10 February 2010 Our ref: Your ref: Southgate Street Bury St Edmunds Matt Deakin Suffolk Suffolk Coastal District Council IP33 2FE Melton Hill T 0300 060 2384 Woodbridge F 0300 060 1662 IP12 1AU Dear Matt Suffolk Coastal District Council Local Development Framework Habitat Regulations Appropriate Assessment and Clarification Summary of the Core Strategy Thank you for your letter of 13 January 2010 consulting Natural England on the above. Following on from my email of last week, below are Natural England’s full and final comments on the Clarification Summary and the Appropriate Assessment of the Core Strategy. 1. The maths involved in estimating the increase in visitors to European sites was more clearly explained in the Clarification Summary in Point 2, so Natural England are now able to agree to the predicted increase of 2-5% of all visitors. 2. We agree with the comments made in 2.6-2.8 that the predicted growth in population in the Suffolk Coastal District Council area of 0.9 people per dwelling should not be used as the occupancy rate for the proposed development areas; also that the increase in population at these growth locations will not necessarily be balanced out by reductions elsewhere, as the growth locations are situated nearer to the SPAs. The proposed development areas East of Ipswich and in the Felixstowe area could therefore mean significant increases in populations locally and therefore potentially significantly high impacts from recreational disturbance. 3. Whilst the statistics in the ‘Heaths’ studies may show that most people have walked less than 1km to get to Dorset Heaths and 79% walked less than 1km to get to Thames Basin Heaths, we do not believe that means that significant numbers of new residents will NOT walk to the estuaries from the proposed development areas (the studies are related specifically to heaths, the coast is different). Colleagues in the South East have studies showing people will go to considerable effort to get to the coast. Therefore, we do not agree with the statement in the AA that provided the allocations are over 1km away from the SPAs ..... there will be no likely significant effect on the SPAs, as we believe that some Natural England Head Office 1 East Parade Sheffield S1 2ET www.naturalengland.org.uk people from new developments will walk to the estuaries and it is not known what level of increased visitor pressure will have an adverse effect on the designated features of the estuaries. Therefore, projects over 1km away could still require an AA. 4. However, we do believe that with the following mitigation approach for developments over 1km from designated sites, we can conclude that Policy SP2 Housing Numbers will not have a Likely Significant Effect on the SPAs: a. Access to Suitable Accessible Natural Greenspace (on and off development sites) to mitigate for impacts ‘alone’ – funding needed from developers. b. A new Country Park as mitigation for the ‘in combination’ effect of future housing developments in the Ipswich Borough and Suffolk Coastal District areas. c. A strong package of visitor management and infrastructure including wardening at the designated sites. d. Monitoring of any impacts caused by visitors and a change in visitor/site management to offset any such impacts. e. Points a, b and c above need to be funded in perpetuity, whilst d would need to continue until the full effects of new developments can be ascertained. 5. HOWEVER, in order to conclude no LSE under the Habitats Regulations Assessment Natural England have to be certain that the mitigation will be delivered and the wording in Policy SP17 leaves that open to question: “…….subject to its priority in comparison with other elements of community infrastructure.” In your summary of key issues to be resolved at our joint meeting in December, your last point concerned mitigation proposals and greenspace and you asked if greenspace would be a luxury or a necessity – as you can see from above comments, it is a necessity to mitigate for LSE from new developments. 6. We agree with Section 5 of the Clarification Summary that further visitor/bird disturbance surveys are needed, not as part of the Core Strategy but for the Area Action Plans. Ipswich BC have the benefit of the Stour-Orwell Estuaries Bird Disturbance report, whereas Suffolk Coastal do not have a similar study of the estuaries in their policy area to make use of. Any studies done should be collaborative with other interested organizations.” I hope this clarifies our position on the Core Strategy and the AA, but please contact me if you have any queries. Yours sincerely Pat Williams Pat Williams Norfolk & Suffolk Government Team East of England Region Direct dial: 0300 060 2384 Email: [email protected] Clarification Summary for Suffolk Coastal District Council Proposed Submission Core Strategy and Development Management Policies January 2010 Issue Quality control Clarification Summary for Suffolk Coastal District Council Proposed Submission Core Strategy and Development Management Policies Appropriate Assessment Checked by Project Manager: Approved by: Signature: Signature: Name: Nicholas Sibbett Name: Dr Jo Parmenter Title: Senior Ecologist Title: Associate Director Date:5th January 2010 Date: 5th January 2010 The Landscape Partnership is registered with the Landscape Institute, the Royal Town Planning Institute, and is a member of the Institute of Environmental Management and Assessment The Landscape Partnership Registered office Greenwood House 15a St Cuthberts Street Bedford MK40 3JB Registered in England No. 2709001 Contents 1 Introduction .................................................................................................................................1 2 Clarifications for Section 5 of the appropriate assessment.................................................................1 3 Clarifications for Section 6 of the appropriate assessment.................................................................3 4 Clarifications for Section 7 of the appropriate assessment.................................................................4 5 Clarifications for Section 9 of the appropriate assessment.................................................................5 Figures 01 Bar chart of visitors to the Suffolk Coast and Heaths AONB Part 1: Text 1 Introduction 1.1 In December 2008, Suffolk Coastal District Council published its Preferred Options for its Local Development Framework Core Strategy and Development Management Policies. This document sets out the Council’s vision for the area to 2025. It then sets out the objectives that a planning strategy must work to if the vision is to materialise. Strategic planning policies then follow, with an emphasis on the ‘spatial’ aspect. Finally, a suite of Development Management policies will provide guidance upon any detailed aspects. 1.2 A draft of the Submission stage was published on Suffolk Coastal District Council’s website as part of the agenda for discussion by Cabinet in their meeting on 7th July 2009. Subsequently, the Housing Distribution section was formally made available for public comment, with the Appropriate Assessment, in September 2009 with the consultation period expiring on 18th November 2009. Comments were received primarily from Natural England, in a letter dated 18th November 2009, which included a number of queries about the contents of the Appropriate Assessment, particularly the most complex sections. To help answer these questions, a meeting was held with Natural England on 7th December 2009 during which it was agreed that a Clarification Summary would be a helpful way of answering those queries. This document is the result of that meeting, but it is also considered that this Clarification Summary may be of wider public interest. 1.3 ‘Clarification Summary’ means that the contents of the Appropriate Assessment are summarised and presented in a more-easily understood format. However, no material changes have been made to the Appropriate Assessment itself. 1.4 This document sets out clarification of the Appropriate Assessment using the numbered sections of the Appropriate Assessment. Sections 1 – 4 and 8 of the Appropriate Assessment are less complex and so no clarification is necessary for those sections. The Appropriate Assessment considers the combined impact of allocations in both Ipswich Borough and Suffolk Coastal, as well as in Suffolk Coastal alone, which is why there are numerous references to Ipswich Borough below. 2 Clarifications for Section 5 of the Appropriate Assessment Increase in visitors to European sites 2.1 The calculations of increased visitors to European sites are complex. Initially, one would expect that a 9.1% increase in the combined population of Ipswich Borough and Suffolk Coastal District to cause a 9.1% increase in visitors to European sites in the Suffolk Coast and Heaths AONB. In reality, a 9.1% increase in population will result in a proportionate increase from only those visitors who come from Ipswich Borough and Suffolk Coastal District. Visitor numbers from elsewhere are unchanged, so the increase in the total number of visitors will be less than 9.1%. 2.2 There is relatively little data available about visits to European sites. A study of visitors to the Suffolk Coast and Heaths AONB conducted in 2004 provides some of the best data available. Data presented in Section 5.3 of the Appropriate Assessment shows that about half (55%) of visitors to the Suffolk Coast and Heaths AONB were local people on a day trip, with