Watford Local Plan Part 2 Publication Stage Environmental Report Appendix 3: Consultation Comments August 2016
Appendix 3 - Responses to Consultation of the Local Plan Part 2 As required by the SEA Directive, consultation has been undertaken at several stages of the process. The reports to date which have been consulted upon include: Local Plan Part 1 (Core Strategy) Scoping Report (February 2006); with subsequent consultations during the development of the Core Strategy. Details of the consultation responses and how they were taken into consideration are provided in the Appendix D of the Core Strategy SA Report (May 2011) Local Plan Part 2 Development Management Policies Options Proposed 1st Consultation Version Sustainability Appraisal Report (November 2013) No SA related responses were received during this consultation. Local Plan Part 2 Site Allocations Plan Options Proposed 1st Consultation Version Sustainability Appraisal Report (November 2013) A summary of the representations received and the actions taken in response are provided in the following tables. Local Plan Part 2-2 nd Consultation Version Environmental Report (December 2014) A summary of the representations received and the actions taken in response are provided in the following tables. Local Plan Part 2-2 nd Consultation Version Environmental Report Addendum (December 2015) A summary of the representations received and the actions taken in response are provided in the following tables. A3-1 August 2016
Comments on Site Allocations Plan Options Proposed 1st Consultation Version SA Report (November 2013) Summary of Comments Reply to comments / how the comments have been taken on board Historic England The SA comments do not refer to any impacts on conservation areas, or the use of The Council s conservation area appraisals in taking schemes forward. Where relevant the SA now identifies where there are potential impacts / opportunities relating to site allocations and Conservation Areas. Comments on Local Plan Part 2-2 nd Consultation Version Environmental Report (2014) Summary of Comments Reply to comments / how the comments have been taken on board Natural England Habitats Regulation Assessment With reference to the Habitats Regulations Assessment (1.6), Natural England agrees with the conclusion drawn that there will be no adverse effect on the integrity of the nearest European sites (a.k.a. Natura 2000 sites) from the implementation of the policies in Watford Borough Council s emerging Local Plan. The two nearest N2K sites are Chilterns Beechwoods Special Area of Conservation (SAC) (close to Berkhamsted) and Wormley-Hoddesdon Park Woods SAC (close to Hoddesdon). This current advice aligns with that given to your Council in May 2011 (our ref: 23132-Watford AA Screening). SA Objectives Natural England supports the principle of the Sustainability Objective for Biodiversity: 1. To protect, maintain and enhance biodiversity and geo-diversity at all levels, including the maintenance and enhancement of Biodiversity Action Plan habitats and species in line with local targets. Hertfordshire Ecology A3-2 August 2016
Appendix 1 - Review of other Policies, Plans and Programmes Reproduced from Watford Borough Council Core Strategy SA Report Extract (updated in May 2013) 1) A1-15 Should the paragraph below be replaced with National Planning Policy Framework (NPPF) as PPS no replaced? Section 1.03 National Draft PPS: Planning for a Natural and Healthy Environment (2010) In its final form this PPS will replace Planning Policy Statement 9: Biodiversity and Geological Conservation (PPS9); Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation (PPG17); Planning Policy Statement 7: Sustainable Development in Rural Areas (PPS7) in so far as it relates to landscape protection (paragraphs 21 to 23), soil and agricultural land quality (paragraphs 28 and 29) and forestry (paragraph 33); and Planning Policy Guidance 20: Coastal Planning (PPG20) in so far as it relates to coastal access, heritage coast and the undeveloped coast (paragraphs 2.9, 2.10 and 3.9). It takes account of the commitment in the 2007 white paper Planning for a Sustainable Future to streamline existing PPGs and PPSs and separate out policy from guidance. The review of other Policies, Plans and Programmes for the Local Plan Part 2 has been rationalised to only consider County and Borough level PPPs, with the exception of the inclusion of the NPPF. This comment will be taken into account when undertaking a full review of all PPPs during the SA of the Local Plan Strategy 2016-2036. Appendix 2 Baseline Information Reproduced from Watford Borough Council Core Strategy SA Report - (updated in May 2013) 2) Refers to English Nature throughout - this should be Natural England Taken into account during the assessment. 3) A2-6; 2. Biodiversity 2.1. Relationship with other Plans and Programmes PPS9 Biodiversity and Geological Conservation - this should be replaced with National Planning Policy Framework / NPPF Section 11 Conserving and enhancing the natural environment. 4) On A2-9.The following sites have been identified for nature conservation by Watford Borough Council and the locations of these sites have been taken into account, in the assessment of the LDF: The Lairage Land has Local Nature Reserve and County Wildlife Site status; Harebreaks Wood has Local Nature Reserve, County Wildlife Site and Ancient Woodland status; Land within Cassiobury Park has Local Nature Reserve and County Wildlife Site status and is also an Invertebrate Site; Albans Wood is part of the Ancient Woodland Inventory and has Local Nature Reserve and County Wildlife Site status; Garston Park is a County Wildlife Site and Protected Species Area; Oxhey Park has County Wildlife Site status. A mixed list, but I know how it came about. Originally, these were all listed as LNRs. But as they are not all LNRs, the LNR label has been removed from the last two sites. However, that leaves the last two sites with the The Section has been updated to refer to the NPPF. The baseline has been updated to provide the additional information. A3-3 August 2016
County Wildlife Site status label. In addition, Garston Park also has Protected Species Area label, which is not a label / status anymore and needs removing. There are currently 27 County Wildlife Sites in Watford Borough (as of December 2013): Albans Wood Ascot Road Scrub Brightwells Farm Grassland & Old Pit Cassiobury Park Cassiobury Park Nature Reserve Croxley Green Junction Sidings Gade Avenue Gammons Lane Wood Garston Park - East Grassland Greenbanks Wood Haydon Hill Pastures and Pond Hempstead Road Wood Holywell Farm Allotments Jacotts Hill/West Herts Golf Course Leavesden Aerodrome North and South Long Spring and Harebreaks Wood (Watford) North Watford Cemetery North Western Avenue (A41) Roundabout and Banks Oxhey Park River & Margins River Colne near Binghams Pumping Station River Colne, Bushey Hall Farm Rough Wood Russell Lane Wood Stanborough Park Woods South The Lairage Land Tunnel Woods Woods E. of Railway, Meriden A3-4 August 2016
5) Page A2-10 This currently mentions 2006 Quality of Life report but this has been updated since. Therefore replace: Hertfordshire s Quality of Life Report 2006 Report reports a number on indicator species which could potentially be used for monitoring: Water voles (declining, reflecting the national trend); Bats (dominated by the Natterer bat and Dauberton s bat; in steady decline since 2001); Grey heron (reflecting wetlands; 121 nests, regional decline and national increase); Skylark (reflecting farmland; 1994 to 2005 numbers declined by 18% in England and 20% in Eastern region. Hertfordshire numbers increased by 1% 2002-03); Song thrush (reflecting woodland and mixed farmland; increasing against regional decline and national increase); and, House sparrow (reflecting urban environment; declining in line with regional trend, no obvious national trend). With: Hertfordshire s Quality of Life Report 2013 Report reports a number on indicator species and sites which could potentially be used for monitoring: Birds - Despite long term declines since 1970, woodland and wetland bird trends have shown slight improvements since 2009. Farmland birds continue to decline and are now at their lowest, half of their 1970 level. Song Thrush numbers declined by 14% and House sparrows by 5% between 2008-2009 in Hertfordshire. Butterflies - The UK Butterfly Monitoring Scheme http://www.ukbms.org/ reported that Washout 2012 was the worst year for UK butterflies on record with 52 out of the 56 species monitored suffering declines. Water voles over half of the sites surveyed in 2013 were negative for Water voles. About a third were positive. There were no records from the Gade, Bulbourne or Ver but they survive on the Colne. Mink (one of the main threats to Water voles) control is still being undertaken. Damselflies and Dragonflies 2012 was a poor year in Hertfordshire and nationally. The baseline for the Biodiversity topic has been updated, using the 2014 Quality of Life Report to provide the equivalent information to that suggested in the Hertfordshire Ecology comment. A3-5 August 2016
Comments on Local Plan Part 2-2nd Consultation Version Environmental Report Addendum (2015) Summary of Comments Reply to comments / how the comments have been taken on board Natural England Natural England is in agreement with your assessment of the amended and additional policies. Cassiobury Residents Association Re Policy GI6 Sports Facilities - any increase in traffic in residential areas contributes to congestion and air pollution and affects air quality and residents' amenity. This greatly affects the local environment - the objectives and assessment appear to overlook this detrimental effect. The representation is based on the assumption that Policy GI6 will result in increased traffic. The main aim of the policy is to protect existing facilities. If those facilities were lost to other uses (housing for example) the traffic in those specific areas would be likely to increase overall. Historic England Together with the 2014 Environmental Report the findings support Historic England's suggested changes to policy TB1 to emphasis matters of significance, setting and context. The Addendum reinforces the need for the use of a robust and comprehensive method of assessment such as that provided by Historic England's Good Practice Advice Note AN4. A3-6 August 2016