase 2) SPA and Ramsar Introduction

Conservation Objectives49

With regard to the SPA and the individual species and/or assemblage of species for which the site has been classified (the ‘Qualifying Features’ listed below), and subject to natural change;

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

• The extent and distribution of the habitats of the qualifying features • The structure and function of the habitats of the qualifying features

48 http://publications.naturalengland.org.uk/publication/5459956190937088 [Accessed 24 May 2019] 49 http://publications.naturalengland.org.uk/publication/5664206519009280 [Accessed 24 May 2019]

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

Qualifying Features

The features for which the site is designated as a SPA50 are:

This site qualifies under Article 4.1 of the Directive (79/409/EEC) by supporting populations of European importance of the following species listed on Annex I of the Directive:

During the breeding season;

Little Tern Sterna albifrons, 38 pairs representing at least 1.6% of the breeding population in Great Britain (5 year mean, 1992-1996)

Over winter;

Avocet Recurvirostra avosetta, 75 individuals representing at least 5.9% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6)

Golden Plover Pluvialis apricaria, 2,530 individuals representing at least 1.0% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6)

Hen Harrier Circus cyaneus, 4 individuals representing at least 0.5% of the wintering population in Great Britain (5 year mean 1994/95-1998/99)

This site also qualifies under Article 4.2 of the Directive (79/409/EEC) by supporting populations of European importance of the following migratory species:

Over winter;

Dark-bellied Brent Goose Branta bernicla bernicla, 4,907 individuals representing at least 1.6% of the wintering Western Siberia/Western Europe population (5 year peak mean 1991/2 - 1995/6)

Redshank Tringa totanus, 2,077 individuals representing at least 1.4% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6)

Assemblage qualification: A wetland of international importance.

The area qualifies under Article 4.2 of the Directive (79/409/EEC) by regularly supporting at least 20,000 waterfowl

Over winter, the area regularly supports 38,548 individual waterfowl (5 year peak mean 1991/2 - 1995/6) including: Black-tailed Godwit Limosa limosa islandica, Dunlin Calidris alpina alpina, Lapwing Vanellus vanellus, Grey Plover Pluvialis squatarola, Ringed Plover Charadrius hiaticula, Shelduck Tadorna tadorna, Cormorant Phalacrocorax carbo, Great Crested Grebe Podiceps cristatus, Redshank Tringa totanus, Dark-bellied Brent Goose Branta bernicla bernicla, Golden Plover Pluvialis apricaria, Avocet Recurvirostra avosetta.

The features for which the site is designated as a Ramsar51 are:

Criterion 1

The site is important due to the extent and diversity of salt marsh present. This site, and the four other sites in Mid- Essex Coast complex include a total of 3,237 ha, that represents 70% of the salt marsh habitat in Essex and 7% of the total saltmarsh in Britain.

Criterion 2

The site supports 12 species of nationally scarce plants and at least 38 British Red Data Book invertebrate species

50 http://jncc.defra.gov.uk/default.aspx?page=2018 [Accessed 24 May 2019] 51 http://jncc.defra.gov.uk/pdf/RIS/UK11015.pdf [Accessed 24 May 2019]

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Criterion 3

This site supports a full and representative sequence of saltmarsh plant communities covering the range of variation in Britain.

Criterion 5

Assemblage of international importance

Species with peak counts in the winter:

• 32,041 water fowl (5 year peak mean 2998/99 – 2002/03)

Criterion 6 – Species / populations occurring at levels of international importance

Qualifying species / populations (as identified at designation):

Species with peak counts in the winter:

• Dark-bellied brent goose, (Branta bernicla bernicla). 3,165 individuals, representing an average of 1.4% of the population (5 year peak mean 1998/99 – 2002/03) • Common redshank (Tringa tetanus totanus). 1,624 individuals, representing an average of 1.3% of the GB population (5 year peak mean 1998/99 0 2002/03)

Species /populations identified subsequent to designation for possible future consideration under Criterion 6

Species with peak counts in the winter:

• Black-tailed godwit (Limosa limosa islandica) Iceland / W Europe. 402 individuals, representing an average of 1.1% of the population (5 year peak mean 19980/99 – 2002/03)

Environmental vulnerabilities related to the Plan52

Essex Estuaries SAC Introduction

Conservation Objectives53

With regard to the SAC and the natural habitats and/or species for which the site has been designated (the ‘Qualifying Features’ listed below), and subject to natural change;

52 http://publications.naturalengland.org.uk/publication/5459956190937088 [Accessed 24 May 2019] 53 http://publications.naturalengland.org.uk/publication/4781199427895296 [Accessed 24 May 2019]

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

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

Qualifying Features54

The features for which the site is designated as a SAC are:

Annex I habitats that are a primary reason for the selection of this site:

• Estuaries • Mudflats and sandflats not covered by seawater at low tide (intertidal mudflats and sandflats) • Glasswort and other annuals colonising mud and sand • Cord-grass swards • Atlantic salt meadows • Mediterranean saltmarsh scrub

Annex I habitats present as a qualifying feature but not a primary reason for selection of this site:

• Sandbanks which are slightly covered by sea water all the time (subtidal sandbanks)

Environmental vulnerabilities related to the Plan55

54 http://jncc.defra.gov.uk/protectedsites/sacselection/sac.asp?EUCode=UK0013690 [Accessed 24 May 2019] 55 http://publications.naturalengland.org.uk/publication/5459956190937088 [Accessed 24 May 2019]

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Appendix B Policy Screening

Policy Description Test of Likely Significant Effects P.1. – Meeting the Housing To meet the future housing needs of the Parish, the following sites are allocated for Likely Significant Effect Need residential development (identified on the proposals map): • P2: Tey Road, around 10 dwellings. Four sites have been allocated for housing development with a • P3: The Dutch Nursery, around 60 dwellings. total of 385 houses. • P4: Cook Field, East Street, around 15 dwellings. • P5: Land North of Colchester Road, around 300 dwellings. Potential impact pathways from the development of houses within the parish include: In addition to the sites listed above, the Parish Council will support the development of brown-field land and infill opportunities within the settlement boundaries for • Recreational pressure residential use, subject to the assessment and consideration of site-specific • Water quality circumstances and the requirements of other policies within this Plan. • Air pollution

Proposals for residential development will be supported where they: I. Include a range of housing types, sizes and tenures appropriate for the location and size of the site, which meet the needs of the Parish as demonstrated by up to date information and surveys on housing needs. It will be expected that the needs of first time buyers and older people are particularly addressed; II. Protect and enhance the distinctive character of Coggeshall Parish and the distinct identity of Coggeshall village; III. Are located within settlement boundaries, and appropriate in scale and design; IV. Facilitate a cohesive community by providing affordable housing designed to be integral to the development as a whole. The types of affordable housing included within the development must be identified, together with an explanation of how they will be delivered as part of the scheme. Residential proposals must meet Braintree’s affordable housing requirement of 40% unless they are fully justified by an open book assessment of viability; V. Are subject to a local connection, meaning that people with a strong local connection to the Parish and whose needs are not met by the open market will be the first to be offered tenancy or shared ownership of the homes. The Parish Council will work with BDC to consider how local residents can gain access to affordable housing within the Parish, where possible seeking the prioritisation of social housing within the Parish to local residents and family members. In this context, a strong local connection means applicants who

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satisfy Braintree District Council’s Local Connection Criteria for Local Housing Needs Schemes; VI. Include, where viable, provision for self-build or community housing e.g. alms housing; VII. Include renewable and low carbon energy generation technology, which supports the sustainable energy needs of future residents; VIII. Include where appropriate, public charging points for electric vehicles in parking areas and encourage, wherever feasible, walking or cycling; IX. Improve 'way finding' throughout the Parish, by taking every available opportunity to incorporate directional signage to places of interest as part of development schemes.

Housing development will be contained within the defined Village Envelope of Coggeshall Parish (as defined by the adopted Development Plan), with the exception of proposals for sites allocated for development in the adopted Development Plan, or for Rural Exception Schemes which comply with policies in the adopted Development Plan. P.2. Allocated Site: Tey Housing density & design Likely Significant Effects Road I. To meet the future housing needs of the Parish, the Tey Road site as This is one of the sites allocated in Policy P.1. Around 10 dwellings identified on the proposals map will be allocated for around 10 dwellings. at the Tey Road Site. II. The design and layout of the site will incorporate mitigation measures to

combat noise and air pollution from the A120. III. The housing development will respect the existing homes on Monksdown Potential impact pathways from the development of houses within Road and Tey Road. this site include: IV. Housing layout and landscape design will respect the landscape setting and employ a mix of house types and tenure to create a distinctive character and • Recreational pressure encourage community development and Integration with its immediate • Water quality neighbours and the village. • Air pollution

Green infrastructure & the natural environment.

I. The development proposals must reinforce the boundary planting to the A120 transport corridor and within the site to develop links to the north of the parish and the fields south of Tey Road as a part of the Parish’s green infrastructure links. The development proposals must Incorporate Sustainable Drainage Systems (SuDS) into the landscape and built form to address flood and drought mitigation. P.3. – Allocated Site: The Housing density & design Likely Significant Effects Dutch Nursery

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I. To meet the future housing needs of the Parish, The Dutch Nursery site as This is one of the sites allocated in Policy P.1. Around 60dwellings identified on the proposals map will be allocated for around 60 dwellings. at the Dutch Nursery Site. II. Housing development adjacent to West Street must respect and reflect the

historic streetscape. III. Housing layout and character to the rear of the site must respect the Potential impact pathways from the development of houses within topography of the land, the landscape setting and employ a mix of house this site include: types and tenure to create a distinctive character and encourage community development. • Recreational pressure • Water quality Green infrastructure & the natural environment. • Air pollution

I. Development proposals must incorporate a new Local Green Space to act as visual and physical link between West Street and the Blackwater valley as part of policy P.6 Protecting and Enhancing Green and Blue Infrastructure and help meet the deficit identified in BDC Open Spaces Action Plan 2017. II. Development proposals must retain the existing semi mature cedar on West Street as part of policy P.14 Design Management within the Built Environment.

i. The Blackwater valley floodplain to be incorporated into the proposals as a local green space with a ‘natural’ character which reflects the existing river corridor and encourages wildlife. P.4. – Allocated Site: Cook Housing density Likely Significant Effects Field I. To meet the future housing needs of the Parish, Cook Field as identified on This is one of the sites allocated in Policy P.1. Around 15 dwellings the proposals map will be allocated for around 15 dwellings. at the Cook Field site. II. Proposals for housing development must respect and reflect the historic

landscape setting. III. Housing layout and character to employ a mix of house types and tenure to Potential impact pathways from the development of houses within create a distinctive character and encourage community development. this site include:

The Essex Way, the rural landscape setting and cross-field views. • Recreational pressure • Water quality I. The development proposal must protect the Essex Way in its rural landscape • Air pollution setting and protect the landscape setting of the conservation area. An area of land adjacent to the Essex Way will be designated as local green space acting as a buffer between new development and the PRoW and retain cross field views in accordance with Figure 6 - Local Green Spaces Proposals Plan. The new local green space will increase the Parish’s green open space allocation to provide informal open space as identified and required in the BDC Open Spaces Action Plan 2017.

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Green infrastructure & the natural environment

Development proposals must enhance the PRoW as part of the Parish’s green infrastructure, as identified on Figure 3 - The Green and Blue Infrastructure Proposals Plan. The new local green space will incorporate measures to enable wildlife to flourish. The mature planting along East Street will be retained as part of development proposal. P.5. – Allocated Site: Land Housing Density & Design Likely Significant Effects North of Colchester Road I. To meet the future housing needs of the Parish, the Colchester Road site as This is one of the sites allocated in Policy P.1. Around 300 dwellings identified on the proposals map will be allocated for around 300 dwellings. at Land North of Colchester Road. II. Development proposals must incorporate a sensitive approach to design

and construction which will respect, conserve and enhance local residential amenity, local character, landscape setting and the local environment, whilst Potential impact pathways from the development of houses within mitigating impacts on local services and facilities. this site include: III. The design and layout of the development must employ a mix of house types, sizes and tenure across the site to meet the evidenced needs of the • Recreational pressure Parish. Proposals should incorporate a variety of road layouts including cul- • Water quality de-sacs and squares to create a distinctive character and encourage social • Air pollution interaction and community development both within the development and with immediate neighbours and the wider village. IV. Housing design should be adaptable to cater for the needs of disabled and elderly family members to encourage the development of an inclusive community. V. Housing layout will incorporate 3% of the total number of homes as self-build plots distributed throughout the site and at key locations. These plots will provide unique buildings to contribute towards the creation of different character areas within the development. VI. Housing density must vary across the developable area to contribute towards the creation of different character areas within the development. VII. Development proposals must mitigate the visual impact of the development and ensure a clear and harmonious relationship between the development and the rural surrounds. VIII. Development proposals must demonstrate how they will respect, conserve and enhance the character, appearance and function of the Coggeshall Conservation Area. Proposals must ensure that long distance views of St Peter ad Vincula church both from within and outside the site will not be obscured.

Masterplanning and Review

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I. Detailed proposals for the site should be in accordance with a Masterplan which has been developed collaboratively between the developer, the local community, infrastructure providers, the local planning authority and other stakeholders. II. The production of the Masterplan should be informed by a Quality Review Panel appointed by the local planning authority, in consultation with the Parish Council. III. The Masterplan shall be subject to public consultation prior to finalisation and should be capable of being adopted as guidance and a material planning consideration by the local planning authority.

Green Infrastructure & the Natural Environment.

I. Development proposals must incorporate a Local Green Space along the line of the watercourse to protect and enhance the landscape setting of the Essex Way and act as a visual and physical link between St Peter’s Road and the north of the Parish. II. Development proposals must incorporate Local Green Space on the southern side of Tey Road to mitigate against the impact of the development to existing properties. This must create an attractive, safe, green cycleway and footpath link between Colne Road and the development and the PRoW at the North west corner of the site. III. Development proposals must prioritise the implementation of a sympathetic landscape scheme with a unified approach to early delivery in order to improve the quality and effectiveness of mitigation proposals. IV. Development proposals must incorporate SuDS into the landscape and built form to address flood and drought mitigation. V. Development proposals must incorporate natural flood management techniques to the watercourse running through the centre of the site and un- culvert the stream to address flood and drought mitigation and improve the biodiversity potential of this blue infrastructure link. VI. Development proposals must incorporate green infrastructure links between all areas of green open space so that wildlife may successfully move between habitats and feeding grounds. VII. Landscape design proposals must incorporate landscape types and vegetation to provide enhanced habitat for wildlife and enhance biodiversity. VIII. Streetscapes should be softened with appropriate tree planting.

Pollution

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I. The design and layout of the site will incorporate mitigation measures to combat air pollution from the A120. II. A detailed noise mitigation scheme will be submitted to demonstrate that acceptable noise levels will be achieved across the site. III. A lighting design strategy will be submitted to reduce the impact of light pollution and for light sensitive biodiversity (i.e. bats).

Public Infrastructure

I. The design and layout will enhance the landscape setting of the public footpath, the Essex Way from St Peter’s Road and incorporate measures to enable and encourage the safe crossing by pedestrians, cyclists and animals over or under the A120. II. The design and layout will incorporate pedestrian and cycle way access points to enable connectivity with the village centre, safe pedestrian and cycle access to local schools and enhanced access to public transport. III. Development proposals must incorporate multiple access points in order to facilitate permeability, integration with the wider village and reduce the potential for vehicular congestion on Colchester Road. IV. The design and layout will incorporate a ‘pump’ cycle track or skateboard park to meet the needs of the Parish. The development will include provision for the growing elderly population in the form of a care home, sheltered housing or alms housing. P.6. – Meeting Business Development proposals that create local jobs and enhance the local Likely Significant Effect Need economy will be supported where they: This policy encourages new business development and enhanced I. Encourage new employment opportunities within the Parish which would tourism facilities within the Parish, although it does not give a potentially reduce levels of out-commuting; quantum or location of the development. II. Provide benefits to the local economy and community which outweigh any

harmful impacts of the proposals; III. Respect the character of the environment and landscape in which they are An increase I business development has the potential to create located; greater numbers of cars journeys commuting in and out of the IV. Are located in areas which are accessible to the surrounding transport Parish and therefore has the potential to increase air pollution network without having a significantly detrimental impact on levels of traffic pressure upon European sites should they be within 200m of a or congestion in the Parish; major journey to work route. V. Will not detrimentally impact upon nearby residential amenity, health and

quality of life of existing residents; VI. Will not have a significantly detrimental impact on heritage assets within the Increases in tourism facilities also has the potential to increase the Parish. recreational pressure of European sites should these be within the catchment area of the Parish.

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New businesses, enhanced tourism facilities and economic growth in the Parish should be encouraged by:

I. Supporting the separation of existing shops, units, and offices into smaller units where this will improve the viability of the premises; II. Seeking improvements to infrastructure services in the Parish to the benefit of the local economy, particularly related to high speed broadband and mobile phone connectivity; III. Supporting the 'sense of place' within Coggeshall village by ensuring that street furniture and shop fronts respond to the visual character of the surroundings.

Proposals which result in the loss of retail (Class A uses) or business (Class B uses) premises will only be favourably considered where:

I. The present use and activity on site significantly harms the character and amenity of the adjacent area, and the proposed development would be more harmonious with its surroundings; or II. The site has been marketed effectively for 12 months at a rate which is comparable to local market value for its existing use, or as a redevelopment opportunity for other Class A or Class B uses or Sui Generis use of an employment nature, and it can be demonstrated that the continuous use of the site for Class A or Class B uses is no longer viable, taking into account the site’s existing and potential long-term market demand for an employment use.

Class A – Shops, financial and professional services, restaurants and cafes, drinking establishments, hot food takeaways.

Class B – Business, general industrial and storage and distribution. P.7. – Protecting and Development proposals must protect, enhance and, where possible, increase the No Likely Significant Effect Enhancing Green and provision of green and blue infrastructure within the Parish. All proposals should seek Blue Infrastructure and to deliver net biodiversity gain, in addition to protecting existing habitats and species. This is a policy focused on protecting and enhancing green the Natural Environment Any proposals which negatively affect, or have the potential to negatively affect, green infrastructure. Development proposals will only be supported and blue infrastructure must demonstrate that any negative impacts on access for where appropriate mitigation measures can be implemented to recreation, biodiversity (including flora and fauna) and local wildlife habitats and improve the provision of green infrastructure and improve corridors, will be adequately mitigated. biodiversity, wildlife habitats and corridors in the Parish.

Therefore no impact pathways are present within this policy

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The Plan seeks to protect and enhance the following green and blue infrastructure features within the Parish, identified in figures 3&4.

Development proposals which are likely to have a negative impact upon these features will only be permitted where the benefits of development clearly outweigh any negative impacts, or where appropriate mitigation measures can be implemented which result in an overall improved provision of green and blue infrastructure and overall benefits to biodiversity, wildlife habitats and corridors within the Parish.

Proposals for new areas of green and blue infrastructure should seek to incorporate pedestrian, cycle and bridleway access, providing connections to existing areas of green and blue infrastructure and pedestrian, cycle and bridleway networks.

All development proposals will seek to enhance biodiversity and the natural environment wherever possible. Significant development proposals which are likely to have a direct or indirect adverse impact on local biodiversity, habitat, wildlife of a Local Nature Reserve or protected species, must provide an independent survey report, which is supported by Braintree District Council’s Ecological Adviser, and demonstrates that:

I. There are no alternatives with less harmful impacts; or II. That appropriate mitigation measures or, as a last resort, compensation measures, can be provided to achieve a net enhancement to the site’s biodiversity.

i. Surveys or assessments, including Phase 1 Habitat Surveys, which accompany development proposals, should be undertaken at an appropriate time of year to reduce the need for repetition. Some surveys, however, may need to be repeated for species throughout the year, if so required. Surveys must include proposals for the measures that will be taken by way of appropriate mitigation to minimise and compensate for any likely impact the development may have on them, in accordance with the requirements of the licence from Natural England. P.8. – Green Coalescence The following locations (identified on Green Coalescence Buffers on the Proposals No Likely Significant Effect Buffers Map, figure 5) are designated as Green Coalescence Buffers: This policy focuses on protecting the green buffers around the I. GCB1: Little Nunty’s - 500m radius from the centre of the hamlet. villages within the Parish boundaries. Developments will not be II. GCB2: Land north of West Street. supported where the create a coalescence between settlements.

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III. GCB3: Land south of West Street -‘The Vineyard’. IV. GCB4: Lands adjacent to the Colchester Road, Surrex. Although this policy does support development within the Parish, it V. GCB5: Land to the east & west of Kelvedon Rd between Coggeshall Hamlet merely sets out the boundaries for this development rather than and Coggeshall. Excluding the PC land and allotment. allocating specific sites or a quantum of housing.

Development proposals within the green coalescence buffer area which contribute Therefore no impact pathways are present within this policy. towards coalescence between the settlements will not be supported.

Development proposals within the green coalescence buffer area must:

I. Protect and enhance the landscape character, setting, amenity value, ecology, heritage assets, and recreational assets located within green coalescence buffer areas; II. Be of a design, density and layout which minimises the potential for coalescence and consolidation between built areas; III. Preserve the rural setting of settlements within the Parish; IV. Provide landscaping which minimises the visual impact of the proposed development, and includes tree planting and vegetation which is predominantly native and consistent with flora in the surrounding area; i. Include an assessment of the local landscape and physical separation between settlements as part of any application, to demonstrate that the development is located in an area which has the least detrimental impact to the character of the countryside and does not significantly reduce the visually sensitive buffer between settlements or groups of houses. P.9. – Identifying Local The following sites (identified on the proposals map Figure 6) are designated as Local No Likely Significant Effects Green Spaces Green Spaces: This policy identifies five areas of local green space for the Parish. • LGS 1: Land at Vicarage Field. • LGS 2: Land at Cook Field, West. This policy is a positive policy as well-designed local green spaces • LGS 3: Land at The Dutch Nursery West (Pissing Gutter Field). have the potential to divert recreational pressure away from • LGS 4: Land off Colchester Road, south and north of the Essex Way. European sites. LGS 5: Land south of Tey Road. Therefore there are no impact pathways within this Policy. P.10. – Green Amenity The following locations (identified on Green Amenity Areas Proposals Plan, No Likely Significant Effect Areas figure 7) are designated as Green Amenity Areas: This policy is focused on protecting local amenity areas. • GAA1: Land to the east and west of Marks Hall Road. Development will not be supported in these areas should it have a • GAA2: Land to the west of Coggeshall Hamlet incorporating the cricket field. detrimental impact on amenity value and quality of the natural environment among other factors.

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• GAA3: Lands to the east of the Essex Way incorporating the western section of Cook Field. This policy does not allocate land this land for development nor • GAA4: Land north of Abbey Lane. provide a quantum of housing, merely sets out the bounds for • GAA5: Valley north & south of the Blackwater including agricultural land development proposals within these areas. rising to the Essex Way.

• GAA6: Land south of West Street, Coggeshall Town football field and associated land. Therefore there are no impact pathways within this Policy.

Development proposals within Green Amenity Areas which would have a detrimental impact on amenity value, quality of the natural environment, landscape setting, character, areas of historical importance, wildlife corridors and accessibility to the Green Amenity Areas will generally not be supported.

Development proposals within Green Amenity Areas must:

I. Protect and enhance the landscape character, setting, amenity value, ecology, heritage assets, and recreational assets located within Green Amenity Areas; i. Provide landscaping which minimises the visual impact of the proposed development, and includes tree planting and vegetation which is predominantly native and consistent with flora within the Green Amenity Area. P.11. – Open Space Proposals for new open space and / or proposals which impact existing areas of open No Likely Significant Effect space will be supported where they: This policy is a positive policy focused on protecting and enhancing I. Increase and enhance public open space for the benefit of the community; areas of opens space and providing new open space. Proposals II. Identify and address the needs of the local community to provide a variety which detrimentally impact the uses of these open spaces will not of active and passive recreational opportunities for all age groups; be supported. III. Increase footpath, bridleway and cycle way connections to develop safe and attractive routes around the Parish, and to the village centre and the hamlets; Therefore there are no impact pathways within this policy. IV. Seek to offer a variety of design solutions to develop a sense of place and respond to the surrounding landscape setting; V. Incorporate measures to increase habitat and / or food sources for wildlife; VI. Increase connections between open spaces using appropriate planting and boundary treatments to enable migrating wildlife to move between different areas of the Parish; VII. Incorporate measures to enable wildlife to flourish within built up areas.

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Open space areas within local schools should be improved. Projects which provide additional areas of open space within local schools will be supported.

Proposed & existing Government funded schools within the Parish to include:

I. A minimum base area of ‘Soft Outdoor PE’ of 200m2 for primary or special schools; II. A minimum area per pupil place of ‘Soft Outdoor PE’ of 1m2 for Reception and Key Stage 2 (age 7-11); III. A minimum base area of ‘Habitat’ of 100m2 for primary or special schools.

Development proposals which have the potential to detrimentally impact on the use of open space will not be supported.

i. Open space areas include existing and new green open space, and hard open spaces such as streetscapes and the village centre. See figure 8. P.12. – Preventing The Plan supports the goals set out in 'A Green Future: Our 25 Year Plan to Improve No Likely Significant Effect Pollution the Environment' (Government, 2018). Opportunities to fulfil these goals at a Parish level will be sought, and new development proposals will be expected to support the This policy focuses on the prevention of pollution. Developments achievement of these goals. which create unacceptable levels of pollution will not be supported by the Parish Council. Development proposals that increase air, land, water, odour, noise, or light pollution to a level which could detrimentally impact upon the health, quality of life and This policy does not allocate development, nor does it give a residential amenity of existing and future residents will not be supported. quantum of housing, it merely sets the bounds within which the developers must comply. Where there is potential for pollution to derive from new development, the proposals should clearly demonstrate the potential risks to the human and natural environment, Therefore there are no impact pathways within this policy. and how the risks will be adequately addressed by appropriate avoidance, alleviation and mitigation measures.

Air quality dust and odour

I. New development proposals within Coggeshall Parish which could have an adverse impact upon local air quality must mitigate significant impacts and be in accordance with up to date guidance issued by the Institute of Air Quality Management. II. New development proposals must promote the use of deciduous and evergreen planting in public spaces, private gardens and on streets.

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III. New development proposals must promote the use of sustainable modes of transport and work with the Parish Council to increase the availability and accessibility of sustainable modes of transport throughout the village.

Water quality, abstraction and temperature fluctuation

I. New development proposals which would detrimentally impact water quality or cause a rise in temperature levels from 2018 levels within waterways will not be supported. I. New development proposals should be accompanied by increased capacity at the Coggeshall Water Recycling Centre as required by the relevant statutory agencies and water companies, in order to protect water quality in the area. II. New development proposals within Coggeshall Parish will not be supported where they propose to abstract water from the river Blackwater to an extent where the flow rate through Coggeshall could be compromised and the health of the river bed could be damaged.

Light Pollution

I. To reduce the impact of light pollution in the Parish, the following areas are designated as Dark Sky Areas (identified on figure 9): • DS1: Land north of the A120 to the northern, eastern and western Parish boundary; • DS2: Land south of the river Blackwater to the southern, eastern and western Parish boundary. II. Development proposals within Dark Sky Areas should demonstrate: • That they will not produce a net increase in artificial light levels within the Parish; • How any potential detrimental impacts to animals and plants arising from artificial light will be adequately mitigated within the proposed scheme. III. Where it is necessary to incorporate external lighting within Dark Sky Areas, development proposals should incorporate only well-designed directional lighting.

Noise pollution

I. Development proposals which could result in an increase in noise pollution should demonstrate the potential impact on the surrounding area and proposed mitigation measures to address these impacts. Tree planting

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throughout the Parish should be increased, to provide an additional filter against noise pollution particularly adjacent to busy roads such as the A120. II. To reduce the impact of noise pollution in the Parish, the following areas are designated as Tranquil Areas (identified on figure 10):

• TA 1: St Peter Ad Vincula Church grounds • TA 2: PRoW's in the vicinity of Coggeshall Abbey • TA 3: The Blackwater river corridor west of the village • TA 4: The Owen Martin Nature Reserve and LWS Bra 206 • TA 5: Rural land in the north west of the Parish.

Development proposals outside the Parish Boundary that could adversely affect the health of humans and animals will not be supported.

i. The Parish Council will work with Braintree Council to seek to achieve suitable mitigation or amelioration to the development proposals in such circumstances or support the refusal of the development. P.13. – Managing Flood To reduce the potential for flooding to occur in Coggeshall Parish and mitigate against No Likely Significant Effects Risk and Drought drought events, development within the existing built environment new development Prevention should: This policy focuses on the reducing flooding and droughts within the parish. I. Not increase flood risk (including fluvial and surface) on site or elsewhere; II. Be located in areas where the use is compatible with national planning This policy does not allocate developments sites, nor a quantum of policy; housing merely sets the bounds within which the developers must III. Demonstrate that the Sequential Test and, where necessary, Exception Test has been satisfactorily undertaken in accordance with national planning comply. policy; IV. Use innovative technology, construction and design techniques to reduce Therefore there are no impact pathways within this policy. the risk of flooding, mitigate any impacts of flooding, and minimise surface water run off; V. Ensure that at least 80% of hard external surface areas are permeable or runoff water is collected by effective infiltration systems; VI. Collect and recycle grey water and incorporate water storage measures or ‘rainwater harvesting’ for high volume rainfall events and to minimise surface run off; VII. Maximise opportunities to reduce the causes and impacts of flooding through appropriate Sustainable Drainage Systems (SuDS), in accordance with guidance contained within the Coggeshall Village Design Statement. All SuDS proposals should be accompanied by a comprehensive management VIII. plan setting out the long term maintenance and responsibility of SuDS features;

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IX. include tree and shrub planting to reduce run off, particularly along field boundaries.

To manage the potential for flooding throughout the Parish, particularly during high volume rainfall events, the following areas (identified on Figure 11 - Managing Flood Risk & Drought proposals plan) are designated as Flood Management Areas:

FMA1: The site of the ‘BT exchange’, East Street.

Future development within FMA1 should incorporate SuDS such as underground storage tanks to hold water in the event of heavy rainfall and minimise storm water run-off into the river Blackwater. FMA2: Flood zone adjacent to the river Blackwater. Development proposals which result in the loss of flood plain will not be supported. Proposals within FMA2 which include the construction of impermeable surfaces will not be supported in this area unless it can be demonstrated that the development will not result in any net increase in surface run off. The lowering of existing ground levels to create temporary water storage areas will be encouraged where appropriate.

FMA2: Land north and south of the stream adjacent to the Essex Way off St Peters Road.

Development proposals within FMA2 should include SuDS and natural flood management techniques to enhance the capacity of the stream to detain water in heavy rainfall events therefore mitigating against alluvial flooding of the Blackwater. Proposals should seek to include SuDS to mitigate against the impacts of increased runoff from the adjacent housing development.

FMA3: Land east of the Essex Way.

Development proposals within FMA3 which include the construction of impermeable surfaces will not be supported in this area unless it can be demonstrated that the development will not result in any net increase in surface run off. The lowering of existing ground levels to create temporary water storage areas will be encouraged where appropriate.

FMA4: Vicarage Field.

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Additional SuDS features within FMA4 should be created to form part of the existing public open space, such as additional ponds, reduced impermeable surfaces, and increased tree planting.

FMA5: The village centre, ‘The Gravel’ and public highways.

Where improvements to highways and public areas within FMA5 are made, these should incorporate additional SuDS features such as permeable surfaces, rain gardens, tree planting, roof gardens and green walls.

FMA6: The Hop Field (Owned by PC) west of the Blackwater, Coggeshall Hamlet.

Development proposals which result in the loss of flood plain will not be supported. Development proposals within FMA6 which include the construction of impermeable surfaces will not be supported unless it can be demonstrated that the development will not result in any net increase in surface run off. The lowering of existing ground levels to create temporary water storage areas will be encouraged where appropriate. P.14. – Protecting and Development proposals which may have an impact on designated heritage assets or No Likely Significant Effects Enhancing our Heritage their setting will be supported where it can be demonstrated that: This policy focuses on protecting and enhancing the heritage of the I. The scale and character of the proposal respects the scale and character of Parish, relating to building Conservation Areas. the Conservation Area and its setting within the surrounding countryside; II. The proposal respects the historic spaces between heritage assets within This policy does not allocate development sites, nor does it allocate the Conservation Area and the historic views into and out of the Conservation Area; a quantum of housing, merely sets the bounds within which the III. The proposals preserve or enhance the character, appearance, setting, developers must comply in relation to design management such as structural stability, and historic features of the relevant heritage asset(s); building materials and finishes. IV. There is no loss of views which contribute to the setting of the relevant heritage asset(s) from the surrounding area; Therefore there are no impact pathways within this policy. V. There would not be a significant increase in the use of the relevant heritage asset(s) which would result in detriment to its character, appearance, setting, structural stability and historic features; VI. Building materials and finishes preserve or enhance the character, appearance, setting and historic features of the relevant heritage asset(s); and VII. The benefits of the proposed development outweigh any identified harm to the character, appearance, setting and historic features of the heritage asset(s).

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The Neighbourhood Plan will work with the Parish Council to identify buildings, structures and features of historic, cultural or economic significance to the community to be nominated for inclusion on the Braintree District Local List of Heritage Assets. P.15. – Design Development proposals must: No Likely Significant Effect Management within the Built Environment I. Be in general conformity with the Coggeshall Village Design Guide; This is a development management policy and sets the bounds II. Contribute positively to the character, setting and appearance of the within which the developer must comply in relation to design surrounding area; management. III. Be of a scale and size which reflects the rural character and appearance of villages and hamlets in the area; IV. Ensure that the design and detail reflects and responds positively to the Therefore there are no impact pathways associated with this policy. scale, design, density, layout and historic character of existing development in the surrounding area; V. Ensure that there is an appropriate use of materials which preserves and enhances the character of the area; VI. Where appropriate, incorporate tree planting and vegetation which is predominantly native and consistent with flora in the surrounding area; VII. Include shared open spaces and shared amenities that will help to develop a sense of community; VIII. Ensure a mix of house types including affordable houses to foster a diverse community; IX. Support the needs of home-working, for example by providing convertible spaces, infrastructure which supports connectivity to high speed broadband, and must provide good pedestrian and cycle access and support public transport facilities within the Parish; X. Not result in significant harm to neighbouring residential amenity;

The Developer must:

I. Provide an assessment that demonstrates how the proposal will contribute positively to the character and appearance of the area and protect or enhance the unique identity of Coggeshall Village; II. Demonstrate how the proposed design is in accordance with guidance within the Coggeshall Character Assessment, Building for Life 12, and the Essex Design Guide (or successor documents); III. Incorporate sustainable design features which promote energy conservation and efficiency and support renewable energy and low carbon energy generation.

Where planning permission is being sought for new development, developers are encouraged to engage with the Parish Council so that the community can be closely involved at the early stages and:

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I. Positively influence the detailed design of the development proposal; II. Guide new development in the Parish in relation to appropriate layout, design, character, scale and appearance; III. Ensure high quality design which reflects and responds to the character and appearance of the surrounding area. P.16. – Design To protect and enhance the rural landscape character of the Parish, where No Likely Significant Effect Management within Rural appropriate development proposals should: Areas This is a development management policy and sets the bounds I. Include an assessment of the potential impact of the development on the within which the developer must comply in relation to design surrounding landscape; management. II. II Be sited and designed to protect, enhance, and respond positively to the

surrounding rural landscape character and setting; III. Promote the use of deciduous and evergreen planting in public spaces, Therefore there are no impact pathways associated with this policy. private gardens and on streets; IV. Protect, enhance, and plant new and locally prevalent species of native hedgerows and trees as boundary treatments to mitigate the visual impact of development. The planting of non-native evergreens as hedging or the erection of large-scale timber or wire fencing will not be supported; V. Protect, enhance, and plant new and locally prevalent species of native species rich grassland; VI. Promote management practices of woodlands and hedgerows which contribute to the rural landscape character of the Parish and Essex. Proposals that use:

I. Excessive or incongruous signage that negatively impacts upon the landscape character and atmosphere of the rural environment will not be supported; II. External lighting which, through aesthetic appearance or excessive illumination, negatively impacts upon the rural character of the Parish will not be supported.

Development proposals must preserve and enhance the following protected views (PVs) identified on Figure 11 - Protected Views Proposals Plan.

• PV1 Colchester Road: SW. • PV2 Cook Field: N & S. • PV3 Abbey Mill: N&S. • PV4 Mill Race: S. • PV5 Essex Way, (East): N. • PV6 West Street, Co op: S.

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• PV7 Market Hill: NE & SW. • PV8 Long Bridge, Bridge St: E&W. • PV9 Essex Way, (West): N. • PV10 Essex Way, (West): E. • PV11 Essex Way, (West): SW. • PV12 Blackwater river corridor: W. • PV13 Public footpath: S. • PV14 West Street: S. • PV15 Public footpath north-west of the village: N. • PV16 Vicarage Field: N. • PV17 Marks Hall Rd: NW. • PV18 Public footpath nr Holfield Grange: S. • PV19 Public footpath nr Cuthedge Lane: NW.

Where development proposals may impact upon the protected views a visual impact assessment will be required.

The Plan supports the 25 goals set out in 'A Green Future: Our 25 Year Plan to Improve the Environment' (Government, 2018) and will seek opportunities to fulfil these goals at a Parish level. New development proposals will be expected to support the achievement of these goals. P.17. – Transport and Proposals for development should encourage the use of more sustainable means of No Likely Significant Effect Infrastructure transport by: This policy focuses on promoting sustainable travel and I. Providing safe pedestrian and cycle access within a development; sustainable infrastructure within the parish. The policy does not II. Providing links from footpaths and cycleways within a development to public allocate residential development nor provide a quantum of rights of way and the wider pedestrian and cycle network within the Parish; housing. This is a development management policy and sets the III. Providing secure and safe areas for cycle storage throughout the Parish including schools and in the village centre; bounds within which the developer must comply in relation to IV. Including public charging points for electric vehicles in visitor parking areas; design management. V. Working with the Parish Council to increase the availability and accessibility of sustainable modes of transport throughout the village. Therefore there are no impact pathways associated with this policy.

Development proposals affecting a public right of way (PRoW) will not be supported where there is a detrimental impact on:

I. The ability of pedestrians and cyclists to safely use and enjoy the PRoW; II. The character, appearance, and setting of the PRoW; III. Flora and fauna which rely on the PRoW and surrounding area as a habitat and wildlife corridor.

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Proposals for development should:

I. Be sited within safe walking distance to public transport routes; II. Provide at least the minimum parking standards set out within the Essex County Council Vehicle Parking Standards; III. Provide dedicated parking areas or parking bays that are sympathetically incorporated into the design; IV. Incorporate measures to ensure that on-street parking is controlled and wherever possible reduced; V. Provide developer contributions towards sustainable transport measures and car clubs where off-street parking is not appropriate or feasible.

Development proposals within the village centre will be required to demonstrate that appropriate parking provision is made.

Development proposals that could result in the loss of an available parking space will be resisted.

a. Development proposals for allocated site Tey Road (refer to Policy P2) must enhance the adjacent public footpath and incorporate measures to enable safe crossing by pedestrians of the A120. P.18. – Developer Subject to the financial viability of development and the future application of the CIL No Likely Significant Effects Constributions Regulations (or future national policy, regulations, and guidance which may succeed the CIL Regulations), any residential development proposals and all proposals for This policy focuses on developers providing a monetary businesses and industrial premises will be required to contribute towards the contribution to improvements of community infrastructure within provision of local infrastructure such as public open space, community facilities, the Parish. This policy does not provide allocation of residential education facilities, health facilities, highways improvements, improved high speed development sites nor a quantum of dwellings. broadband connectivity, pedestrian and cycle links and community projects and initiatives within the Parish which specifically address the needs and aspirations of Therefore there are no impact pathways present within this policy local residents.

Developer contributions will be sought as appropriate towards the following specific projects which address local needs, including:

I. Improved pedestrian and cycle access to Coggeshall village centre; II. Increased provision of secure cycle parking areas throughout the Parish; III. Signage improvements throughout the Parish to improve connectivity between places of interest;

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IV. Flood managements improvements within Flood Management Areas 1-6 designated in Policy 6; V. Open space provision; VI. Community bus provision; VII. Safe crossing over the A120.

The requirements for developer contributions should be discussed after the submission of a planning application with Coggeshall Parish Council, Braintree District Council and, where relevant, Essex County Council.

Planning applications for residential developments and business and industrial premises should clearly demonstrate the impact of the proposed development on local infrastructure in the area and demonstrate how developer contributions towards local infrastructure will satisfactorily mitigate the identified impacts.

Relevant development proposals that fail to provide sufficient mitigation of the impact of the development through developer contributions will not be supported, unless:

I. It is proven that the benefit of the development proceeding without full mitigation outweighs the collective harm; or II. A fully transparent ‘open book’ viability assessment has proven that full mitigation cannot be afforded, allowing only for the minimum level of developer profit and land owner receipt necessary for the development to proceed; or III. Obligations are entered into by the developer that provide for appropriate additional mitigation in the event that viability improves prior to completion of the development.

Where viability evidence is to be provided by the applicant, it must clearly demonstrate the level of developer contributions which can be provided without rendering the scheme financially unviable. P.19. – Recreational • Financial contributions will be sought for all residential development, which No Likely Significant Effect disturbance Avoidance falls within the zones of influence, towards a package of measures to avoid and mitigate likely significant adverse effects in accordance with policy SP2b and Mitigation Strategy This is a positive policy which provides for mitigation of the effects of the Shared Strategic Section 1 Plan and policy ENV1 (Environment) of the Section 2 Braintree District Local Plan. of recreational pressure upon European sites through financial contributions from developers providing housing within the zone of • This includes development allocated in Neighbourhood Plans within influence of the European sites. Braintree District. Therefore there are no impact pathways present within this policy.

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• Details of the zones of influence and the necessary measures will be included in the Essex Coast RAMS Supplementary Planning Document (SPD).

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Appendix C Maps

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THIS DRAWING IS TO BE USED ONLY FOR THE PURPOSE OF ISSUE THAT IT WAS ISSUED FOR AND IS SUBJECT TO AMENDMENT

LEGEND Coggeshall Neighbourhood Plan Area Site Buffer 15km Ramsar Special Area of Conservation (SAC) Special Protection Area (SPA)

d x m . p a M Purpose of Issue s e t i S DRAFT d e t a n Client g i s e

D COGGESHALL NEIGHBOURHOOD

p PLAN STEERING GROUP a M \ l l

a Project Title h s e g g o C \ COGGESHALL s p a

M NEIGHBOURHOOD PLAN _ 2 0 \ 2 2 0 2

_ Drawing Title 8 1 0 2 _ B R C _ n DESIGNATED SITES a l P _ d o o h r u o Drawn Checked Approved Date b h g i CN JW AK 02/07/2019 e N

_ AECOM Internal Project No. Scale @ A3 7 8

0 60571087 1:150,000 1 7

5 THIS DOCUMENT HAS BEEN PREPARED PURSUANT TO AND SUBJECT TO THE 0 6

\ TERMS OF AECOM'S APPOINTMENT BY ITS CLIENT. AECOM ACCEPTS NO LIABILITY s FOR ANY USE OF THIS DOCUMENT OTHER THAN BY ITS ORIGINAL CLIENT OR m

e FOLLOWING AECOM'S EXPRESS AGREEMENT TO SUCH USE, AND ONLY FOR THE t s PURPOSES FOR WHICH IT WAS PREPARED AND PROVIDED. y S n AECOM o i t

a Scott House m Alençon Link, Basingstoke r o f Hampshire, RG21 7PP n I

Telephone (01256) 310200 -

4 Fax (01256) 310201 0

0 www.aecom.com 5 \ : I : Drawing Number Rev e m a N e l MAP 1 01

i 2 0 2 4 6 8 10 km F THIS DRAWING IS TO BE USED ONLY FOR THE PURPOSE OF ISSUE THAT IT WAS ISSUED FOR AND IS SUBJECT TO AMENDMENT

LEGEND Coggeshall Neighbourhood Plan Area Site Allocation

Site 1: Tey Road

Site 4 - Land North of Colchester Road

Site 2 - Cook Field West

Site 3

d - Dutch x m .

t Purpose of Issue

n Nursary e m

s DRAFT s e s s Client A e t i

S COGGESHALL NEIGHBOURHOOD

p PLAN STEERING GROUP a M \ l l

a Project Title h s e g g o C \ COGGESHALL s p a

M NEIGHBOURHOOD PLAN _ 2 0 \ 2 2 0 2

_ Drawing Title 8 1 0 2 _ B R C _ n SITE ALLOCATIONS a l P _ d o o h r u o Drawn Checked Approved Date b h g i CN JW AK 02/07/2019 e N

_ AECOM Internal Project No. Scale @ A3 7 8

0 60571087 1:10,000 1 7

5 THIS DOCUMENT HAS BEEN PREPARED PURSUANT TO AND SUBJECT TO THE 0 6

\ TERMS OF AECOM'S APPOINTMENT BY ITS CLIENT. AECOM ACCEPTS NO LIABILITY s FOR ANY USE OF THIS DOCUMENT OTHER THAN BY ITS ORIGINAL CLIENT OR m

e FOLLOWING AECOM'S EXPRESS AGREEMENT TO SUCH USE, AND ONLY FOR THE t s PURPOSES FOR WHICH IT WAS PREPARED AND PROVIDED. y S n AECOM o i t

a Scott House m Alençon Link, Basingstoke r o f Hampshire, RG21 7PP n I

Telephone (01256) 310200 -

4 Fax (01256) 310201 0

0 www.aecom.com 5 \ : I : Drawing Number Rev e m a N e l MAP 2 01

i 200 0 200 400 600 800 1,000 m F Coggeshall Neighbourhood Plan HRA Coggeshall Neighbourhood Plan Group

Project number: 60571087

Amelia Kent Consultant Ecologist ACIEEM

AECOM Infrastructure & Environment UK Limited Midpoint, Alencon Link Basingstoke Hampshire RG21 7PP United Kingdom

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

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