Aylesbury Vale Area

Habitats Regulations Assessment

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Support

VALP Further Main Modifications

Representation ID: 3732

Received: 05/02/2021

Respondent: Natural England

Representation Summary:

Natural England provided a response on the 18th November 2020 agreeing with the conclusions reached in the Addendum Habitats Regulations Assessment (HRA) and Appropriate Assessment.

Full text:

Dear Sir or Madam,
Planning Consultation: Aylesbury Vale Local Plan – Further Main Modifications
Thank you for your consultation on the above dated 15 December 2020 which was received by Natural England on the same day.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We would like to thank you for taking our comments from the previous consultation on board. We have reviewed the modifications and in particular Policies NE1-9 and I1, and have no further comments to make.
We have included some advisory comments, which should constitute best practice. Most are minor changes concerned with wording of certain policies.
ADVISORY
Policy D1 - Delivering Aylesbury Garden Town
As the main Policy for the Garden Town, we recommend addition to D1 to require all associated development to conserve the biodiversity on site and provide a biodiversity net gain through multifunctional green infrastructure. this is supported within the NPPF (paras. 170, 175 (d). and will bring the Policy in line with Policies NE1-9 and I1.
D-WHA001 Shenley Park
Due to the areas of ancient woodland (irreplaceable habitat), deciduous woodland (priority habitat) and ‘no main habitat but additional habitats present’ (priority habitat) on the site, we advise wording is put in to ensure habitats are not damaged or destroyed. In addition, we advise removal of ‘where practicable’ in regards to retention of habitats.
D-HAL003 RAF Halton
Wording should be added to the site specific description to highlight the neighbouring sites of ecological value, and to ensure they are not encroached onto.
The 50% green infrastructure on site should focus on providing a similar experience to the adjacent Ancient Woodland to keep people on-site. Mitigation options for recreational disturbance can include
offsite works such as signage, fencing and footpath creation within the protected sites to minimise recreational disturbance such as trampling of vegetation, dog fouling, and disturbance of wildlife.
Site Allocations
Several of our points can be applied across all of the site allocation policies;
• We recommend removal of all mentions of ‘where practicable’ in reference to the retention of existing habitats, woodland and hedgerows, and creation of linkages of surrounding wildlife assets. In order to comply with the NPPF, para. 175, ‘if significant harm to biodiversity resulting from a development cannot be avoided, adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused’. The NPPF also stresses the importance (para 171) of taking a ‘strategic approach to maintaining and enhancing networks of habitats and green infrastructure’. By including the words ‘where practicable’ you allow for the possibly of destruction of priority habitats and the loss of biodiversity.
• It is Natural England’s opinion that the vast majority of the site allocations should require an ecological management plan and subsequent ecological mitigation to be provided. Unless you know there is mitigation required, then remove the ‘as required’. The discrepancy on how biodiversity is considered between site allocations is currently inconsistent with NPPF para. 170 and Policy NE1.
• All site allocations should require the provision of a measurable net gain in biodiversity, to remain consistent with para. 170 (d) of the NPPF.
Habitats Regulations Assessment
Natural England provided a response on the 18th November 2020 agreeing with the conclusions reached in the Addendum Habitats Regulations Assessment (HRA) and Appropriate Assessment.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter only please contact me.
Yours sincerely,
Ellen Satchwell
Sustainable Development Lead Adviser
Thames Solent Team

Attachments:

Support

VALP Further Main Modifications

Representation ID: 3752

Received: 08/02/2021

Respondent: Crest Nicholson

Agent: Savills

Representation Summary:

The HRA Addendum is considered to be robust and appropriate assessment, presenting information on the further main modifications and finding no adverse effect on the sites assessed.

Full text:

The Habitat Regulations Assessment Addendum provides an update to the HRA of the Local Plan Submission (2019) (included in Appendix A) and assesses any implications on European Sites of the main modifications listed within the proposed main modifications and should be read in conjunction with the HRA of the Local Plan Submission.

The HRA Addendum is considered to be robust and appropriate assessment, presenting information on the further main modifications and finding no adverse effect on the sites assessed.

The HRA Screening of the Local Plan Submission identified the effects of recreational pressure and air pollution on the Chiltern Beechwoods Special Area of Conservation and the Aston Rowant Special Area of Conservation, as key issues.

With regards to recreational pressure, site allocations located further than 7 km from the SAC were considered unlikely to result in any notable contributions to recreational pressures, either alone or in-combination. As a result, the potential for the VALP to result in likely significant effects on Aston Rowant SAC, either alone or in-combination, were ruled out due to distance of Aylesbury Vale District (as was) to this SAC.

It was predicted that housing increases within 7km of the Chiltern Beechwoods SAC could contribute, either alone or in combination, to likely significant effects associated with increases in recreational pressures.

The key findings as a result of a review of the main modifications to determine the potential for changes to the HRA conclusions previously reached, reads positively. In particular, it is noted that in this context, the level and spatial distribution of growth is broadly consistent with the Local Plan Submission.

Site reference D-WHA001 Shenley Park, which is the subject of FMM058, is not within the relevant distance for recreation pressure or other environmental effect in respect of either SAC site.

Object

VALP Further Main Modifications

Representation ID: 3768

Received: 03/02/2021

Respondent: Wendover Parish Council

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Officer summary:

The A413 has not been considered in the effects of the major housing developments on the SAC sites.

Water resources issues have still to be addressed for this water and sewage stressed area, where are the plans for this?
The Weston Turville reservoir SSSI, the Bacombe Hill Local Nature Reserve or the Chilterns Area of Outstanding Natural Beauty in general.) will need support and protection from recreational pressures. They have not been identified as protected open spaces in these HRAs.
Whilst Air Pollution effects have been estimated for the Beechwoods SAC and Aston Rowant SAC, there are no figures for the A413 on the Chilterns AONB etc, which is highly congested in normal times with schools, jobs etc.

Full text:

Wendover Parish Council agrees in principle with the majority of the VALP main modifications 2020-21.
There are four concerns:
ED247 HRA
In this document, the A413 has not been considered in the effects of the major housing developments on the SAC sites. There is no mention of the effects on Coombe Hill NT site, the Weston Turville reservoir SSSI, the Bacombe Hill Local Nature Reserve or the Chilterns Area of Outstanding Natural Beauty in general.
ED247A
In this appendix
“Chapter 5HRA Screening Vale of Aylesbury Local Plan 2013-2033June 2019LUC I 48 SSSI
Water resources
4.42 ....‘The results of the Thames Water supply assessments show that for most settlements, proposed development is unlikely to have a negative impact on water supply. Some settlements including Aylesbury, Haddenham and Wendover have insufficient resources but there is planning and funding in place to meet future demand. In terms of water supply infrastructure, development at most settlements would have a low impact on the local network. However, development in locations such as those listed above, would have a significant impact on supply infrastructure and would require significant investment to accommodate new demand’.
These issues have still to be addressed for this water and sewage stressed area, where are the plans for this?
5.26 The TBH Delivery Framework (DF) – which is endorsed by Natural England, and which was scrutinised for robustness and appropriateness by the Technical Assessor of the South East Plan – suggests that at distances between 400m and 5km, residential housing is likely to result in significant effects associated with recreation. Beyond this distance, the Assessor recommended that larger developments between 5 and 7km from the SPA be assessed and may be required to provide appropriate mitigation.....
5.27 As specified above, it has been assumed that housing increases within 7km of the Chiltern Beechwoods SAC could contribute, either alone or in combination, to likely significant effects associated with increases in recreational pressures. The Ashridge Commons and Woods , which was identified as being particularly sensitive to recreational pressures, is located over 7km from housing allocations specified in the VALP, and therefore is not expected to be significantly affected by increases in recreational pressures.

5.28 The only housing allocation within 7km of the Chilterns Beechwood SAC is HAL03 (RAF Halton). This site is located 2.9km to the west of Tring Woodlands SSSI, and 5.3km to the northeast of Ellesborough and Kimble Warren SSSI ....”

In the current lockdown climate the pressure on recreation spaces and those cited above, has been huge. Large numbers of residents from Aylesbury and the surrounding areas are driving to these sites and causing enormous erosion of paths and trampling across tracks of grassland. With further increases in the local population these areas (Coombe Hill NT site, the Weston Turville reservoir SSSI, the Bacombe Hill Local Nature Reserve or the Chilterns Area of Outstanding Natural Beauty in general.) will need support and protection. They have not been identified as protected open spaces in these HRAs.
Air Pollution
Whilst the effects have been estimated for the Beechwoods SAC and Aston Rowant SAC, there are no figures for the A413 on the Chilterns AONB etc, which is highly congested in normal times with schools, jobs etc. The negative effects of HS2 have also been omitted even though HS2 will be the biggest multiplier of traffic generated pollution for the period of the VALP. The A413 is now a preferred route for HS2 construction traffic according to recent updates, creating more issues.

Sheila Bulpett
On behalf of Wendover Parish Council

Attachments: