24th November 2017 Presentation on behalf of the RAMS Project Steering Group by Alison Collins (Natural England), Clare Dawson (Babergh Mid-Suffolk District Council) and Natasha Moreno-Roberts (Ipswich Borough Council).
What is the purpose of the Recreational Disturbance Avoidance and Mitigation Strategy (RAMS)?
It is a means of facilitating residential development whilst at the same time adequately protecting Suffolk’s coastal, estuarine and heathland European wildlife sites from harm.
This harm could potentially occur because of increased recreation pressure arising from the new housing growth.
What do we mean by recreation pressure? ď ľ
New residential growth brings new residents to the local area, and if those residents use the European sites for recreation, which evidence suggests, then increases the pressure on European sites as a consequence.
Why is the mitigation necessary?
The need to protect European wildlife sites was first identified in the Habitats Regulations Assessments (HRAs) of the currently adopted local plans for the following local planning authorities (LPAs):
Ipswich Borough Council
Babergh District Council
Suffolk Coastal District Council
Habitats Regulations Assessments / Appropriate Assessments of these plans identified that it was possible to conclude no adverse effect on the integrity of European sites in terms of recreational pressure provided that a suite of mitigation measures were put in place to address the identified impacts.
Why aren’t other LPAs included in the RAMS?
The RAMS covers the requirements under the current plan period, where there is an existing requirement for Babergh, SCDC and IBC to mitigate. This is Phase 1 of the project.
The RAMS will be reviewed 18 months after its adoption. This would take into account the mitigation that will be required for forthcoming Local Plans such as Mid-Suffolk and Waveney and strategy monitoring information. This is Phase 2 of the project.
Whilst not currently included in the RAMS, relevant LPAs have been involved in the development of the RAMS including at the stakeholder event.
Natural England has used the evidence from the RAMS to inform its HRA mitigation recommendations for other relevant projects and plans.
Where are the European wildlife sites in question? Special Areas of Conservation
Special Protection Areas
Why is the strategic mitigation approach being taken?
Plan level HRAs for each LPA noted the key elements of mitigation, but highlighted the need for further consideration and information gathering relating to mitigation, particularly in relation to measures on the European sites to manage access.
Key mitigation measures included:
Provision of a new Country Park (IBC and SCDC)
Provision of green spaces as part of new development (IBC, BDC);
Visitor management measures for key European sites (IBC, SCDC and BDC); and
Monitoring the impact of recreational pressure on birds in protected sites (IBC, SCDC and BDC).
To make mitigation delivery more co-ordinated, efficient and effective, a joint and strategic approach is being established by the LPAs, on the advice of Natural England and with support from Suffolk County Council.
Interim Measures Mitigation agreed through individual project level HRAs Collection of funds from developers Via Supplementary Planning Document and associated documentation
SANGs Ipswich Garden Suburb Adastral Park
RAMS Delivery of mitigation projects as set out in the Strategy
Gathering evidence for the RAMS
The stakeholder workshop
Patterns of recreational use
• • • • • •
On the land? In the water? At present? In the future? Which are the most disruptive? Any trends?
Sensitive locations at Specific mitigation the European Sites measures for sites/sensitive locations E.g. nesting sites, shoreline, etc.
• • • • •
Prioritisation Sequencing Costs Synergies Possibilities
Desktop study e.g.
Review of reports, surveys and assessments relating to the study area
Analysis of emerging best practice from other strategic mitigation scheme.
Creating the zones of influence
Determining Housing Numbers in the Zones
What allocations and windfalls fall inside the zones?
Whole of Ipswich
2 zones for SCDC, some areas outside of zones
1 zone for Babergh, some areas outside of zones
It applies to the residential development being delivered in the ‘plan period’ i.e. from 2011 onwards.
It applies to all net increases of dwellings that are built/get planning permission in the plan period i.e. whether one dwelling or a scheme of 3,500 dwellings.
It does not apply to extensions of existing dwellings
Does RAMS apply to all residential developments?
Yes, all residential dwelling types whether affordable or market homes:
gypsy and traveller pitches
housing for the 'mobile' elderly, BUT NOT care homes for elderly or infirm who have significantly reduced mobility
What mitigation is required? 1.
Signage, Interpretation and awareness raising
Suffolk Coast and Heaths dog project
Site specific projects and longer-term measures
Audit of car-parking
Dog related measures
E.g. Codes of Conduct for watersports, cycling, new signs…
Delivery officer, warden(s)
E.g. re-routing paths, bye laws, car park charging
SANGs and green infrastructure
Ipswich Garden Suburb and Adastral Park
How have the costs of mitigation been minimised?
The RAMS steering group is working to ensure:
Efficient governance of the RAMS
Efficient RAMS delivery and model for hosting of staff
Dovetailing the RAMS into existing initiatives
No duplication through working with stakeholders to identify gaps
There will be ongoing stakeholder engagement in the RAMS to ensure that the benefits of the RAMS are maximised.
How are we calculating the costs?
The overall cost, determined by adding up all estimated costs for the mitigation projects is approximately £2.5 million.
This will be split across the four zones in accordance with housing to be delivered and the potential risks to European sites posed by each zone (as per the evidence set out in the RAMS).
We will then calculate a tariff to be paid per dwelling on commencement of the development.
Some measures will be weighted to target delivery in some sites more than others.
E.g. the warden resource is not spread equally across sites, but is divided in accordance with the relative need for a staff presence on site as part of the mitigation package.
The final tariff per dwelling is currently being finalised by the LPAs and the consultants advising on the strategy.
Why should the developer pay into the RAMS?
Facilitating residential development and speeding up planning applications
Polluter Pays Principle
Meeting legal requirements for planning and biodiversity
Relevant to planning - fair
Relevant to the development
Timely and implementable
Using the RAMS - practicalities
Translating the RAMS into the planning process
Requirement for an SPD
Governance and accountability
Importance of communication
Local authority partnership
Understanding planning and biodiversity legislation
How to make this user friendly for the applicant and DM officers:
What happens next?
LPAs currently developing template legal documents and SPD
Final tariff being calculated
Further discussions with Natural England regarding the Coast Path
Strategy and SPD to go through LPA committees in Spring 2018
Phase 1 of RAMS in place Spring 2018
Appointment of delivery officer in Summer 2018
Phase 2 of RAMS to be planned once delivery officer in post
Published on Jan 9, 2018