Record of Meeting
Project
Habitats Regulations Assessment of the Mid Sussex Core Strategy
Date
21st January 2009
Time
10am
Venue
Mid Sussex District Council Offices, Oaklands Road, Haywards Heath
Subject
Draft Appropriate Assessment Report
Page
1 of 4
Attendees
Marina Brigginshaw
Wealden DC
Louise Bardsley
Natural England
Jayne Field
Natural England
Alma Howell
Mid Sussex DC
Nick Pincombe
UE Associates
Ed Sheath
Mid Sussex DC
Nathan Spilstead
Mid Sussex DC
Julia Wallace
ATLAS
Apologies
Claire Tester
Mid Sussex DC
Item
Action
1.
Introductions
AH introduced the agenda and invited everyone to introduce themselves to the group.
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2.
Background to Core Strategy and Habitats Regulations Assessment
NP briefly described the background to the HRA process for the Core Strategy, and UE-A’s
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involvement so far. A Screening Statement was prepared by MSDC in late 2007. Natural
England agreed with its main findings but recommended that further detail be added. MSDC
commissioned UE-A to provide this, and an expanded Screening Statement was published in
January 2008, including details on the scope of the appropriate assessment.
Throughout the remainder of 2008 most UE-A activity was focused on two baseline studies to
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inform the assessment (see item 4, below), prior to production of the current draft Appropriate
Assessment Report.
3.
Core Strategy Timetable
ES gave an update on progress with the Core Strategy, and the timetable going forward.
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MSDC is currently working on the Core Strategy Proposed Submission Document. A decision
has been taken to wait until the South East Plan is adopted before entering the Core Strategy
into MSDC political processes; it is anticipated that it will go before Council in July 2009.
Formal submission to the Secretary of State is expected in January 2010, with an Examination in
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Public planned for April/May 2010. Once adopted, the Core Strategy will be built upon by a
series of town-wide masterplans to add further detail.
January 2009
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Record of Meeting: Habitats Regulations Assessment of the Mid Sussex Core Strategy
Item
Action
4.
Evidence Base
NP gave a brief description of the two baseline studies:
a) The Air Quality Baseline Study uses secondary monitoring data and the APIS online
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resource to establish levels of background air pollution across Ashdown Forest. It
demonstrates that the critical load/level is exceeded, or close to exceedance for nitrogen
deposition, ozone and acidifying pollutants.
b) The Recreational Visitor Survey is a primary research project, drawing heavily on
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methodologies established by similar studies elsewhere. Twenty sampling points were
surveyed for eight two-hour periods each, where visitors were asked to respond to a
questionnaire and visitor activity was observed. The report provides extensive data
analysis and reveals a probable local catchment area of 13km. Total annual visitor
numbers are estimated at 1.354m.
Discussion ensued, particularly regarding the visitor survey. Limitations to the project, as
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described in the report, were discussed and accepted. LB pointed out that it was very unusual
for such a study to indicate that visitors on foot originate from more than 0.8-1km from the point
of entry. Furthermore, modelling outputs that suggest residents living only 300m away would
only visit the Forest once every three years were also believed to be unusual.
There was general agreement that, assuming the analysis is correct, the study does provide the
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best baseline available as it can only report the findings of data collected in the field. NP to re-
check data and analyses to try and explain the anomalies.
LB suggested further analysis to what is already contained in the report, to investigate any
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patterns between the routes taken while on the Forest, distribution of bird territories and habitat
mapping. The results of such analysis should be used in conjunction with a comparison of local
and national bird trend data to further develop an understanding of whether the SPA is currently
experiencing negative effects. If the results of these analyses do not return a clear answer, the
following assumption must apply: that the current level of activity is acceptable (with harm to
ecological integrity) but that any increases in visitor numbers would lead to adverse effects. This
is a defendable precautionary approach.
LB also highlighted the use of SSSI conservation objectives in the AA report, and recommended
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they were shortened to only include SAC/SPA objectives.
5.
Discussion of Appropriate Assessment
NP introduced the draft AA report and discussion ensued:
a) Methods and approach
The methods and approach employed were deemed appropriate. NP invited opinion on the
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use of ‘proportionality’ in the assessment. LB confirmed that, unless the evidence base is very
strong, there are inherent risks and uncertainties involved, and recommended against its use in
this project.
JF and LB asked for greater clarity to be brought to the assessment findings, possibly through
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the use of additional matrices.
January 2009
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Record of Meeting: Habitats Regulations Assessment of the Mid Sussex Core Strategy
Item
Action
Continued…
b) Quantifying impacts, determining significance
There was discussion on the means adopted for quantifying impacts and determining
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significance. The approach used was broadly endorsed by the meeting, subject to the various
actions outlined in this record.
c) Avoidance/mitigation strategy
Options for avoidance and mitigation were discussed at length. NP began with a summary of
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what he believed to be an appropriate strategic overview, for agreement with the group. The
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main principles of this approach are:
Agreement should be sought on an appropriate quantum of SANGS provision (for
example, 8ha/1000pop) to address impacts of the larger housing allocations that fall
within the 13km catchment area of the Forest, excluding East Grinstead;
Improved accessibility to surrounding countryside for the smaller towns’ and villages’
housing allocations, to make best use of existing resources;
Agree a lower level of development for East Grinstead (for example, c.1,500 homes –
N.B. MSDC reported that a decision to scope the potential for reduce development at
East Grinstead to this level had already been taken internally);
Do not pursue East Grinstead relief road link 3b (the southernmost link);
Explore opportunities to the south of East Grinstead for the provision of SANGS to
accommodate the level of development required, making best use of existing
environmental capital (including open space, landscape, ancient woodland and heritage
assets; and
An access management strategy for Ashdown Forest, ideally signed up to by all local
authorities surrounding the Forest, and to be delivered by the Conservators with funding
provided by developers through the planning system, possibly through a joint SPD.
A more detailed avoidance and mitigation strategy will also need to establish multifunctional
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benefits from the provision of new green space, to promote other policy objectives, as well as
MSDC
setting the terms of reference for the access management strategy. In addition, the Leisure
Strategy and provision of PPG17 requirements should link with Core Strategy delivery.
Specific attention was given to the ‘menu’ of avoidance and mitigation measures set out in the
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draft AA report. A summary follows:
Air quality: remove measures 1, 2, 3, 4, 5; retain but amend measures 6, 7, 8.
Disturbance: retain all measures, but re-word and move the content of most measures
to within the access management strategy.
Given the limitations of the visitor survey, its apparent underestimation of visitor numbers, and
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the possible risk of challenge to it as the basis for decision-making, UE-A would advise MSDC to
maintain a precautionary approach to housing numbers and the level of provision for avoidance
and mitigation.
d) Residual effects and in combination assessment
Once the avoidance and mitigation strategy is agreed, any residual effects will need to be
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assessed in combination with other plans and projects. LB confirmed that of any significant in
combination effects identified, only the element of the effect that is generated by the Core
Strategy needs to be mitigated by MSDC.
January 2009
DRAFT_TESS-0023_meeting_record210109NP
Record of Meeting: Habitats Regulations Assessment of the Mid Sussex Core Strategy
Item
Action
6.
Next Steps
JF agreed to provide written comments on the draft Visitor Survey and AA reports within two
JF
weeks if possible.
In a post-meeting AH and NP agreed that the next phase of work on the AA would most likely
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commence in mid-April, after the strategic housing sites had been to committee.
NP agreed to issue a final version of the Visitor Survey report approximately two weeks after
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receiving comments from JF, depending how extensive the comments are.
7.
AOB
For information, strategic housing allocations are likely to include (over and above Small Scale
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Housing Allocations DPD and sites coming forward through the LPR):
1,000-1,500 distributed among the villages, to include small scale greenfield urban
extensions (<50 dwellings) to satisfy local need at some of the more substantive
settlements;
c.4,200 at Burgess Hill, mainly to the north and east of the town;
c.1,600 at Haywards Heath and Lindfield; and
1,000-1,500 at East Grinstead, which is a reduction from the Structure Plan allocation of
2,500.
The larger strategic allocations will all need to accommodate some employment land as well.
January 2009
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