Greater Cambridge Local Plan Issues & Options 2020

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Form ID: 50253
Respondent: Natural England

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The adopted Local Plans allocate land for 33,500 homes to 2031. However, current calculations using the Government’s standard method indicates a need for 1,800 homes per year, or 40,900 homes for the Plan period 2017 – 2040. This represents significant growth and associated development pressure across Greater Cambridge. In light of the Councils’ ambitious targets for zero net carbon, more efficient water use and ‘doubling nature’ our major concern is whether the proposed level of growth, and the additional infrastructure needed to support it, will be truly sustainable i.e. capable of having no adverse environmental impact and contributing towards the 100% BNG target. Also to ensure legal compliance it will be necessary to ensure assessment of the maximum number of houses through the SA and HRA, rather than a minima figure. As discussed above, the Local Plan will need to promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet the needs of development.

Form ID: 50255
Respondent: Natural England

Q36 – Q38 Infrastructure and sustainable travel. The Local Plan should ensure that infrastructure is capable of supporting new development and that it contributes towards net zero carbon and doubling nature targets. As already mentioned a more sustainable transport network is required to reduce reliance on car travel in order to improve air quality, people’s health, biodiversity and to slow down climate change. We are aware that Greater Cambridge Partnership (GCP) is developing a number of transport schemes to improve sustainable travel in the area and the Combined Authority is preparing a Local Transport Plan including plans for a Cambridge Autonomous Metro (CAM) to build on the work of the GCP by linking destinations across Cambridge and beyond. Several rail schemes are being developed which are likely to influence the location of new development including the East West Rail Link, with a new station at Cambourne, and a new station planned for Addenbrookes. We welcome that the Councils are lobbying the East West Rail Company for the project to achieve biodiversity and wider environmental net gain. Wider Ox-Cam Arch projects include the A428 Black Cat to Caxton Gibbet Improvement Scheme. Our advice is that any new development should avoid impacts to the natural environment and should take a partnership approach to delivering strategic enhancements. Infrastructure such as waste water treatment facilities should be sited in the most sustainable locations, prioritising avoidance of impacts to the natural environment, and delivery of significant environmental enhancements including BNG.

Form ID: 50257
Respondent: Natural England

Q36 – Q38 Infrastructure and sustainable travel. The Local Plan should ensure that infrastructure is capable of supporting new development and that it contributes towards net zero carbon and doubling nature targets. As already mentioned a more sustainable transport network is required to reduce reliance on car travel in order to improve air quality, people’s health, biodiversity and to slow down climate change. We are aware that Greater Cambridge Partnership (GCP) is developing a number of transport schemes to improve sustainable travel in the area and the Combined Authority is preparing a Local Transport Plan including plans for a Cambridge Autonomous Metro (CAM) to build on the work of the GCP by linking destinations across Cambridge and beyond. Several rail schemes are being developed which are likely to influence the location of new development including the East West Rail Link, with a new station at Cambourne, and a new station planned for Addenbrookes. We welcome that the Councils are lobbying the East West Rail Company for the project to achieve biodiversity and wider environmental net gain. Wider Ox-Cam Arch projects include the A428 Black Cat to Caxton Gibbet Improvement Scheme. Our advice is that any new development should avoid impacts to the natural environment and should take a partnership approach to delivering strategic enhancements. Infrastructure such as waste water treatment facilities should be sited in the most sustainable locations, prioritising avoidance of impacts to the natural environment, and delivery of significant environmental enhancements including BNG.

Form ID: 50259
Respondent: Natural England

Q36 – Q38 Infrastructure and sustainable travel. The Local Plan should ensure that infrastructure is capable of supporting new development and that it contributes towards net zero carbon and doubling nature targets. As already mentioned a more sustainable transport network is required to reduce reliance on car travel in order to improve air quality, people’s health, biodiversity and to slow down climate change. We are aware that Greater Cambridge Partnership (GCP) is developing a number of transport schemes to improve sustainable travel in the area and the Combined Authority is preparing a Local Transport Plan including plans for a Cambridge Autonomous Metro (CAM) to build on the work of the GCP by linking destinations across Cambridge and beyond. Several rail schemes are being developed which are likely to influence the location of new development including the East West Rail Link, with a new station at Cambourne, and a new station planned for Addenbrookes. We welcome that the Councils are lobbying the East West Rail Company for the project to achieve biodiversity and wider environmental net gain. Wider Ox-Cam Arch projects include the A428 Black Cat to Caxton Gibbet Improvement Scheme. Our advice is that any new development should avoid impacts to the natural environment and should take a partnership approach to delivering strategic enhancements. Infrastructure such as waste water treatment facilities should be sited in the most sustainable locations, prioritising avoidance of impacts to the natural environment, and delivery of significant environmental enhancements including BNG.

Form ID: 50260
Respondent: Natural England

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Question 42. The current strategy focuses new development within Cambridge and then on the edge of Cambridge, at new settlements close to Cambridge, and at better served villages. It is proposed to add to this current development strategy. A key new site will be North East Cambridge with development contributing to the additional targets for the new Local Plan. Another potential major development site is Cambridge Airport. The location of further significant development is likely to be influenced by projects such as the Combined Authority’s CAM and the East West Rail project. Natural England believes that priority should be given to targeting growth in the most sustainable locations i.e. where impacts to the natural environment, through development and associated infrastructure, can be avoided and where maximum enhancements can be achieved by that development. The availability of existing infrastructure and services will be a key consideration. The Local Plan development strategy should be underpinned by up to date environmental evidence such as the mapping of ecological networks and enhancement opportunity areas currently being undertaken by the Councils for the green infrastructure and biodiversity evidence base. The assessment of existing and potential components of local ecological networks should inform the SA: application of the mitigation hierarchy will ensure development avoids adverse impact to the natural environment; development is instead focused on land of least environment value; and opportunity enhancement areas are linked for delivery through those developments. Natural England suggests that cross-cutting issues should be identified at this early stage. For example, transport infrastructure, water and sewerage, air quality, flood protection and recreation and leisure requirements can have potential implications for the natural environment and policies to deliver these requirements will need to ensure its protection and enhancement. Key issues for Greater Cambridge’s natural environment include pressure on water resources, flood management, recreational pressure & deficits in accessible GI, air quality and climate change. The effects of large scale housing development on the existing green infrastructure network, through recreational pressure and disturbance, is a significant issue. Avoiding impacts by locating development away from more sensitive designated sites and habitat is critical. However, the scale of proposed growth requires additional measures to mitigate residual impacts; buffering and extending these sensitive areas to enhance their resilience to access pressure and creation of new alternative areas of accessible greenspace capable of meeting people’s needs and diverting pressure away from more sensitive areas. Our advice is that the location of new development should be informed through preparation of a map of the existing ecological network including designated sites, priority habitats and other important green spaces to identify key areas for protection and delivery of strategic / landscape-scale enhancements. This should be used to develop a strategy to inform the appropriate location of site allocations and to identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. This could then be used to prepare a Green Infrastructure Strategy / SPD or an update to the Cambridgeshire Green Infrastructure Strategy.

Form ID: 50264
Respondent: Natural England

Natural England supports the purpose of Cambridge’s Green Belt in preserving the unique character of Cambridge, maintaining and enhancing the quality of its setting and maintaining community separation. The Plan should, as far as possible, seek to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide areas for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. In our view the Councils should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

Form ID: 50265
Respondent: Natural England
Form ID: 50270
Respondent: Natural England

Annex A: Natural England additional guidance and advice on embedding biodiversity net gain into the Greater Cambridge Local Plan policies Background Biodiversity Net Gain (BNG) is an approach to development, and/or land management, which aims to leave the natural environment in a measurable better state than beforehand. Defra recently consulted on proposals to make biodiversity net gain mandatory for Town & County Planning Act (TCPA) developments. The consultation closed in February 2019 and in the Spring Statement it was confirmed that mandatory net gain would be taken forward. BNG is usually measured through use of a metric, most commonly one based upon Defra’s ‘biodiversity metric’. This calculates before and after habitat values in terms of ‘biodiversity units’. The recent net gain consultation, also sought views on updates to the metric, which was originally piloted by Defra in 2012. BNG does not replace existing environmental legislation or policy requirements. Importantly this includes the application of the mitigation hierarchy and BNG does not apply to development subject to the Habitats Regulations. Furthermore BNG is not intended to be used to assess impacts and calculate compensation for habitat damage or loss affecting irreplaceable habitats or other designated sites, including SSSIs. BNG outcomes can be achieved onsite, offsite or a combination of the two. The priority should be on securing onsite gains where possible. When delivering offsite, links should be made to relevant plans or strategies to ensure gains are targeted on areas of opportunity, for example the Cambridgeshire Green Infrastructure Strategy, the Cambridgeshire and Peterborough Biodiversity Group Habitat Opportunity Mapping areas, etc. It should be noted that BNG is not predicated on there being a biodiversity loss on a site. National Planning Policy Framework (NPPF) The revised NPPF (2019) set outs the planning policy context for delivering BNG through the planning system, clearly stating that planning policies and decisions should provide net gains for biodiversity. The net gain policy should be considered in conjunction with other NPPF policies on the natural environment, including the mitigation hierarchy: ‘providing net gains in biodiversity where possible’, has been strengthened to ‘minimising impacts on and providing net gains for biodiversity’ (para 170, NPPF 2019) and now refers to ‘measurable net gains’ (174). In addition, LPAs have a duty to have regard for biodiversity in the exercise of their functions* (under Section 40 NERC Act, 2006). An evidence based approach to biodiversity net gain can help LPAs demonstrate compliance with this duty. Links to green infrastructure Green infrastructure within and around new development e.g. SUDs, green spaces etc. can be designed and maintained to deliver new or enhanced habitat features for biodiversity (contributing towards the need for measurable BNG requirements) as well as providing a range of other health and wellbeing benefits for communities, contributing towards wider place-making. BNG through Local Plans Strategic policies should include requirements to conserve and enhance the natural environment (NPPF, para 20). LPAs can set a clear framework at this level for biodiversity net gain, which can flow down and be supplemented by lower tier plans, including neighbourhood plans. Non-strategic policies should be used to set out more detailed policies for specific areas, neighbourhoods or types of development. This can include allocating sites for development and the provision of infrastructure and community facilities at a local level. Non-strategic policies may provide further detail on biodiversity net gain, for example the delivery criteria for a development allocation or local priorities for habitat enhancement. Helpful guidance is available through the CIRIA/IEMA/CIEEM publication** including https://www.ciria.org/Resources/Biodiversity_Net_Gain.aspx One of the first steps is to identify locations where development should be avoided (in line with the mitigation hierarchy) and locations where any off-site BNG delivery should be targeted e.g. to enhance ecological networks or to restore degraded habitats. The work being undertaken by Greater Cambridge to develop a biodiversity and green infrastructure evidence plan should help to identify these areas. Natural England has already advised on the availability of existing information through the following sources:  Natural England’s Impact Risk Zones (IRZs) available through Magic;  The Cambridgeshire Biodiversity Partnership’s Mapping Natural Capital and Opportunities for Habitat Creation in Cambridgeshire (May 2019);  Combined Authority Doubling Nature Investment Plan;  Cambridgeshire and Peterborough Non-Statutory Strategic Spatial Framework;  the objectives and projects in the Cambridgeshire Green Infrastructure Strategy (2011);  Natural England’s Cambridgeshire Analysis of Accessible Natural Greenspace 2010;  Cambridgeshire Rights of Way Improvement Plan. The Cambridgeshire and Peterborough Environmental Records Centre (CPERC) and existing environmental assessments for recent developments may provide useful additional data. The existing evidence can be used to help develop policy objectives, for example by securing habitat creation to connect areas of fragmented habitat through development. It can be useful to gather evidence and emerging approaches in a background paper to inform policy development. The Portsmouth Background Paper*** provides a useful example of bringing together the existing baseline and key priorities for the new Local Plan, highlighting gaps in evidence relevant to priorities for the plan. BNG is integral to the entire paper and key actions around environmental mapping and policy development is highlighted. Another good example is Lichfield Local Plan 2015 which includes a good BNG policy which requires development resulting in a loss to provide compensation that is at least 20% greater. Engaging local stakeholders is also crucial in early plan making and we welcome the approach being taken to this by the Greater Cambridge Shared Partnership. Natural England may be able to assist with designated site knowledge, however it also important for the LPA to engage with the local community, Wildlife Trust, RSPB, local birdwatching groups etc. to understand what is important locally to the people who work, live and visit the area. A partnership approach is considered the most effective way of delivering BNG. This includes an understanding of the view of local communities, residents, visitors and landowners, to help understand local aspirations and priorities. Organisations working together via the Local Enterprise Partnership, the Combined Authority, the Local Nature Partnership or other biodiversity partnership can help to deliver BNG across larger spatial scales. We are aware that Greater Cambridgeshire Partnership is taking forward a partnership approach to the delivery of BNG in planning, which includes a leading role for the Local Nature Partnership. Mapping biodiversity and green infrastructure opportunity areas and analysing connectivity, ahead of selecting sites for development, will help identify where the biggest opportunities exist to maximise biodiversity gains when considering where to allocate areas of growth through the Local Plan. Warwickshire County Council’s approach to the Local Plan is underpinned by a robust evidence base using various data sets, including maps on grassland and woodland habitats. From here, they began to target where enhancement could be made and/or the connections between well-established existing habitats. The County Council formed a close working relationship with the Local Environmental Records Centre and neighbouring authorities to outline a programme of work to review and update data. More detail can be found here. At this early stage the Councils should consider: - What biodiversity is at risk locally and whether the approach to BNG should be targeted on-site or off-site, and how this might work in practice to secure delivery; - Consider and map the area’s most important assets and their connectivity; - Identify other relevant plans and strategies and cross reference these, for example the Cambridgeshire Green Infrastructure Strategy (Cambridgeshire Horizons, 2011) and Cambridgeshire Habitat Opportunity Mapping to identify opportunity areas, reducing the need for additional evidence mapping; - Establish the best and least favourable areas for BNG underpinned by evidence; - Undertake further evidence gathering where gaps occur or to provide further detail to inform options; - Set out minimum requirements for BNG, bearing in mind the ‘doubling nature’ vision for Cambridgeshire is equivalent to 100% net gain; - Consider the impact of the BNG approach on viability and the deliverability of emerging policies and allocations. Natural England advocates the inclusion of a standalone BNG policy within Local Plans, and the inclusion of specific BNG requirements within site allocation policies. Ideally this should include a BNG % target, although local plan policy may simply outline the positive intention for BNG, noting that a mandatory requirement is likely to be at least 10%. The policy should also include a commitment to using a single, preferably the Defra 2.0 metric, to ensure consistency. Policy requirements should be clear so that they can be accounted for down the line, ensuring costings are factored in and that BNG is deliverable indicating whether this will be secured through planning condition or S106 agreement. Further details can be set out in lower tier plans such as a Supplementary Planning Document (SPD). Local Plans should include a commitment to monitor the BNG policy and approach including the quantified gains achieved by the policy and the recording of any losses. A habitat banking approach could be taken for smaller developments. The SA should include an objective around biodiversity and net gain that could be tested against all policies in the emerging draft plan For larger sites allocations additional evidence including mapping of key areas and opportunities for BNG can be sought from the developer. Longer term the Nature Recovery Network (NRN) will be a useful tool in the delivery of BNG. Net gain can contribute both towards the creation of new habitats and the enhancement of existing sites and habitats to develop a NRN, which is a key action in the Defra 25 Year Environment Plan. *See http://www.legislation.gov.uk/ukpga/2006/16/section/40 ** CIRIA/IEMA/CIEEM Biodiversity Net Gain – Good practice principles for development (2016) CIRIA/IEMA/CIEEM Biodiversity Net Gain: Good practice principles for development – a practical guide’ 2019) CIRIA/IEMA/CIEEM Biodiversity Net Gain: Good practice principles for development Gain – Case studies (2019) ***Biodiversity and Portsmouth Background Paper. Portsmouth City Council, February 2019.

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Form ID: 50279
Respondent: Natural England

B: Natural England Further Advice on Local Plan Policies Biodiversity and geodiversity Designated sites The Local Plan should set criteria based policies to recognise the hierarchy of designated biodiversity and geological sites and ensure their protection. Such policies should clearly distinguish between international, national and local sites*. Natural England advises that all relevant Sites of Special Scientific Interest (SSSIs), European sites (Special Areas of Conservation and Special Protect Areas) and Ramsar sites** should be included on the proposals map for the area so they can be clearly identified in the context of proposed development allocations and policies for development. Designated sites should be protected and, where possible, enhanced. The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can inform key decision making on strategic options and development sites. It may be necessary to outline avoidance and/or mitigation measures at the plan level, which will usually need to be considered as part of an Appropriate Assessment, including a clear direction for project level HRA work to ensure no adverse effect on the integrity of internationally designated sites. It may also be necessary for plans to provide policies for strategic or cross boundary approaches, particularly in areas where designated sites cover more than one Local Planning Authority boundary. The Plan should set out a strategic approach, planning positively for the creation, protection, enhancement and management of networks of biodiversity through all relevant development including housing, transport and community infrastructure. There should be consideration of geodiversity conservation in terms of any geological sites and features in the wider environment. The biodiversity policy and wider Plan preparation should apply the mitigation hierarchy and promote delivery of biodiversity net gain, in accordance with paragraphs 170 and 174 of the NPPF. The existing ecological network including designated sites, priority habitats and other important green spaces should be mapped along with key areas for protection and delivery of strategic / landscape-scale enhancements. This will help in the development of a strategy to inform the appropriate location of site allocations and to identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. Ideally the policy should include a requirement for proposals to be accompanied by a biodiversity survey, including an audit of gains and losses, based on the Defra 2.0 metric or very similar methodology. Developer’s should also be required to consider Natural England’s IRZs to ensure that potential direct and indirect impacts to designated sites, including recreational pressure, are appropriately assessed and that any adverse impacts can be satisfactorily mitigated. The policy should seek to safeguard the value of previously developed land where it is of significant importance for biodiversity and/or geodiversity. Priority habitats, ecological networks and priority and/or legally protected species populations Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England. Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area. Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks. Planning positively for ecological networks will also contribute towards a strategic approach for the creation, protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF. Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran trees, there should be appropriate policies to ensure their protection. Natural England and the Forestry Commission have produced standing advice on ancient woodland, ancient and veteran trees. The policy should include a commitment to work with developers and Natural England to identify a strategic approach to great crested newt mitigation, where this is required, on major sites and other areas of key significance for this species. Green Infrastructure Green infrastructure refers to the living network of green spaces, water and other environmental features in both urban and rural areas. It is often used in an urban context to provide multiple benefits including space for recreation, access to nature, flood storage and urban cooling to support climate change mitigation, food production, wildlife habitats and health and well-being improvements provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands, rivers and wetlands. Green infrastructure is also relevant in a rural context, where it might additionally refer to the use of farmland, woodland, wetlands or other natural features to provide services such as flood protection, carbon storage or water purification. A strategic approach for green infrastructure is required to ensure its protection and enhancement, as outlined in para 171 of the NPPF. Green Infrastructure should be incorporated into the plan as a strategic policy area, supported by appropriate detailed policies and proposals to ensure effective provision and delivery. Evidence of a strategic approach can be underpinned by Green Infrastructure Strategy. We encourage the provision of green infrastructure to be included as a specific policy in the Local Plan or alternatively integrated into relevant other policies, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure. We advise the Council to prepare a map of the existing ecological network and opportunities for enhancement. An accompanying strategy should identify opportunities for delivery of biodiversity and green infrastructure enhancement projects through the Plan’s major development and biodiversity and green infrastructure policies. The policy should make provision for appropriate quantity and quality of green space to meet identified local needs as outlined in paragraph 96 of the NPPF. Natural England’s Cambridgeshire Accessible Greenspace Analysis (2010) may be of use when considering current level of provision whilst our Accessible Natural Greenspace Standard (ANGSt) offers useful guidance to developers. Provision of sufficient quantity of high quality alternative natural greenspace is an important tool in mitigating the effects on recreational pressure associated with new housing development on more sensitive SSSIs. Our advice is that the level of provision should be proportionate to the scale of development, for example 8ha /1000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance. The policy should promote Natural Cambridgeshire’s Developing with Nature Toolkit to maximise opportunities within the design of the development to provide sufficient area of high quality multi-functional green infrastructure, including sustainable drainage (SuDS) to deliver net gain for biodiversity, landscape and accessible open space to meet people’s recreational and health needs. Appropriately designed and managed green infrastructure can also provide significant climate change mitigation including urban cooling. Developers should be encouraged to follow Natural England’s Accessible Natural Greenspace Guidance detailed in 'Nature Nearby'. Landscape Natural England expects the Plan to include strategic policies to protect and enhance valued landscapes, as well criteria based policies to guide development. Access and Rights of Way Natural England advises that the Plan should include policies to ensure protection and enhancement of public rights of way and National Trails, as outlined in paragraph 98 of the NPPF. Recognition should be given to the value of rights of way and access to the natural environment in relation to health and wellbeing and links to the wider green infrastructure network. The plan should seek to link existing rights of way where possible, and provides for new access opportunities and avoid building on open space of public value as outlined in paragraph 97 of the NPPF. Soils and agricultural land The Local Plan should give appropriate weight to the roles performed by the area’s soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver. The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with National Planning Policy Framework paragraph 170. Air pollution We would expect the plan to address the impacts of air quality on the natural environment. In particular, it should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs. The environmental assessment of the plan (SA and HRA) should also consider any detrimental impacts on the natural environment, and suggest appropriate avoidance or mitigation measures where applicable. Natural England advises that one of the main issues which should be considered in the plan and the SA/HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment. The effects on local roads in the vicinity of any proposed development on nearby designated nature conservation sites (including increased traffic, construction of new roads, and upgrading of existing roads), and the impacts on vulnerable sites from air quality effects on the wider road network in the area (a greater distance away from the development) can be assessed using traffic projections and the 200m distance criterion followed by local Air Quality modelling where required. We consider that the designated sites at risk from local impacts are those within 200m of a road with increased traffic***, which feature habitats that are vulnerable to nitrogen deposition/acidification. APIS provides a searchable database and information on pollutants and their impacts on habitats and species. *International sites include: Special Protection Areas (SPAs); Special Areas of Conservation (SACs) and Ramsar sites**. National sites include Sites of Special Scientific Interest (SSSIs) and National Nature Reserves (NNRs) Local sites include wildlife Sites or geological sites (a variety of terms are in use for local sites). Page 15 of 15 Tranquillity The Local Plan should identify relevant areas of tranquillity and provide appropriate policy protection to such areas as identified in paragraph 100 and 180 of the NPPF. The CPRE have mapped areas of tranquillity which are available here and are a helpful source of evidence for the Local Plan and SA. Flood and Water Management Natural England expects the Local Plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should be based on an up to date evidence base on the water environment and as such the relevant River Basin Management Plans should inform the development proposed in the Local Plan. These Plans (available here) implement the EU Water Framework Directive and outline the main issues for the water environment and the actions needed to tackle them. Local Planning Authorities must in exercising their functions, have regard to these plans. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focussed on European sites, SSSIs and local sites which contribute to a wider ecological network. Plans should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this. A specific requirement for relevant development to be accompanied by a detailed hydrogeological assessment should be included. Site allocations / assessment Our advice is that site assessment methodology should be based upon a robust and credible consideration of deliverability, the suitability of the land to accommodate the proposed development, as well as the potential contribution towards sustainable development against potential suitable alternatives. Preference should be given to allocating sites on brownfield / previously developed land to protect BMV land, noting that these can support important biodiversity. When assessing Site Allocations we recommend the use Natural England’s Impact Risk Zones, which are available for LPAs to download or through www.magic.gov.uk, to identify where development may have an impact on designated sites. Impacts and mitigation requirements should be identified through the SA. The delivery of mitigation measures will need to be secured through relevant Plan policies. Water resource / quality impacts and the effects of increased recreational pressure on SSSIs are likely to be key issues which need to be addressed for some of the settlements identified. The combined effects of proposed development will need to be considered where relevant. **The following wildlife sites should also be given the same protection as European sites: potential SPAs, possible SACs, listed or proposed Ramsar sites and sites identified, or required, as compensatory measures for adverse effects on European sites ***The ecological effects of diffuse air pollution (2004) English Nature Research Report 580 Design Manual for Roads and Bridges Volume 11, Section 3 Part 1 (2007), Highways Agency

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