Changes to the Appropriate Assessment

 

This document outlines the changes made to the Appropriate Assessment (AA) of SCDC’s LDF Core Strategy. It does not attempt to provide a detailed criticism of the AA, and the changes it mentions are only the major ones. Its purpose is to help people respond to the current consultation (which ends on the 14th October 2011).

 

The actual documents can be found at:

Nov. 2010 version: http://www.suffolkcoastal.gov.uk/NR/rdonlyres/2ADAED7E-17F8-41A5-AF0C-5D9887141883/0/SCDCHabitatsRegulationsAssessmentNov2010.pdf

 

June 2011 version: http://www.suffolkcoastal.gov.uk/NR/rdonlyres/87898E10-800D-4A2D-AF28-1C250F2C2FA5/0/W11204SCDCLDFAppAssessment.pdf

 

Aug. 2011 version: http://www.suffolkcoastal.gov.uk/NR/rdonlyres/58DA2A5F-6450-4052-9A10-7C711E7FB5CD/0/AAReportFinalAugust2011.pdf

 

§1.5 Impacts in combination with other Land-use Plans

This section is new. It first appeared in the June 2011 version. Only minor changes have been made since then.

 

§1.6 Modifications to this Appropriate Assessment

This section describes the changes made to the June 2011 version. However, this is confusing and misleading, since the latest version the public have had an opportunity to comment on in an official consultation (as opposed to NANT’s lawyers and others writing letters to SCDC) is the November 2010 one (which is actually the Sept. 2009 version plus a ‘clarification’ – see below).

 

Here is a summary of the various iterations of the AA:

 

Date Description Public consultation?
Sept. 2009 Original Y
Jan. 2010 Clarification Summary (did not alter the content of the AA but explained some of the technical detail in a different way ‘so that it was clearer’) N
Nov. 2010 Sept. 2009 version + Clarification Summary + letter from NE (Feb. 2010) Y
June 2011 Incorporates changes to LDF Core Strategy Nov. 2010 (housing numbers), IBC’s LDF Core Strategy and the S. Sandlings Report N
August 2011 Changes due to NANT’s lawyers and SWT (see §1.6 for details). Y (this one)

 

The reason given for the latest changes are: “Comments were received by the Council from Richard Buxton on behalf of NANT (No Adastral New Town) dated 6th July 2011, and from Suffolk Wildlife Trust dated 7th July 2011.” No mention is made of the letters sent to SCDC by Waldringfield PC on 6/7/11 or the Suffolk Preservation Society on 7/7/11.

 

§2 European sites potentially affected

No significant changes have been made since Sept. 2009

 

§3 Likely significant effects

No significant changes have been made since Sept. 2009

 

§4 Policies to be assessed

No significant changes have been made since Sept. 2009

 

§5.1

More detail has been provided. In particular, there are sections on ‘The amount of housing proposed in Suffolk Coastal District’ and ‘The amount of housing proposed in Ipswich Borough’. These were missing from the Sept. 2009 version (which made it very difficult to understand what precisely the Sept. 2009 AA was assessing).

§5.1.12

A brief reference has been added to the South Sandlings Report (SWT) and the Deben Estuary Report (NANT).

§5.2.6

A comment from NE about recreational impact on wildlife has been added.

 

§5.3

The main differences in this section are to the way in which the increase in visitor numbers to European Sites has been calculated, and the changes to the resulting figures.

 

All versions of the AA use a 2004 study of visitors to the AONB (as opposed to the Deben Estuary SPA, Newbourne Springs, etc.) to estimate the proportion of day visitors to the AONB who come from Ipswich and Suffolk Coastal District. This is unchanged (see Table 2, §5.3.5).

 

They then attempt to estimate the increase in population due to the extra housing proposed in the SCDC and IBC LDF Core Strategies. This is shown in Table 3. The changes in this table are due to:

  • The housing numbers have changed, mainly due to the replacement of the RSS figures with SCDC’s own figures.
  • A change in the figure used for the ‘number of new people per new dwelling’ in SCDC. In the Sept. 2009 version it was 0.9, in the Aug. 2011 version it is 1.57 (the figure for IBC is unchanged at 1.38). Despite being marginally more realistic, this table (and the accompanying text) still contains hidden within it the unstated assumption that a large proportion of the future residents of the new housing will move out of existing housing in the area, and so will not be adding to the number of extra people living near the sensitive European Sites. The Jan. 2010 ‘clarification’ explained why 0.9 should not be taken as an ‘occupancy’ figure, but failed to explain how it was arrived at, or even mention this hidden assumption. The new figure of 1.57 comes from the Oxford Economics Study, which SCDC rejected, and has also never been explained.

 

A complicated (and largely unchanged) method is then used to produce an estimate for the total percentage increase in visitor numbers to the AONB (again, as opposed to the Deben Estuary SPA, Newbourne Springs, etc.), see Tables 4, 5 and 6. This has increased from 2.48% (Sept. 2009) to 2.83% (Aug. 2011). In both documents these are given as a range of 2% – 5%, “to allow for assumptions about people’s behaviour patterns”. The actual increase in number of people visiting the sites is not given in either version, because the current number of visitors is unknown – see comments on changes to §9, below.

 

§5.4 Impact on European sites in Colchester and Tendring Districts, Essex

This section is new. It first appeared in the June 2011 version. It hasn’t changed since then.

 

§5.5 Calculations to predict additional visitors to European sites in the south Sandlings using 2010 visitor survey data

This section is new. It first appeared in the June 2011 version. Only minor changes have been made since then.

 

§5.6 Impact on specific sites

A new section (§5.6.3) on the 2010 South Sandlings Visitor Survey has been added.

 

No changes have been made to the claims that people are unlikely to walk further than 1km or drive further than 8km. These are based on a 2005 Dorset study. The appropriateness of using this data out of context has been questioned by Waldringfield PC, NE and others, but their criticisms have been ignored.

 

§5.8 Other visitor surveys, comparison of visitor surveys and calculations of impact

This section is new. It first appeared in the June 2011 version. Only minor changes have been made since then. It contains sub-sections on:

  • Comparison of AONB and South Sandlings impacts
  • Deben Estuary Visitor Survey report, July 2011 (by NANT)
  • Natural England national visitor survey (2010/2011)
  • Further Dorset studies (2008) – probably in response to Waldringfield PC’s references to this.

 

§6.2 Policy SP2. Housing numbers

§6.2.13 and §6.2.22 have the added sentence: “However, Natural England has commented that it does not routinely monitor disturbance to birds on Sites of Special Scientific Interest, and recreational impacts may therefore not be included as a reason for unfavourability in condition assessments.” This was added since the June 2011 version. It is not clear if this is relevant, as the areas in question are SPAs as well as SSSIs.

 

In the Sept. 2009 version, §6.2.37 contained a statement about the car parking arrangements at Waldringfield: “The car park at the Deben Estuary at Waldringfield is privately operated for users of the pub and sailing club, and is not available as a starting point for estuary-side walks.”  This was strictly speaking correct at the time, although the car park was widely used by the general public. However, in early 2010 the manager of the Maybush changed the arrangements to the current situation, in which there is a pay-and-display public car park, as well as a private one for Maybush patrons. The statement quoted above was not changed in the Nov. 2010 version or in the June 2011 one, and neither was the conclusion: “Given this lack of available parking, it is possible to ascertain that the integrity of the Deben Estuary at Waldringfield will not be affected by the housing allocations at Martlesham”. Waldringfield PC complained about this in a letter to Cabinet members (dated 6/7/11) and as a result the Aug. 2011 version has 3 new sections, §6.2.34-36. The conclusion quoted above has now been dropped.  (There are many problems with these three sections, which will be discussed elsewhere).

 

§6.2.34 refers to NANT’s Deben Estuary survey in the discussion of the impact of the Felixstowe housing allocation on the Deben Estuary. This has been added since the June 2011 version.

 

The Summary of initial conclusions is unchanged. In particular, it still says: “It is therefore concluded that there would be no adverse affect upon the integrity of the respective European sites.“ (§6.2.45).

 

§7.2 Mitigation for Policy SP2. Housing numbers

§7.2.1 and §7.2.2 have been added since the June 2011 version.

 

§7.2.8 has been significantly expanded since the June 2011 version (in which it is numbered §7.2.6). It is an attempt to describe the requirements for mitigating green space and to convince us that such mitigation is “a good method of reducing pressure on European sites”.

 

Mitigation for all proposed housing in Ipswich Borough and Suffolk Coastal District

Various small changes have been made to §7.2.9-17 since June 2011.

  • The phrase [The new Country Park] “or similar high-quality provision“ appears more often since the June 2011 version. (Is this significant? What other type of ‘high-quality provision’ is there?).
  • §7.2.12 and §7.2.13 were added since the Sept. 2009 version
  • §7.2.16 says more about wardening – this was added since the June 2011 version.

 

Mitigation for housing allocation by Ipswich Borough Council

This sub-section was added since the Sept. 2009 version. Table 10 (§7.2.21) was added since the June 2011 version.

 

§7.3 Implementation of the proposed mitigation

This section is new. It first appeared in the June 2011 version. Since then it has been expanded to include a statement about the use of the Community Infrastructure Levy to pay for the necessary measures. No mention is made of the fact that no actual site has been found, SCC have ceased funding country parks, and no timetable has been proposed for the creation of this hypothetical green space.

§7.4 Mitigation conclusions

No change has been made since Sept. 2009: “It is ascertained that, with the proposed mitigation, Policy SP2 and related housing policies will have no adverse effect upon the integrity of any European site.

 

§8 Conclusions of the Appropriate Assessment

No change has been made since Sept. 2009

 

§9.1 The evidence base

This section has been significantly expanded since the Sept. 2009 version, and minor changes have been added since the June 2011 version.

 

Whilst the lack of data is acknowledged in all versions: “The evidence base for the amount of visitors to European sites is poor for a number of Europe sites, as data is very sparse” (§9.1.1), the obvious solution – to commission a proper scientific study of visitors to the areas in question (Deben Estuary, Newbourne springs, etc) has been rejected: “Although it would have been desirable to have had better evidence of visitor numbers on European sites, it would not be reasonable to delay the Appropriate Assessment, and therefore the Core Strategies and Policies, for a number of years until further evidence was collected” (§9.1.1). One consequence of this is that the current number of visitors to the European Sites remains unknown, and therefore the estimated increases can only be given as percentages rather than actual visitor numbers, which would have been far more meaningful.

 

§9.2 Further work needed

This section has been significantly expanded since the Sept. 2009 version, and only one very minor change has been added since the June 2011 version.

 

§9.2.3 was added since the Sept. 2009 version. Having acknowledged that the data is poor, it makes the highly dubious claim that: “further work is not immediately required for this Appropriate Assessment or the Core Strategies and Policies to progress.”

 

§10 Iterations and Consultations

This section has been added since the Sept. 2009 version, and minor changes have been added since the June 2011 version.

 

 

 

 

 

 

 

 

 

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