Habitats Regulations Assessment (HRA)
Natural England concurs with the conclusions drawn in the HRA, which state that no adverse effect on integrity of Ashdown Forest is expected to result from development provided by the Sevenoaks Local Plan, even in combination with other plans and projects. However, we note that the wording of the HRA appears to confuse the terms ‘likely significant effect’ and ‘adverse effect on integrity’. The conclusions refer to likely significant effects, although adverse effects on integrity are discussed in the Appropriate Assessment chapter. The conclusions should be updated to reflect this, and it should be ensured that consistent wording is used throughout the HRA.
Nevertheless, we support the precautionary approach confirmed in Policy 5 (Ashdown Forest) which states although all site allocations are a minimum of 11 km from the Ashdown Forest SPA/SAC, any new housing within the 7km zone will contribute to the Strategic Access Management and Monitoring (SAMMs) mitigation scheme adopted by the relevant councils (of which Sevenoaks is one). We also support the indication in the HRA that any windfall development within 7km will contribute to SAAMS scheme, however we would advise that these are considered under an appropriate assessment at project level.
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