New Tools for Impact Risk Zone (IRZ) Assessments
Written by John M Patmore
Natural England has produced a way to identify the possible damage to natural features caused by building developments, termed an ‘Impact Risk Zone (IRZ) Assessment’. This uses a GIS layer to define the potentially damaging developments and activities, to help provide an important first line of defence for conserving natural features. This tool helps in providing a ‘checklist’ to ensure the most immediate questions are asked. Intelligent assessment can then be used to answer these immediate questions.
Although the IRZ Assessment tool currently provides a layer in relation to SSSIs, for southern England this layer is quite generic and covers most of the land. Large numbers of properties and a large number of small SSSIs are intermingled at the District level. Whilst the impact upon grassland has been included based on calcareous habitats within the SSSI network, from an ecological perspective the proposed development is likely to have a similar impact upon all grassland with wildlife value. An ecologically diverse grassland site, rich in structure and biodiversity may have been overlooked when the SSSI boundaries were chosen. Initially SSSIs were surveyed and notified in the 1980s, often at speed. I determined part of a grassland site boundary which was under a 10cm snow blanket, which was confirmed as SSSI later in the year (in the autumn).
In terms of promoting biodiversity, a key point is that the grasshoppers leaping around do not know whether they are inside the SSSI boundary line or in the adjacent field on the grassland sites. However the release of pollutants, or road building, will have the same impact on biodiversity features.
Selecting Wildlife Sites
At a strategic level SSSIs were selected on the basis of representing the habitats, species and earth science features within a region. They were only a selection, not all the examples of that habitat type (JNCC, 1989). They were selected by the UK Government’s Statutory Advisers on Nature Conservation between the 1970s and today, based on a long and distinguished history of nature conservation in Great Britain.
Whilst the SSSI series provided a representative sample of habitats there were many other sites not formally notified as SSSIs. These are often called ‘Non Statutory’ sites and include local authority designated SNCI/SINCs and Local Geological Sites. Local Authorities also declare LNRs in consultation with the local Wildlife Trust and Natural England. Other high quality habitats which support recognised biodiversity features include Ancient Woodland and species rich grassland. Within suburban areas there is a mosaic of habitats; including parklands, grasslands with some shrubs, denser shrub, linear habitats such as hedges, roadside verges, central reservations, adjacent gardens, ponds and ‘open habitats’ (NVC: OV1-42, OV42 is characterised by ivy-leaved toadflax often growing on walls or path edges).
Designated Nature Reserves aside, much of the wider countryside has lost its highest value biodiversity. Perhaps the margin between urban areas and wider countryside now supports the remnants of British biodiversity. Could the suburbs represent an important meta-habitat with a diverse mosaic of interconnected low-intensity micro-habitats? Could the suburbs provide both an important area for conserving British Biodiversity, and also for reconnecting people with the remnants of Britain’s semi-natural wild heritage?
Brighton and Hove City Council: Case Study
Brighton and Hove became a ‘Unitary Authority’ in 1997 with its own planning and development control duties. Physically lying between the South Downs chalk ridge and the coastal strip, restricts the area of land available for new house building. Consequently greatest pressure is now placed on any land south of the National Park boundary for housing. One such area is ‘Meadow View’. This supports a mosaic of habitats which includes grassland, scrub and hedgerow edges. There are a range of native plants and animals, including some scarce and Local BAP species.
As the City Council has no ‘in-house’ ecologist they place relatively little importance on their Biodiversity Duty and planning decisions reflect other sector interests. This has resulted in a gap: Guidelines and advice on promoting biodiversity versus making planning decisions within restricted timescales which meets local development plan needs. In practice this has resulted in a local backlash. Now local groups are struggling to protect their local sites, usually with only a restricted access to high quality ecological guidance.
In the ‘Meadow View’ case the developer’s ecological consultants have not even undertaken an invertebrate survey. But in the absence of high quality ecological advice within the local planning authority this gap in the ecological impact baseline data has been overlooked. The local conservation group (‘Save Our Deans’) have used the features highlighted in the IRZ Assessment tool to bring the key impact assessment features to the planning authorities attention. Although there are two SSSIs which may potentially be impacted by the proposed development it is reasonable to consider the ecological impacts may also affect other habitats and species. The reptiles and grasshoppers really do not know where the official wildlife site boundary falls!
The IRZ Assessment tool can be considered to have five functions:
• Provide a source of competent knowledge on potential impact criteria
• Alert the planning officers (in the ‘Competent Authority’) to these criteria
• Raise the standard of EIA scoping, survey and reporting to inform planning officers
• Ensure the impact upon SSSIs and local sites of high biodiversity value is adequately assessed
• Encourage transparency and engagement by local groups and people with the ‘Planning Process’ to ensure environmental impacts are adequately considered by the competent authority
Ultimately it will be for the planning authority to ensure that biodiversity features and impacts are fully considered. The IRZ Assessment tool can certainly help them in this function. For ‘Meadow View’ the section relating to biodiversity features from the Local Group’s representation stated:
“1.1 Natural England
Local Planning Authorities (LPAs) have a duty to consult Natural England before granting planning permission on any development that is in or likely to affect a SSSI. The following assessment has been omitted from the Environmental Impact Assessment process.
1.1.1 Impact Risk Zone (IRZ) Assessments
Natural England has produced a tool for the assessment of risk to Sites of Special Scientific Interest (SSSIs) from proposed developments. Lightwood has not used this tool in its assessment, and as a consequence there is no information available on how the development could impact SSSIs in the vicinity.
1.1.2 Cumulative Impact
There is a cumulative effect from this and other proposed developments on the waste streams from Brighton & Hove. Waste streams that have the potential for producing harmful effects include inert landfill, non-hazardous landfill and hazardous landfill.
The IRZs tool described above will help developers inform planners whether a proposed development is likely to affect a SSSI and determine whether they will need to consult Natural England to seek advice on the nature of any potential SSSI impacts and how they might be avoided or mitigated.
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Land near Meadow Vale: SSSI_IRZs_Aug2014_Summary
feature id: 32506
OS Ref: TQ362042
AirPollution: Pig & Poultry Units. Any other development/ industrial or commercial process that could cause AIR POLLUTION.
Airport: Airports, helipads and other aviation proposals, including new roads etc.
AllConsult: 0
Combustion: General combustion processes >20MW energy input. Incl: energy from waste incineration, other incineration, landfill gas generation plant, pyrolysis/gasification, anaerobic digestion, sewage treatment works, other incineration/ combustion.
Compost: Any composting proposal with more than 75000 tonnes maximum annual operational throughput. Incl: open windrow composting, in-vessel composting, anaerobic digestion, other waste management.
Discharge: Any discharge of water or liquid waste that is more than 20m /day. The water needs to either be discharged to ground (ie to seep away) or to surface water, such as a beck or stream. Discharges to mains sewer are excluded.
Infrastruc: 0
NonResiden: 0
Quarry: 0
Residentia: 0
RuralResid: 0
Waste: Landfill. Incl: inert landfill, non-hazardous landfill, hazardous landfill.
WindSolar: 0
Local Planning Authorities are assisted by Natural England’s IRZ Assessment GIS layer, in helping to ensure professional ecological consultants working on behalf of developers, address the correct environmental features. Whether they meet the LPA’s requirements in its Duty to Promote Biodiversity will depend upon the professionalism of the Consultants. This tool provides an important foundation towards meeting the Formal Biodiversity Duty.
The author is an independent naturalist providing biodiversity advice in Sussex (Eco21st.com). He is vice chair of Brighton and Hove’s Wildlife Forum, but these are his own views in this article and they have not been checked with any planning advisers.
Reference:
JNCC, 1989, ‘Guidelines for selection of biological SSSIs.’ Joint Nature Conservation Committee, Peterborough.