HRA - Public forum - Planning Advisory Service (PAS)

Hi Fiona, You will need to do another HRA, but this can be a revision to your previous HRA which updates it to reflect the changes to the Core Strategy since the second draft. You might find the RSPB's guidance useful. You can find it here: http://www.rspb.org.uk/Images/spatialplansengland_tcm9-168180.pdf If you have any queries I'll be happy to answer them. Best wishes, James

Hi James thanks for your reply. I'll have look at the guidance. Best wishes Fiona

I was wondering whether you are doing the HRA in-house or whether you intend to get consultants. My Council has had two HRAs completed - one for our Core Strategy and one for an AAP, both done by different consultants, but I haven't been particularly impressed with the results. We are now working on our allocations DPD and I can't help thinking that we should be able to do the HRA for that in-house.

On the basis of advice Natural England gave us, we had a neighbouring Unitary Authority's ecologist prepare a methodology for us then undertook the screening assessment ourselves (in-house). The HRA has then been updated as a rolling draft throughout the Core Strategy's development. Doing the HRA this way has helped us keep a handle on the process, rather than being left to interpret someone else's assessment. While we have been happy to undertake the screening stage (with the author of the methodology acting as a 'critical friend') having not identified any significant effects, we would need further 'expert advice' to undertake an AA.

This isn't the "stupid questions" forum, but I'm assuming you're talking about something other than the Housing Revenue Account ? Could someone take 1 minute to explain what an HRA is, and why new housing figures might alter an appropriate assessment process ?

An HRA in this context is a Habitat Regulations Assessment (which can include an Appropriate Assessment). The question why housing figures may affect the outcome is illustrated by the position of the authorities around the Thames Basin Heaths Special Protection Area (Berks, Hants & Surrey). Natural England has advised that increases in population within 5km of the site could lead to further recreational disturbance impacting upon the breeding success for which the site was designated. In line with the requirements of the European Commission's Habitats Directive (from which the HRA requirement derives), an authority must consider all plans and projects around the site and work out if there are any cumulative impacts. With respect of the Thames Basin Heaths and the level of additional housing envisaged during the drafting of the South East Plan, there could be harmful impacts upon the breeding success of the birds. To address this, authorities need to undertake HRA of plans and projects (LDF documents and planning applications as appropriate). Unlike some of the other authorities, due to Wokingham Borough's proximity to the Thames Basin Heaths SPA, we have had to do a number of HRA associated with LDF documents.

Graham, you are a gentleman and a scholar. I continue to learn something new every day.

Hi Fiona, You raise a pertinent issue. National guidance on the HRA process is not as clear as it could or should be; it could benefit from a refresh. Ideally, a singular and comprehensive guide to best practice and procedural compliance, approved and sponsored by the government and its agencies, would be available. It would be up to date and be prepared in the context of the Conservation of Habitats and Species Regulations 2010. Guidance on Habitats Regulations Assessment has been published in draft form by the government (DCLG, August 2006: Planning for the Protection of European Sites: Appropriate Assessment). Natural England (David Tyldesley and Associates, February, 2009) has produced draft internal guidance on the assessment of local development documents regional strategies under the provisions of the Habitats Regulations. As part of our work with LPAs we have usually used a combination of these methodologies. Natural England has always been helpful and supportive. Can I suggest you liaise with them in the first instance to establish a way forward? PS They are always very busy!

The first part of HRA work is doing a screening report to assess whether any European sites are likely to be adversely affected. Many authorities probably will not need to go beyond the screening report stage. We had to revise our Core Strategy screening report to satisfy Natural England. It did and now they are quoting it as good practice and will be using it as part of some training they are doing in Cumbria. They will also be revealing their checklist for screening reports so we can all see what they are looking for. See attached.

Kick-starting this discussion again:

 

Having undertaken an HRA for our Core Strategy, is it necessary to regurgitate this for the emerging Site Allocations DPD, given that it is in accordance with the Core Strategy and is therefore unlikely (as far as I can tell) to throw up any new issues/potential impacts?