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Non-technical assessment
The story of the SA since the main modification’s consultation
1. In January 2019, the council submitted a final draft of the Purbeck Local Plan 2018-2034 and supporting information to the Secretary of State for examination. During the examination process, changes were made to the plan in order to make the plan sound and able to be adopted. The modifications were consulted on between November 2020 and January 2021, and screened and assessed for any significant environmental, economic and/or social effects.
2. Representations raised the following issues which are believed to have merit:
- that the evidence presented during the hearings [SD93] did not demonstrate that the council had fully examined the opportunity to deliver heathland infrastructure projects (including strategic SANG) in locations outside the Green Belt where they would serve a similar function or on sites within the Green Belt without the need for changes to Green Belt boundaries
- that as part of the process of examining alternatives the council did not fully explain its approach to funding the proposed Morden SANG or explore the opportunity to fund (through contributions collected via planning obligations or CIL contributions) heathland infrastructure projects independently of enabling development that required release of Green Belt and
- that the comparison of alternatives did not include an evaluation of whether land to be released from the Green Belt as enabling development was proportionate with the SANG to be delivered (having regard to both its size and its function as part of the Green Belt)
3. Following consideration of these issues, the council believes further changes are necessary to ensure the plan can be found sound.
4. These changes need to be assessed and then consulted on.
The need and location of a strategic SANG
5. The Habitats Regulations Assessment (HRA) to support Purbeck Local Plan Part 1(PLP1) identified a need for a strategic SANG to the north of the then Purbeck District. The need was then confirmed by Natural England at examination.
6. The same HRA identified a possible location for SANG in northern Purbeck , between Bere Regis and Lytchett Matravers (paragraph 5.52). Visitor survey data from Sherfield Bridge carried out as part of the Wild Purbeck project confirmed that most of the visitors to the area, which includes Morden Bog and Hyde Heath SSSI (part of Dorset Heathlands Ramsar, Dorset Heathlands SPA, Dorset Heaths (Purbeck & Wareham) & Studland SAC Dorset Heaths and SAC Poole Harbour Ramsar), are from the north of the site, mainly along the A35 corridor.
7. The need for a strategic SANG is reiterated in SD93: Mitigation Strategy Green Belt, to:
- provide an alternative location specifically for those people visiting Morden Bog SSSI (and the SPA, SAC and Ramsar sites which the SSSI underpins) which is within the wider Wareham Forest area and
- address the additional effects of new housing development expected in this part of the area (including completed and expected windfall development, and allocations from earlier plans)
8. Subsequently the HRA of proposed Main Modifications states that ‘The HRA for PLP1 identified the need for a SANG in the north of the then Purbeck District, and the need for strategic SANG in this area was confirmed by Natural England at examination. In the HRA report at the Partial Review Options stage, the potential for part of the proposal to come forward as a strategic SANG is discussed, i.e. a SANG that provides capacity for absorbing recreation pressure from other developments in the Purbeck area.’ (Paragraph 5.62).
9. Much of the land in the north of Purbeck that might be suitable as a SANG is either owned by the Charborough Estate (western area including Morden) or the Lee’s Estate (eastern area including Lytchett Minster). Strategic SANG options were presented in the Partial Review Options Consultation Document 2016; Morden Park/Wareham Forest (as identified on the policies map of the Purbeck Local Plan) and those SANGs associated with the Bere Farm and Lytchett Minster housing options sites.
10. Natural England advised that:
a) the characteristics of the possible SANG site at Morden/Wareham Forest mean that it will perform more effectively than either of the other alternatives and
b) the position of the Morden Park/Wareham Forest SANG is likely to contribute toward bringing Morden Bog into a favourable conservation status by reducing existing adverse effects (encouraging visitors to use the proposed SANG rather than the adjacent European site) and avoiding likely significant effects from plans and projects (including homes in the Bournemouth Christchurch and Poole Council area as well as the proposed holiday park) (Paragraph 39, [SD93])
11. Natural England advised there were no other strategic SANG locations identified in a suitable location and this was corroborated by the landowner.
Proposals in the Purbeck Local Plan 2018-2034
12. The SANG and areas of the park to be used for informal recreation were not identified for release from Green Belt as these uses conform with paragraph 150 (e) of NPPF which states ‘certain other forms of development are also not inappropriate in the Green Belt provided they preserve its openness and do not conflict with the purposes of including land within it. These are:….material changes in the use of land (such as changes of use for…recreation)…’. However exceptional circumstances for Green Belt release were found for the holiday park, which acted as enabling development for the strategic SANG (see Memorandum of Understanding between: Dorset Council, Charborourgh Estate and Natural England, June 2019), and can be summarised as follows:
- the site will deliver a strategic SANG to mitigate the adverse effects on protected heathland sites generated by construction of new homes in the north of the district. The creation of a SANG in this location would serve a significant strategic function in supporting the delivery of existing and future windfall development. Supporting development in existing towns and villages, and on previously developed land in these locations, is consistent with the NPPF and makes effective use of land
- the effects of the holiday park can be partially offset through compensatory improvements, as the SANG will increase public accessibility into this part of the Green Belt (SD56, Green Belt study 2018 [pre-submission])
What now?
13. Dorset Council and Charborough Estate intended that the holiday park would act as enabling development to support delivery of the strategic SANG. The council continues to support delivery of a strategic SANG at Morden independently of the proposed holiday park. Further discussions are ongoing with the Charborough Estate on this matter.
14. In addition, the Dorset Council Local Plan has completed a regulation 18 consultation in March 2021 and is now progressing towards pre-submission. It is anticipated that this plan will be adopted in 2023 and will consider strategic mitigation measures across Dorset up to 2038.
15. Given the uncertainty around the delivery of a strategic SANG at Morden, and the progression of the Dorset Council Local Plan, mitigating the impacts of residential development on Dorset Heaths SAC, Dorset Heathland SPA, and Ramsar and Dorset Heaths (Purbeck & Wareham) & Studland Dunes SAC (here after collectively referred to as Dorset heaths habitat sites) are considered necessary during an interim period pending adoption of the Dorset Council Local Plan. The council is satisfied that the mitigation measures in its Interim Mitigation Strategy (2018/19 to 2023/24) and Further Proposed Main Modifications (interim mitigation strategy) are deliverable and will act effectively to mitigate the impacts from residential development over this period.
16. As a result of the issue raised regarding the release of Green Belt through the proposed Main Modifications consultation, Dorset Council is proposing Further Proposed Main Modifications to remove the proposed release of Green Belt for a holiday park from the Local Plan. The council also proposes Further Proposed Main Modifications that are related to these proposed changes.
17. This SA is required to assess potential environmental, social, and economic impacts resulting from the interim measures that are considered suitable and deliverable, and which remove the requirement to release land from the green belt for the holiday park.
Reasonable alternatives
18. The following alternatives were identified with Natural England and landowners where possible. Specifically, alternatives have been considered where:
- they are able to provide mitigation during the interim period, namely, to 2023/24 (there are many other options that could be suitable over the longer term, but it is considered that they will be reviewed during the Dorset Council Local Plan) and
- they are located where they can mitigate the impacts of windfall residential development on the Dorset heaths habitat sites
Morden Park SANG
19. As already proposed through the Purbeck Local Plan 2018-2034, Morden Park could provide 37ha of SANG. The premise of this has already been established and agreed by Natural England.
Strategic Access Management and Monitoring (SAMM)
20. A mitigation measure already in place through the Heathlands Planning Framework SPD. SAMM includes wardening, raising awareness and monitoring the effectiveness of the strategy.
21. Further SAMM projects would help towards partially mitigating the impact of development.
22. If used in isolation, the level of mitigation provided by SAMM projects would need to be able to satisfactorily offset any negative impacts of development until 2023/24.
Heathland Infrastructure Projects (HIPs).
23. HIPs are described in the Dorset Heathlands Planning Framework Supplementary Planning Document (SPD) as ‘physical infrastructure works, such as the provision of Suitable Alternative Natural Greenspace (SANGs) or enhancement of existing greenspaces’, they are designed to ‘increase the attractiveness for visitors that would otherwise visit the Dorset Heathlands’, thereby offsetting impact on the heaths that would occur without them.
24. HIPs, as an already established form of mitigation, could help towards providing an interim mitigation strategy.
25. If used in isolation, the level of mitigation provided by HIPs would need to be able to satisfactorily offset any negative impacts of development until 2023/24.
Increasing the capacity of existing SANGs
26. As an existing form of mitigation, SANGs already in use could have extra capacity, as shown in SD93.
27. Existing SANGs would need to be within the area of search and are therefore restricted to Bog Lane, Wareham and Frenches Farm, Upton. An increase in capacity of any existing SANGs would need to be able to satisfactorily offset any negative impacts of development until 2023/24.
Increasing the capacity of proposed SANGs
28. In addition to SANGs that are already in place, larger developments proposed within the Purbeck Plan will deliver SANG as mitigation.
29. The proposed SANGs would need to be in the area of search and therefore would be appropriate on the Upton and Lytchett Matravers sites. If extra capacity is demonstrated, they could also form part of an interim mitigation strategy.
30. The proposed SANGs would likely need to be delivered in the short term. Planning applications for their delivery are currently being considered.
Restricting development
31. Another option is to restrict development for a short period of time until mitigation measures are in place either through the Dorset Council Local Plan or until there is certainty over the Morden Park SANG.
32. Without mitigation in place, Natural England would likely object to planning applications for new residential uses in the Purbeck area of Dorset Council.
33. There would be negative impacts associated with this and the council’s requirement to deliver housing would need to be considered.
Mitigation strategies and their likely impact on SA objectives
How do the Further Proposed Main Modifications to the plan help in the objective of meeting as much of Purbeck’s housing need as possible?
34. Options that do not provide adequate mitigation cannot be recommended. Without necessary mitigation in place, impacts from windfall development will have a negative impact on Dorset heaths habitat sites. As such it is unlikely that windfall residential development could be granted consent, resulting in a period in which homes built in the area are restricted to the development allocations or development providing its own distinct mitigation.
35. All mitigation strategies that help to achieve the mitigation required in the short term, such as HIPs and SAMMs without restricting growth, will therefore help to deliver homes.
36. Over the short term, increasing the capacity of existing, proposed SANGs or the delivery of Morden Park SANG is likely to also help enable the delivery of homes.
37. The interim strategy provides reasonable assurance of its deliverability and therefore helps to enable the delivery of housing development.
How do the modifications to the plan help in the objective to promote services and facilities where need is identified?
38. Although not directly affected by the interim strategy, services and facilities are often extended or improved due to an increase in population, particularly through an increase in residential development. This type of development therefore provides the driver for improved services and facilities and therefore if residential development doesn’t take place, there is unlikely to be any improvement to existing facilities and services.
39. The interim strategy provides reasonable assurance of its deliverability and will thus help to enable the delivery of housing development and therefore facilities and services.
How do the modifications to the plan assist in the objective of harnessing the economic potential of tourism and widening employment opportunities in Purbeck?
40. Employment opportunities in the tourism sector could be hindered if they have a negative impact on Dorset heaths habitat sites. This could result in restricted employment opportunities. Other employment sectors are however unlikely to be impacted upon.
41. The changes to Policy I5 in the Local Plan will reduce the certainty that a holiday park will be delivered in Morden. Failing to deliver the holiday park will have direct and indirect economic impacts on local tourism in comparison to the impacts the delivery of a holiday park would have. However, there would be no negative impacts on the current state of tourism. Also, there would still be an opportunity for the landowner at Morden Park to make a planning application for the holiday park independently from the Purbeck Local Plan.
42. Balanced against these impacts on the tourism industry, all mitigation strategies that help to achieve the mitigation required in the short term, such as HIPs and SAMMs, without restricting growth will therefore help to support the tourism industry.
43. Over the medium term, increasing the capacity of existing, proposed SANGs or the delivery of Morden Park SANG is likely to also help enable development of the tourism industry.
44. HIPs could have a negative impact on this objective, e.g. the Purbeck Visitor Network Project and the Purbeck Heaths Visitor Management Project. These projects would help mitigate against harm to habitats however they would need to be carefully developed to ensure tourism industry is not negatively impacted.
How do the modifications to the plan assist in the objective to help everyone access basic services, reduce the need to travel by car and encourage cycling, walking, and use of public transport?
45. The options explored are unlikely to have any impact on this objective.
How do the modifications to the plan assist in the objective to reduce vulnerability to flooding and coastal change and adapt to climatic changes?
46. The options explored are unlikely to have any impact on this objective.
How do the modifications to the plan assist in the objective to protect and enhance habitats and species?
47. All mitigation strategies that help to achieve the mitigation required in the short term, such as HIPs and SAMMs, will ensure that residential development does not have an adverse effect upon the integrity of Dorset heaths habitat sites in Purbeck.
48. Over the medium term, delivery of HIP (including SANG), increasing the capacity of existing, proposed SANGs or the delivery of Morden Park SANG will also help protect and enhance habitats and species from the adverse effects of residential development.
49. The interim strategy provides reasonable assurance of its deliverability and therefore will help to enable protect habitats and species.
How do the modifications to the plan assist in the objective to protect and enhance Purbeck’s unique landscape and townscape and cultural and historical assets?
50. The options explored are unlikely to have any impact on this objective.
How do the modifications to the plan assist in the objective to minimise all forms of pollution and consumption of natural resources?
51. Providing a network of mitigation strategies in the area of search could reduce the effects of pollution on the Dorset heaths habitat sites. This would be achieved by providing alternative sites for recreation away from heathland sites, therefore minimising car-based travel to/through the heathland sites.
Snapshot of assessment of reasonable alternatives to mitigation strategies
Snapshot of assessment of reasonable alternatives to further modifications
