Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document

(3) Appendix 2:

(4) Relevant impacts of development

Urban effects

5.2 There are particular risks associated with development in such close proximity to European site boundaries. These risks relate to increased recreation use, cat predation, increased occurrence of predators associated with gardens (e.g. Fox Vulpes vulpes, Magpie Pica pica, Brown Rat Rattus norvegicus), increased fire risk (garden bonfires, Chinese lanterns, barbeques), dumping of garden waste and the physical proximity of the built environment. The impacts of urbanisation and the synergistic effects of development have been the subject of a range of reviews (Chace & Walsh, 2006; Mcdonald et al., 2008; McDonald & Boucher, 2011; Underhill-Day, 2005).

5.3 These issues are relevant where the housing is in direct proximity to the edge of the European site and creates particular pressures around the periphery of the site. In general, more houses are likely to result in greater levels of impact and the impacts relate to wherever there is development close to the boundary.

Recreation

5.4 Increased recreation use of nearby countryside sites is related to urban growth and impacts can extend over considerable distances. We treat recreation and urban effects therefore as separate issues, though they are closely linked. Recreation involves people walking, cycling or driving to the European site for recreational activity such as dog walking, jogging, walking etc. This can lead to impacts such as disturbance to birds, trampling damage and increased fire risk. A summary of the different impacts from recreation is provided in Table 3.

Impacts to supporting habitats

5.5 A number of qualifying features of the South Pennine Moors SPA Phase II SPA are relatively mobile species and will use areas outside the SPA boundary. This is particularly the case with some of the wading birds such as Golden Plover and Curlew which will forage in areas outside the SPA. For example, birds nesting on the moors could use nearby pastures to feed.

5.6 The issues are relevant for the following species: Golden Plover, Curlew, Lapwing, Ring Ouzel and Twite. Development that affects the quality or availability of supporting habitat clearly has implications for the SPA population and has the potential to undermine the conservation objectives. Risks could include the direct loss of supporting habitat or issues such as infrastructure (power lines), lighting, disturbance, drainage that might affect the suitability for the relevant species. For example, the Supplementary Conservation Advice for the South Pennine Moors Phase II SPA recognises the extent and distribution of supporting breeding habitat for Golden Plover as an attribute and sets a target to restore the extent, distribution and availability of suitable breeding habitat for all necessary stages of its breeding cycle (courtship, nesting, feeding). The explanatory notes clearly state that the objective applies to any critical supporting habitat which is known to occur outside the site boundary. The notes state that Golden Plover may travel up to 4km from their nesting sites to feed. Marginal pastures adjacent to the SPA are also known to be likely important feeding grounds for the birds. Where this supporting habitat is regularly used and 'functionally-linked' to the SPA, it will be key to breeding success on the moorland.

5.7 The importance of functionally-linked land and a summary of relevant case law relating to the Habitats Regulations and HRAs where functionally-linked land is a consideration are provided by Chapman & Tyldesley (2016).

(4) Evidence to underpin the zones

5.8 The justification for the zones defined in Policy SC8 and shown in is set out in detail within the Core Strategy HRA (Cox & Pincombe, 2014) and also set out below.

Urban effects and the 400m zone (Zone A)

5.9 The use of a 400m exclusion zone (i.e. where there is a presumption of no development) has been incorporated into a range of local authority plans to address concerns about urbanisation and urban effects directly on the periphery of European sites. For example, a 400m zone is an integral part of the mitigation package in the following locations:

• Around the Dorset Heaths^[8];
• Across the Thames Basin Heaths (11 local planning authorities)^[9]
• In the Brecks (e.g. Breckland District[10]);
• Around the East Devon Pebblebed Heaths (East Devon District Council^[11]);
• Around Cannock Chase SAC (e.g. Cannock Chase Council Local Plan^[12]);
• At Ashdown Forest SPA/SAC (e.g. Wealden District's Core Strategy Local Plan)^[13];
• At Burnham Beeches (e.g. Draft Chilterns and South Bucks Local Plan 2036)^[14];
• At Epping Forest (e.g. Epping Forest District Local Plan submission version)^[15]

5.10 The exclusion zone provides a mechanism for the most severe impacts to be avoided and ensures protection for the European site. On the South Pennine Moors it helps reduce the scale of impacts relating to functionally-linked land, and recreation impacts, as well as resolving any risks for the wider suite of urban effects.

5.11 The exclusion is necessary as impacts tend to be more severe from development in close proximity and mitigation measures (such as access management and wardening) are likely to be less effective. For example, people living within 400m of the SPA/SAC are likely to use the Moor at a wide range of times of day (and even during the night) and potentially access it from multiple informal access points (e.g. back gardens and cut-throughs). Such use will be by people who have the greenspace literally on their doorstep – their de facto space to use and potentially seen as an extension to their garden. That use will differ from the use by people who travel to the site and make an effort to visit, potentially driving and arriving at a main car-park. Such visitors are much easier to intercept through wardening, interpretation etc. With increased risk and limited effectiveness for mitigation, adverse effects on integrity cannot be ruled out. Mitigation approaches such as alternative greenspace and wardening can be applied for development that is outside the exclusion zone with the confidence that they will work effectively.

Supporting habitat 0.4-2.5km (Zone B)

5.12 The adopted policy follows the advice of the Core Strategy HRA, and subsequent HRA work, that SPA qualifying bird features will move in and out of the European site boundary. SPA birds will regularly use habitat outside the SPA boundary, for example for additional food sources, and this habitat may therefore be of significance in maintaining SPA bird populations, i.e. it is 'functionally linked.' A zone of 2.5km is therefore referenced within the policy as a zone within which functionally linked land could be present and needs to be checked for at the development project proposal stage.

5.13 The risks are more relevant in close proximity to the SPA and therefore the 400m zone ensures a degree of protection for some of the most important supporting habitat.

5.14 Data for relevant species are summarised in Table 2. It can be seen that it is Golden Plover that are the most relevant species and most likely to be using fields well away from the moorland edge.

Table 2: Examples from the literature on the relevant species and use of wider areas during the breeding season

Recreation visits from within 7km (Zone C)

5.15 The Core Strategy HRA considers the data collected during visitor surveys conducted on the South Pennine Moors in 2013. Visitor survey data can help to identify the extent to which people are travelling to the European site. The 2013 data concluded that the majority of visitors were travelling under 7km, and this distance was therefore used in the Core Strategy as a 'zone of influence' within which additional housing may add to the visitor pressure on the moorlands.

5.16 A zone of influence is the zone within which it is deemed that there is an 'influence' or potential impact on a European site. Visitor survey work (i.e. interviewing or counting visitors, cars or dogs on the European site) is used to assess the recreation use of the site by existing visitors, and this provides a means by which predictions can be made relating to future use as a result of new housing. Common practice for mitigation strategies for European sites elsewhere is to look at the distance within which 75% of visitors are travelling to the European site, or to assess the visitor origins on a graph to see the distance at which there is a tail off of visitors, which is normally somewhere near 75% of visitors. Outliers in the survey results are often individuals on less frequent trips or holiday makers. For the 2013 survey data, there was a clear tail off at just under 7km, representing 81% of visitors.

5.17 Taking 7km as the zone of influence, the Core Strategy HRA concluded that measures would be required to mitigate for the recreational impact of new residential development coming forward within the 7km zone. The HRA recommended that a range of measures should be developed, the provision of alternative natural greenspace for recreation and visitor management at the European sites. These recommendations are set out within existing Core Strategy Policy SC8, and now developed in more detail within this SPD.

5.18 Recognising the need to regularly update the visitor survey work, Bradford Council commissioned new visitor surveys to be undertaken in 2019. This survey found that the greatest numbers of visitors to the South Pennine Moors SPA/SAC live in close proximity to the moors, particularly those visiting from postcodes around Ilkley, Addingham, Oxenhope, Haworth and the Airedale area. 21% of visitors were walking to the moors rather than travelling by car. This visitor survey work provides information that will be relevant to the development of this mitigation strategy including the key access points and car parks used, the reasons for coming to the Moors and where they go once they are there.

5.19 The new 2019 survey data is consistent with the 2013 data showing a tail off in visits from postcode origins over 7km. Again, this represents approximately 81% of the visitors surveyed. This now gives confidence that the 7km zone of influence continues to be fit for purpose in informing the zone for this SPD.

5.20 The zone of influence for developer contributions therefore remains at 7km, in accordance with Core Strategy Policy SC8, and will be used as the policy is updated through the Local Plan Review.

5.21 Increased levels of recreation can undermine the conservation objectives in a range of ways. Issues are summarised in Table 3.

Table 3: Impact pathways on interest features (relevant to the South Pennine Moors Phase 2 SPA and South Pennine Moors SAC) potentially vulnerable to recreational pressure. Relevant months describe when the impact can occur. In source/evidence column "SIP" refers to relevant site improvement plan^[16] produced by Natural England.

^[8] Dorset Heaths planning framework

^[9] Thames Basin Heaths Delivery Framework

^[10] See 3.73 in the Breckland Core Strategy

^[11] East Devon Local Plan, strategy 47

^[12] See para 4.89 pf Cannock Chase Local Plan

^[13] Wealden District Local Plan Policy EA2 (note this has since been withdrawn)

^[14] Section 9.3 of the Draft Chilterns and South Bucks Local Plan 2036 (note this has since been withdrawn)

^[15] See Policy DM2 in the Epping Forest District Local Plan submission version

^[16] See relevant part of the Natural England website