Quality information

Prepared by		Checked by			Approved by
Hannah Corrigan Graduate Ecologist		Dr James Riley Technical Director			Dr Max Wade Technical Director

 

 

Revision History

Revision	Revision date	Details	Authorized	Name	Position
01	09/10/2019	Draft	JR	James Riley	Technical Director

 

 

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Prepared for:

   

South Downs National Park Authority

 

Prepared by:

 

 

‌AECOM Infrastructure & Environment UK Limited

Midpoint, Alencon Link

Basingstoke

Hampshire RG21 7PP

United Kingdom

 

T: +44(0)1256 310200

aecom.com

 

 

 

 

© 2019 AECOM Infrastructure & Environment UK Limited. All Rights Reserved. 

This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

 

Table of Contents

1.         Introduction. 6

Scope of Project 6

Legislation. 6

2.         Methodology. 8

Introduction. 8

Likely Significant Effects (LSE) 9

HRA Task 2 – Appropriate Assessment (AA) 9

HRA Task 3 – Avoidance and Mitigation. 10

Confirming Other Plans and Projects that may act ‘In combination’ 10

3.         Internationally Designated Sites. 12

East Hampshire Hangers SAC.. 12

Introduction. 12

Upper Greensand Hangers: Empshott to Hawkley. 12

Upper Greensand Hangers: Wyck to Wheatley. 12

Coombe Wood and The Lythe. 12

Wick Wood and Worldham Hangers. 12

Selborne Common. 12

Noar Hill 12

Wealden Edge Hangers. 12

Reasons for Designation. 13

Historic Trends and Current Pressures. 13

Rook Clift SAC.. 13

Introduction. 13

Reasons for Designation. 13

Historic Trends and Current Pressures. 14

Wealden Heaths Phase 2 SPA.. 14

Introduction. 14

Reasons for Designation. 14

Historic trends and current pressures. 14

4.         Likely Significant Effects. 16

Introduction. 16

Screening Rogate and Rake NP.. 18

5.         Consideration of Effect ‘in combination’ 22

6.         Appropriate Assessment 23

Introduction. 23

Recreational pressure and disturbance. 23

Introduction. 23

Mechanical/Abrasive Damage and Nutrient Enrichment 24

Disturbance. 24

Discussion. 24

Air quality. 25

Discussion. 26

Urbanisation. 26

7.         Conclusion. 28

 

Figures

Figure 1: Four-Stage Approach to Habitats Regulations Assessment (Source: CLG, 2006) 9

Figure 2: Four-Stage Approach to Habitats Regulations Assessment (Source: CLG, 2006) 10

Figure 3. The response of two species, Yorkshire Fog and broad buckler fern to ammonia. 26

 

Tables

Table 1. Other projects and plans that may act 'in-combination' to the development of Rogate and Rake NP. 11

Table 2. Describes how each European Site could be susceptible to the above impact pathways due to increased urbanisation proposed by Rogate and Rake NP and associated development policies. 17

Table 3. Screening outcome of likely significant effects. 18

                                                                                                             

                                                                                                             

1.    Introduction

Scope of Project

1.1       AECOM was appointed by South Downs National Park Authority to assist in undertaking a Habitats Regulations Assessment (HRA) for the Rogate and Rake Neighbourhood Plan (NP) Submitted March 2019. This is for the purpose of informing Rogate and Rake Parish Council and the South Downs National Park Authority of the potential effects on European sites and how they are being addressed in the Submitted Neighbourhood Plan, for that Council to take into account in their formal HRA.

1.2       The South Downs Local Plan 2018 was subject to HRA in July 2018 (post Examination and Local Plan policy modifications). The primary conclusion of the HRA was a need to address air quality, water quality, recreational pressure and urbanisation issues with regards to the South Downs National Park including its constituent parishes. The HRA recommended policy mechanisms for this, which were reflected in the adopted Local Plan.

1.3       At the time of HRA preparation for the South Downs Local Plan; site allocations for residential development within Rogate Parish were not detailed and were therefore not assessed at a Site level. However, the overall scale of growth expected within South Downs National Park, including Neighbourhood Plans, was assessed. The objective of this particular HRA is to identify if any particular site allocations and/or policies that have the potential to cause an adverse effect on the integrity of Natura 2000 or European designated sites (Special Areas of Conservation, SACs, Special Protection Areas, SPAs, and Ramsar sites designated under the Ramsar convention), either in isolation or in combination with other plans and projects, and to determine whether site-specific mitigation measures are required. 

Legislation

1.4       The need for HRA is set out within Article 6 of the EC Habitats Directive 1992 and interpreted into British law by the Conservation of Habitats & Species Regulations 2017 (as amended). The ultimate aim of the Habitats Directive is to “maintain or restore, at favourable conservation status, natural habitats and species of wild fauna and flora of Community interest” (Habitats Directive, Article 2(2)). This aim relates primarily to habitats and species, and designated sites that have a significant role in delivering favourable conservation status. European sites (also called Natura 2000 sites) can be defined as actual or proposed/candidate Special Areas of Conservation (SAC) or Special Protection Areas (SPA). It is also Government policy for sites designated under the Convention on Wetlands of International Importance (Ramsar sites) to be treated as having equivalent status to Natura 2000 sites.

1.5       The Habitats Directive applies the precautionary principle to protected areas. Plans and projects can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question. This is in contrast to the SEA Directive which does not prescribe how plan or programme proponents should respond to the findings of an environmental assessment; merely that the assessment findings (as documented in the ‘environmental report’) should be ‘taken into account’ during preparation of the plan or programme.  In the case of the Habitats Directive, plans and projects may still be permitted if there are no alternatives to them and there are Imperative Reasons of Overriding Public Interest (IROPI) as to why they should go ahead.  In such cases, compensation would be necessary to ensure the overall integrity of the site network.

Box 1: The legislative basis for HRA

1.6       Over the years, ‘Habitats Regulations Assessment’ (HRA) has come into wide currency to describe the overall process set out in the Habitats Regulations, from screening through to identification of IROPI. This has arisen in order to distinguish the overall process from the individual stage of "Appropriate Assessment". Throughout this Report the term HRA is used for the overall process and restricts the use of Appropriate Assessment to the specific stage of that name.

 

 

2.    Methodology

Introduction

2.1       This section sets out the approach and methodology for undertaking the HRA. HRA itself operates independently from the Planning Policy system, being a legal requirement of a discrete Statutory Instrument. Therefore, there is no direct relationship to the ‘Test of Soundness’.

2.2       The HRA is being carried out in the absence of formal Government guidance.  The Department for Communities and Local Government (DCLG, now MHCLG) released a consultation paper on Appropriate Assessment (AA) of Plans in 2006[1]. As yet, no further formal guidance has emerged specifically regarding HRA of plans, although government has released general guidance on HRA[2]. Moreover, Court Judgements can be used to shape the approaches used.

2.3       The draft DCLG guidance[3] makes it clear that when implementing HRA of land-use plans, the AA should be undertaken at a level of detail that is appropriate and proportional to the level of detail provided within the plan itself: “The comprehensiveness of the [Appropriate] assessment work undertaken should be proportionate to the geographical scope of the option and the nature and extent of any effects identified. An AA need not be done in any more detail, or using more resources, than is useful for its purpose. It would be inappropriate and impracticable to assess the effects [of a strategic land use plan] in the degree of detail that would normally be required for the Environmental Impact Assessment (EIA) of a project.” More recently, the Court of Appeal[4] ruled that providing the Council (competent authority) was duly satisfied that proposed mitigation could be ‘achieved in practice’ to avoid an adverse effect, then this would suffice. This ruling has since been applied to a planning permission (rather than a Local Plan)[5]. In this case the High Court ruled that for ‘a multistage process, so long as there is sufficient information at any particular stage to enable the authority to be satisfied that the proposed mitigation can be achieved in practice it is not necessary for all matters concerning mitigation to be fully resolved before a decision maker is able to conclude that a development will satisfy the requirements of reg. 61 of the Habitats Regulations’.

2.4       In other words, there is a tacit acceptance that HRA can be tiered and that all impacts are not necessarily appropriate for consideration to the same degree of detail at all tiers.

2.5       Figure 1 below outlines the stages of HRA according to current draft DCLG guidance.  The stages are essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan until no significant adverse effects remain.

Figure 1: Four-Stage Approach to Habitats Regulations Assessment (Source: CLG, 2006)

Likely Significant Effects (LSE)

2.1       The first stage of any Habitats Regulations Assessment (HRA Task 1) is a Likely Significant Effect (LSE) test - essentially a risk assessment to decide whether the full subsequent stage known as Appropriate Assessment is required. The essential question is:

2.2        “Is the Plan, either alone or in combination with other relevant projects and plans, likely to result in a significant effect upon European sites?”

2.3       The objective is to ‘screen out’ those plans and projects that can, without any detailed appraisal, be said to be unlikely to result in significant adverse effects upon European sites, usually because there is no mechanism for an adverse interaction with European sites. 

HRA Task 2 – Appropriate Assessment (AA)

2.4       Where it is determined that a conclusion of ‘no likely significant effect’ cannot be drawn the analysis has proceeded to the next stage of HRA known as Appropriate Assessment. Case law has clarified that ‘appropriate assessment’ is not a technical term. In other words, there are no particular technical analyses, or level of technical analysis, that are classified by law as belonging to appropriate assessment rather than determination of likely significant effects.

2.5       One of the key considerations during appropriate assessment is whether there is available mitigation that would entirely/ appropriately address the potential effect. This reflects a recent decision by the European Court of Justice[6] that concludes that measures intended to avoid or reduce the harmful effects of a proposed project on a European site cannot be taken into account at the Likely Significant Effects or ‘screening’ stage of HRA. In practice, the appropriate assessment takes any policies or allocations that could not be dismissed following the determination of Likely Significant Effects with a view to concluding whether there would actually be an adverse effect on integrity (in other words, disruption of the coherent structure and function of the European site(s)).

 

HRA Task 3 – Avoidance and Mitigation

2.6       Where necessary, measures are recommended for incorporation into the Plan in order to avoid or mitigate adverse effects on European sites. There is considerable precedent concerning the level of detail that a plan needs to contain regarding mitigation.  The implication of this precedent is that it is not necessary for all measures that will be deployed to be fully developed prior to adoption of the Plan, but the Plan must provide an adequate policy framework within which these measures can be delivered.

2.7       This fits with the advice of Advocate-General Kokott[7] who commented that: ‘It would …hardly be proper to require a greater level of detail in preceding plans [rather than planning applications] or the abolition of multi-stage planning and approval procedures so that the assessment of implications can be concentrated on one point in the procedure. Rather, adverse effects on areas of conservation must be assessed at every relevant stage of the procedure to the extent possible on the basis of the precision of the plan. This assessment is to be updated with increasing specificity in subsequent stages of the procedure’.

2.8       In evaluating significance, AECOM has relied on professional judgement as well as the results of previous stakeholder consultation regarding development impacts on the European sites considered within this assessment.

2.9       When discussing ‘mitigation’ for the proposed development sites, one is concerned primarily with the policy framework to enable the delivery of such mitigation rather than the details of the mitigation measures themselves since the Neighbourhood Plan document is a high-level policy document.

Confirming Other Plans and Projects that may act ‘In combination’

2.10     It is a requirement of the Regulations that the impacts and effects of any plan being assessed are not considered in isolation but in combination with other plans and projects that may also be affecting the European site(s) in question.

Table 1. Other projects and plans that may act 'in-combination' to the development of Rogate and Rake NP.

Plans

South Downs Local Plan (adopted 2019)

Liss Neighbourhood Development Plan 2011-2028, submitted November 2016

Milland Neighbourhood Development Plan 2016-2030, adopted 2016

West Sussex Joint Minerals Local Plan until 2033, adopted 2018

Chichester District Council, Local Plan Key Policies:  2014-2029 (adopted July 2015), and relevant Neighbourhood Plans (e.g. Selsey Neighbourhood Plan)

East Hampshire*, The East Hampshire District Local Plan: Joint Core Strategy (adopted 2014), Local Plan Part 2: Housing and Employment Allocations (adopted April 2017).

Havant Borough Council, 2011. Local Plan (Core Strategy). Adopted March 2011 and Local Plan (Allocations) adopted 2014

Horsham District Local Development Framework (adopted November 2015), the Core Strategy (2007) and replacement Horsham District Planning Framework and associated Neighbourhood Plans.

Mid-Sussex District Council. Mid-Sussex District Plan, 2018.

Winchester* City Council, 2013. Local Plan – Joint Core Strategy. (Adopted) and Local plan Part 2: Development Management & Allocations document.  (adopted April 2017)

Arun Local Plan 2011-2031 Main Modifications (March 2017); now awaiting adoption

Brighton and Hove Submission City Plan Part One. February 2013, Further Proposed Modifications (2015) and associated Neighbourhood Plans.

Eastbourne Borough Council, 2013. Core Strategy Local Plan and Employment Land Local Plan (2014).

Wealden* District Council (Incorporating Part of the South Downs National Park), 2013. Core Strategy Local Plan. New Local Plan shortly to go to consultation

Transport Plans: West Sussex Transport Plan 3 (2011-2026); East Sussex Local Transport Plan 3 (2011-2026); Hampshire Local Transport Plan (2011-2031); and Surrey Local Transport Plan LTP3 (2011-2026); South East River Basin Management Plan 2015 - 2021; Lower Tidal River Arun Strategy Environmental Report (2014).

Minerals and Waste Plans: East Sussex, South Downs and Brighton & Hove Waste and Minerals Plan (adopted 2013); Hampshire Minerals and Waste Plan (adopted 2013); West Sussex Waste Plan (adopted 2014); The East Sussex, South Downs and Brighton & Hove Waste and Minerals Sites Plan (anticipated for adopted early 2018); West Sussex Joint Minerals Plan (at the time of writing (February 2018) modifications to the Proposed Submission version was subject to consultation).

 

 

 

 

3.    Internationally Designated Sites

East Hampshire Hangers SAC

Introduction

3.1       The East Hampshire Hangars describe a series of woodlands (totalling 569.68ha) on the western edge of the Weald. The SAC is made up of a number of SSSIs.

Upper Greensand Hangers: Empshott to Hawkley

3.2       A series of steep, rocky woodlands on calcareous soils. The dominant tree is ash, often with evidence of past coppicing. A variety of herb layer plants occurs, including ancient woodland indicators such as early purple orchid Orchis mascula, herb Paris quadrifolia, butcher’s broom Ruscus aculeatus, sanicle Sanicula europaea, wild daffodil Narcissus pseudonarcissus and sweet woodruff Galium odoratum. The woodland supports the nationally scarce Italian lords-and-ladies Arum italicum sub species neglectum. Bryophyte communities are notable and include nationally scarce species. Molluscs and hoverflies are also represented by nationally scarce species.

Upper Greensand Hangers: Wyck to Wheatley

3.3       The geology and species supported are similar to those found at Empshott to Hawkley.

Coombe Wood and The Lythe

3.4       The hanger woodlands comprise a range of species including ash, oak Quercus robur, beech Fagus sylvatica and hazel Corylus avellana. These woods support a relatively rich calcareous ground flora with substantial populations of green hellebore Helleborus viridis and violet helleborine Epipactis purpurata. The hanger woods also possess a rich bryophyte flora, mostly epiphytic on the older trees.

Wick Wood and Worldham Hangers

3.5       The species rich ancient woodland associated with varied soils is ecologically distinct and contains a number of nationally rare woodland types. On the freely draining upper slopes ash and wych elm Ulmus glabra predominate forming an extremely rare woodland type. Beech, pedunculate oak and whitebeam Sorbus aria also occur on the upper slopes. A few large coppice stools of small leaved lime Tilia cordata occur in Wick Hill Hanger. Fifty-seven species of plant which are indicative of ancient woodlands have been found in the SSSI. Two ponds provide added diversity, which attracts a variety of common and uncommon birds, butterflies, dragonflies and damselflies.

Selborne Common

3.6       This SSSI is beech-dominated woodland on a steep east-facing chalk slope, grading to mixed plateau woodland with relict open acid grassland on clay-with-flints. The ground flora is well-developed, with a number of unusual plant species and rare moss species. On the clay-with-flints plateau, acid grassland adds variety, together with a small water body. A small area of downland turf also exists. Selborne Common is one of the most important mollusc sites in Britain, and a number of notable beetles and butterflies also occur.

Noar Hill

3.7       Noar Hill exhibits a range of chalk vegetation seral stages from open short-sward chalk grassland overlying ancient quarries, through invasive mixed scrub of hawthorn Crataegus monogyna, blackthorn Prunus spinosa, juniper Juniperus communis, and sweetbriar and southern downy roses Rosa micrantha and Rosa tomentosa to mature beech hanger woodland. In addition, hazel coppice is found on the top of the steep scarp slopes. Eleven species of orchid occur, and the site is of national importance for butterflies and grasshoppers.

Wealden Edge Hangers

3.8       The Wealden Edge Hangers comprise the mainly wooded easterly facing escarpment of the Hampshire chalk plateau, at the western extremity of the Weald. It exhibits a wide range of woodland types including mono-specific yew (in some cases developed over former juniper scrub), yew/beech and beech/ash with beech/wych elm /field maple Acer campestre/ash, and oak /hazel, on deeper soils, and moist ash/alder Alnus glutinosa wood by escarpment-foot springs. Ash, beech and elm all occur in coppice forms. A wide range of calcareous shrubs occur. The bryophyte flora is extremely rich, and the lichen flora is the richest for any woodland on chalk in Britain, after Cranborne Chase, with 74 species. The total vascular flora of the area comprises a known 289 species.

Reasons for Designation[8]

3.9       The East Hampshire Hangers qualify as a SAC for both habitats and species.  Firstly, the site contains the Habitats Directive Annex I habitats of:

·         Dry grasslands and scrublands on chalk or limestone, including important orchid sites:  Noar Hill in particular, has an outstanding assemblage of orchids, including one of the largest UK populations of the nationally scarce musk orchid.

·         Beech forests on neutral to rich soils: the site is extremely rich in terms of vascular plants.

·         Tilio-Acerion forests of slopes, screes and ravines. The bryophyte flora is richer than on the chalk examples and includes several species that are rare in the lowlands

·         Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco-Brometalia) (* important orchid sites)

·         Yew woods of the British Isles

3.10     Secondly, the site contains the Habitats Directive Annex II species early gentian.

Historic Trends and Current Pressures[9]

3.11     The habitats of the East Hampshire Hangers SAC are dependent upon maintenance of appropriate species composition and cover. The great majority of the SAC is in favourable condition, and where not, this is due to factors such as non-native species present, inappropriate vegetation structure (e.g. lack of regeneration, or too much scrub), and inadequate grazing regimes.

3.12     The key vulnerabilities to the SAC are:

·         Low nutrient runoff from surrounding land: being steep and narrow, the Hanger woodlands are vulnerable to nutrient run-off leading to eutrophication.

·         Disease outbreaks affecting beech trees.

·         Absence of direct fertilization (agricultural runoff).

·         Appropriate woodland management.

Rook Clift SAC

Introduction

3.13     At 10.82ha, Rook Clift is the largest known remnant stand of Tilio-Acerion forests dominated by large-leaved lime Tilia platyphyllos in the south of England. It lies on the deeper soils towards the base of the slope and valley bottom of a small wooded combe, which gives the site its humid microclimate. The soils are rather deeper and there is less exposed rock at this site because the chalk is more readily weathered than the limestones on which many of the other sites lie. Despite this, the vegetation is otherwise typical of the habitat type, with an abundance of ferns such as hart’s-tongue Phyllitis scolopendrium and shield-fern Polystichum spp. In addition to species more common in the west of Britain, continental species such as Italian lords-and-ladies Arum italicum also occur.

Reasons for Designation[10]

3.14     Rook Clift qualifies as a SAC for its habitats. The site contains the Habitats Directive Annex I habitats of:

·         Tilio-Acerion forests of slopes, screes and ravines for which this is considered to be one of the best areas in the United Kingdom

Historic Trends and Current Pressures[11]

3.15     Rook Clift is a small wooded coombe on the scarp slope of the South Downs. Large-leaved lime dominates the canopy together with ash and some beech. The site is in private ownership and is managed under the Woodland Grant Scheme. As with almost any woodland in southern England, deer could be a problem when plans are instituted for regeneration. Its small size and unusual composition mean that any planting inside the wood would need to be tightly controlled. At present 100% of the site is in favourable condition.

3.16     The key vulnerabilities to the SAC are:

·         Over grazing by deer – deer management

·         Controlled planting of appropriate species of tree

Wealden Heaths Phase 2 SPA

Introduction

3.17     The Wealden Heaths Phase II SPA is situated on an arc of hilly country on the edge of the Weald. The area runs parallel to the South Downs and is located on the borders of Hampshire, Surrey and West Sussex. 

3.18     The underlying geology is composed of Cretaceous sandstones and ironstone, which give rise to predominantly acid soils. These are often sandy and free-draining but clay and silt layers produce poorly-drained areas where streams and wetland habitats can be found. The landscape is largely rural and is characterised by a prominent escarpment with broad, steep-sided valleys and low, rounded hills with a mixture of heaths, oak and birch woodland, mature conifer woodlands, pastures and wetlands. 

3.19     Large parts of the SPA are used for military training, including live-firing, and so public access is restricted. However, there are also areas in the SPA which are very popular destinations for a variety of recreational uses including walking, birdwatching, orienteering and cycling. Some of the land is registered common land but traditional common land management practices, including grazing, have largely died out in the area. Nevertheless, there are strong cultural and historical links to the past reflected in the landscape. 

Reasons for Designation[12]  

3.20     The SPA supports three Annex I species:

·         Dartford warbler Sylvia undata - when classified, the SPA supported 16 pairs (5 year peak mean 1989-1993) which represented 1.7% of the GB population.

·         Nightjar Caprimulgus europaeus - when classified, the SPA supported 43 pairs (5 year peak mean 1989-1993) which represented 1.4% of the GB population.

·         Woodlark Lullula arborea - when classified, the SPA supported 15 pairs (5 year peak mean 1989-1993) which represented 4.3% of the GB population.

Historic trends and current pressures

3.21     The habitats and features that are supported by Wealden Heaths Phase 2 SPA are sensitive to changes in air quality. Exceeding critical values for air pollutants may result in changes to the chemical status of a supporting habitat’s substrate, accelerating or damaging plant growth, altering vegetation structure and composition and thereby affecting the quality and availability of nesting, feeding or roosting habitats. Some of the effects that might be attributable to aerial pollution could include accelerated and more vigorous growth of bramble, birch and coarse grasses and consequent loss of bare ground and/or heather which offer nest sites.  In addition, to air quality pressures the site is also susceptible to disturbance caused by recreational pressure. The nature, scale, timing and duration of some human activities can result in the disturbance of birds at a level that may substantially affect their behaviour, and consequently affect the long-term viability of the population. 

 

4.    Likely Significant Effects

Introduction

4.1       The civil parish of Rogate includes the villages of Rogate and Rake (the majority), and the hamlets of Fyning, Hillbrow (part), Durford Wood, Durleighmarsh, Terwick Common, Tullecombe, Habin, Langley and Nyewood (part). In total, there are 1,556 residents in some 639 households. The parish lies within Chichester district of West Sussex, England.

4.2       Rogate and Rake are located within the South Downs National Park in the centre of the Western Weald.  The parish is approximately 5 miles north to south, 3 miles east to west at its widest, covers approximately 9 square miles or 23 square km, and has a perimeter of about 16 miles. The A272 crosses the parish from east to west, through the centre of Rogate.  Serving the linear settlement of Rake is the B2070 (old A3) that runs northeast and southwest along the western boundary of the parish, which is also the West Sussex County and Chichester District border.

4.3       Based upon previous HRA work undertaken for the South Downs Local Plan, there are several pathways of impact that require analysis regarding increased development within Rogate Parish. These are:

·         Recreational pressure,

·         Air quality, and

·         Urbanization

4.4       Water quality impacts were considered. Internationally designated sites that were assessed for potential likely significant effects resulting from the SDNPA Local Plan were as follows:

·         River Itchen SAC – located over 20km to the west of Rogate and Rake Parish Boundary

·         Arun Valley SAC, SPA and Ramsar site – located over 20km to the east of Rogate and Rake Parish Boundary.

4.5       However, it is considered that due to the considerable distances listed above that River Itchen SAC and Arun Valley SAC, SPA and Ramsar are very unlikely to be impacted by increased development at Rogate and Rake.

4.6       Table 2 identifies the environmental impact pathways to the River Itchen SAC due to increased development within Rogate and Rake NP.

Table 2. How each European Site could be susceptible to the above impact pathways due to increased housing proposed by Rogate and Rake NP and associated development policies.

Impact pathway	Discussion
Air quality	Increased residential development within Rogate and Rake will lead to a greater number of vehicles within the parish. As such, increased air pollution is expected from vehicles emission. Pollutants realised form vehicles may be carried directly by wind currents and deposited to at European Sites or pollutants may become soluble and taken up during evaporation and deposited to European Sites at precipitation.
Recreational pressure	Increased residential development within Rogate and Rake could lead to high numbers of visitors to European Sites. This is highly likely for Wealden Heaths Phase 2 SPA (depending on the location of housing within the parish) as this European Site boarders the Parish boundary. For example, the nature, scale, timing and duration of some human activities can result in the disturbance of birds at a level that may substantially affect their behaviour, and consequently affect the long-term viability of the population.
Urbanisation	Increased urbanisation could lead to likely significant effects to European Sites. In particular, increased residential development within 5km (and particularly 400m) of the Wealden Heaths Phase 2 SPA could increase cat predation to ground nesting birds and chicks reducing breeding success of Annex II species.

4.7       For the Screening assessment (Table 3) green shading in the final column indicates that the proposed development site or policy has been deemed not to lead to a likely significant effect on any European sites due to the absence of any mechanism for an adverse effect. Orange shading indicates that a pathway of impact potentially exists and further discussion is therefore required. For the purposes of this assessment a 5km zone of influence is used around each European Site. A 5km zone is chosen because a) this is the zone within which a series of HRAs have identified that all net new housing will have an adverse effect on the integrity of Wealden Heaths Phase 2 SPA without mitigation and b) the HRA of the SDNP LP records that Natural England recommended during preparation of their HRA that the Council undertake a project-level HRA on all developments located within 5km of Wealden Heaths Phase II SPA.              

Screening Rogate and Rake NP

Table 3. Screening outcome of likely significant effects.

Policy	Designated Site Location	Brief Summary	Screening outcome
Policy NE1: To Conserve, Protect and Enhance the Natural Environment	Within Rogate Parish.	Policy describes that any new development must conserve and, wherever possible, enhance the natural environment and the characterising views identified in this Plan. This broad principle includes geology, geo-diversity, wetlands, water systems, heathland, open spaces, notable trees, landscape setting, overall tranquillity, dark night skies and characterising views of the parish.	No likely significant effects. Screened out.   This is a positive policy that requires new development to conserve and, where possible, enhance the natural environment. The policy also says that development is expected to contribute to and enhance the natural environment by conserving the wider benefits of ecosystem services and minimising any adverse impact on biodiversity. This covers both designated sites and non-designated areas that may have biodiversity value either through the presence of endangered species or the diversity of the plants and species present.
Policy BE1: Locally Distinctive Design within the Parish	Within Rogate Parish.	Policy describes that new development must be of high quality and delivered without permanent detriment to local environment, the setting of the Plan area and the Special Qualities of the South Downs National Park.	No likely significant effects. Screened out.    This policy requires design of development to demonstrate good quality, innovative and sensitive design, and sets out criteria that Design and Access Statements must take into account.
Policy BE2: Conservation Area	Within Rogate Parish.	Policy describes that permission will only be granted for development either within, or within the setting of, Rogate’s Conservation Area, if it can be demonstrated that it will conserve or enhance the character of the designation.	No likely significant effects. Screened out.   This policy sets out the circumstances under which development proposals in or contiguous with Rogate’s Conservation Area, which is within the settlement boundary, may be permitted and sets out a series of requirements that proposals must address.The policy does not in and of itself provide for development and therefore not expected to effect European Sites.
Policy H1: Settlement Boundary	·          Wealden Heaths Phase II SPA: 5.5km north ·          East Hampshire Hangers SAC: 6.4km north-west ·          Rook Clift SAC: 5.3km south	Policy describes the development boundary within Rogate’s settlement area.	Likely significant effects. Screened in.   The policy provides for development in principle within the defined Rogate settlement boundary.    The potential impact pathways are: - Air quality (in combination)
Policy H2: Residential Development in the Open Countryside	·          Wealden Heaths Phase II SPA: directly adjacent, north of the Parish boundary ·          East Hampshire Hangers SAC: 3.9km west ·          Rook Clift SAC: 3.8km south	This policy describes that residential development outside of the settlement boundary will be limited to replacement dwellings and extensions, except when one or more of the policy requirements are achieved.	Likely significant effects. Screened in.   This policy facilities development outside of Rogate’s settlement boundary. At the time of writing, there is no spatial detail outlined within this policy and therefore development could occur within the wider extent of the Parish boundary. Impacts to European Sites are expected via the following pathways:    - Recreational pressure of East Hampshire Hangers SAC, Wealden Heaths Phase II SPA - Urbanisation of Wealden Heath Phase II SPA - Air quality (in combination)
Policy H3: Conversion of Existing Residential Properties	·          Wealden Heaths Phase II SPA: directly adjacent, north of the Parish boundary ·          East Hampshire Hangers SAC: 3.9km west Rook Clift SAC: 3.8km south	This policy describes requirements for the conversion of current residential plots into several self-contained smaller plots for residential inhabitation.	Likely significant effects. Screened in.   This policy facilities concentrated development within existing residential plots. However, at the time of writing there is no spatial detail outlined within this policy and therefore development could occur within the wider extent of the Parish boundary. Impacts to European Sites are expected, as above, via the following pathways:    - Recreational pressure of East Hampshire Hangers SAC, Wealden Heaths Phase II SPA - Urbanisation of Wealden Heath Phase II SPA - Air quality (in combination)
Policy H4: Replacement Dwellings, Extensions and Annexes	·          Wealden Heaths Phase II SPA: directly adjacent, north of the Parish boundary ·          East Hampshire Hangers SAC: 3.9km west ·          Rook Clift SAC: 3.8km south	This policy sets out criteria for replacement dwellings, extensions and annexes.	Likely significant effects. Screened in.   Again, this policy does not provide spatial detail with regards to development placement therefore development could occur within the wider extent of the Parish boundary. Impacts to European Sites are expected, as above, via the following pathways:    - Recreational pressure of East Hampshire Hangers SAC, Wealden Heaths Phase II SPA - Urbanisation of Wealden Heath Phase II SPA - Air quality (in combination)
Policy H5: Local Housing Needs	N/A	This policy describes the requirement of affordable housing and mix of homes on allocated sites in Policy H6	No likely significant effects. Screened out.   This policy sets out the requirements for housing mix and does not allocated sites for development. As such, this policy is not expected to impact European Sites.
Policy H6: Renault Garage and Bungalow South of A272, Rogate	·          Wealden Heaths Phase II SPA: 5.7km north ·          East Hampshire Hangers SAC: 6.7km north-west ·          Rook Clift SAC: 5.4km south	This policy allocates 9 residential dwellings and either 2 flats or 2 workshops.	Likely significant effects. Screened in.   The policy allocates 9 residential dwellings and either 2 flats or 2 workshops that are located within the settlement boundary towards the north east of Rogate. Current site use is a car garage and bungalow.   The potential impact pathways are: - Recreational pressure to Wealden heaths Phase II SPA - Air quality (in combination)
Policy H6: Land on North side of B2070 London Road West of Flying Bull PH, Rake	·          Wealden Heaths Phase II SPA: 1.7km, north ·          East Hampshire Hangers SAC: 5.3km west ·          Rook Clift SAC: 9.6km south	This policy allocates 4 residential dwellings.	Likely significant effects. Screened in.   The policy allocates 4 residential dwellings towards the centre of Rake Village. Current site use is a pub garden with associated scrub and trees.    The potential impact pathways are: - Recreational pressure to Wealden heaths Phase II SPA - Air quality (in combination)
Policy EW1: Supporting the Rural Economy	Within parish boundary.	This policy facilitates development in the open countryside provided it is restricted to proposals that demonstrate positive and demonstrable benefits to sustaining to the rural economy.	Likely significant effects. Screened in.   This policy does not provide specifically for development but does provide criteria and circumstances for potentially suitable rural business development. This could increase the number of people commuting into the Rogate Parish.   The potential impact pathways are: - Air quality (in combination)
Policy T1: Encouraging Sustainable Travel	Within parish boundary.	Policy encourages residential and commercial development to incorporate attractive links to the nearest point on the public right-of-way network and local footway networks.	Likely significant effects. Screened in.   This policy relates to encouraging sustainable travel options. This policy requires that, where practical, new development to connect to the nearest point of the public right of way network and that opportunities to enhance existing links should be taken wherever possible.    The potential impact pathways are: - Recreational disturbance of East Hampshire Hangers SAC, and Wealden Heath Phase II SPA
Policy T2: Safety	N/A	Policy describes that proposal should not have a detrimental impact on the safety of road users including cyclists, pedestrians and horse riders.	No impact pathways. Screened out.   The policy relates to road safety and is not expected to have likely significant effects to European Sites.
Policy T3: Parking	Within parish boundary.	Policy describes development that will generate additional trips by private car should provide sufficient off-street parking.	Likely significant effects. Screened in.   This policy does not provide specifically for development but does provide criteria and circumstances for increasing car parking facilities with increased development, specifically with regards to schools, the village hall and recreational grounds. This could increase the number of people using cars within the parish and/or commuting into the Rogate Parish.   The potential impact pathways are: - Air quality (in combination)
Policy E1: Renewable Energy	N/A	Policy describes the councils desires to support the use of renewable energy projects.	No impact pathways. Screened out.   This policy sets out criteria in which small scale renewable energy projects may be supported. In particular, support will be given where they can be delivered without permanent detriment to the local environment and are commensurate with the special qualities of the National Park (which includes its biodiversity).
Policy CH1: Community Facilities	N/A	Policy describes the continuing use of current community facilities.	No impact pathways. Screened out.   This policy does not allocate new sites for community development and is therefore not expected to impact European Sites.
Policy CH2: Development of community Facilities	N/A	Policy set out strict requirements for the redevelopment of community facilities.	No impact pathways. Screened out.   Again, this policy does not allocate new sites for community development rather the policy aims are to restrict change of use and redevelopment of current community facilities. Therefore, no likely significant effects are expected to European Sites.
Policy CH2: Development of Community Facilities	N/A	Policy describes affords protection from development to public open spaces.	No impact pathways. Screened out.    This a positive policy that safeguards specific public open spaces and Local Green Spaces in the parish.

5.    Consideration of Effect ‘in combination’

5.1       The SDNP LP was subject to HRA in 2017 and updated in 2018. That HRA included a strategic assessment of air quality, hydrology, recreational pressure and urbanisation ‘in combination’ with growth in other authority areas (including Rogate and Rake Parish) over the same time period. The ‘in combination’ assessment is discussed further in the appropriate assessment section of this report.

 

 

5.2        

6.    Appropriate Assessment

Introduction

6.1       The law does not prescribe how an appropriate assessment should be undertaken or presented but the appropriate assessment must consider all impact pathways that have been screened in, whether they are due to policies alone or to impact pathways that arise in combination with other projects and plans. That analysis is the purpose of this section. The law does not require the ‘alone’ and ‘in combination’ effects to be examined separately provided all effects are discussed. The impact pathways of concern to this HRA (water quality, water resources and recreational pressure) are inherently ‘in combination’ since the amount of new development in the Rogate Neighbourhood Plan is too small to result in an adverse effect alone but only ‘in combination’ with other plans and projects.

6.2       The HRA screening exercise undertaken in Chapter 4, Table 3 indicated a total of 9 policies that were expected to have likely significant effects to the European Sites due to air quality, recreational pressures and urbanisation issues. At the screening stage the following policies were screened in, requiring further assessment:

·         Policy H1: Settlement Boundary;

·         Policy H2: Residential Development in the Open Countryside;

·         Policy H3: Conversion of Existing Residential Properties;

·         Policy H4: Replacement Dwellings, Extensions and Annexes;

·         Policy H6: Renault Garage and Bungalow South of A272, Rogate;

·         Policy H6: Land on North side of B2070 London Road West of Flying Bull PH, Rake;

·         Policy EW1: Supporting the Rural Economy;

·         Policy T1: Encouraging Sustainable Travel; and

·         Policy T3: Parking.

Recreational pressure and disturbance

Introduction

6.3       Recreational use of a European site has the potential to:

·         Prevent appropriate management or exacerbate existing management difficulties[13];

·         Cause damage through erosion and fragmentation;

·         Trampling of vegetation[14];

·         Cause eutrophication as a result of dog fouling; and

·         Cause disturbance to sensitive species, particularly ground-nesting birds[15].

6.4       Different types of European sites are subject to different types of recreational pressures and have different vulnerabilities. Studies across a range of species have shown that the effects from recreation can be complex. It should be emphasised that recreational use is not inevitably a problem. Many European sites also contain nature reserves managed for conservation and public appreciation of nature. For example, Parts of the Wealden Heaths Phase II SPA are managed by the National Trust where access is encouraged and where resources are available to ensure that recreational use is managed appropriately.

Mechanical/Abrasive Damage and Nutrient Enrichment

6.5       Most types of terrestrial European site can be affected by soil compaction and erosion, which can arise as a result of visits by walkers, cyclists, horse-riders and users of off-road vehicles. Dog walkers adversely impact sites through nutrient enrichment via dog fouling and also have potential to cause greater disturbance to fauna as dogs are less likely to keep to marked footpaths and move more erratically. Motorcycle scrambling and off-road vehicle use can cause serious erosion, as well as disturbance to sensitive species.

6.6       The Wealden Heaths Phase II SPA is an internationally designated sites for species that could be adversely affected by the impacts of excessive trampling and erosion to their supporting habitats. Direct mechanical trampling and nutrient enrichment are both more subtle and reversible effects than disturbance of nesting bird populations.

Disturbance

6.7       Concern regarding the effects of disturbance on birds stems from the fact that they are expending energy unnecessarily and the time they spend responding to disturbance is time that is not spent feeding. Disturbance therefore risks increasing energetic output while reducing energetic input, which can adversely affect the ‘condition’ and ultimately survival of the birds. In addition, displacement of birds from one feeding site to others can increase the pressure on the resources available within the remaining sites, as they must sustain a greater number of birds.

6.8       Human activity can affect birds either directly (e.g. through causing them to flee) or indirectly (e.g. through damaging their habitat). The most obvious direct effect is that of immediate mortality such as death by shooting, but human activity can also lead to behavioural changes (e.g. alterations in feeding behaviour, nest abandonment, avoidance of certain areas etc.) and physiological changes (e.g. an increase in heart rate) that, although less noticeable, may ultimately result in major population-level effects by altering the balance between immigration/birth and emigration/death.

6.9       The factors that influence a species response to a disturbance are numerous, but the three key factors are species sensitivity, proximity of disturbance sources and timing/duration of the potentially disturbing activity.

Discussion

6.10     The impact pathways assessed at the screening stage regarding increased residential development and by default more visitors to European Sites is considered in combination with development elsewhere in the National Park. This is an issue that is most appropriate to tackle at a Local Plan level and it was discussed extensively in the HRA of the adopted SDNP Local Plan. Within that HRA a total of 11 net new residential dwellings were assumed at Rogate village in combination with other residential allocations elsewhere within and beyond the SDNP. It was concluded that the growth in the Local Plan would not result in adverse effects on the integrity of any European sites. Since the Local Plan HRA was completed, the Rogate and Rake NP has allocated a total of 4 residential dwellings at Rake village (Policy H6: Land on North side of B2070 London Road West of Flying Bull PH, Rake). The location of this allocated is 1.7km to the south of the Wealden Heaths Phase II SPA. The extent to which these further four dwellings might change the conclusion of the Local Plan HRA must therefore be considered.

6.11     The adverse effects of recreational pressure on the Wealden Heaths Phase II SPA and East Hampshire Hangers SAC were investigated and discussed in detail at the time the East Hampshire/South Downs National Park Local Plan Joint Core Strategy was prepared and is documented in its various iterations of HRA and the HRA of the adopted Waverley Local Plan Part 1; the analysis was then updated for the adopted South Downs Local Plan, with which Natural England concurred. It is therefore not repeated in this document. The various Core Strategy and Local Plan HRAs concluded that, based on the levels of development expected within 5km of the SPA over the Strategy period (including that expected within Waverley district), no strategic mitigation solution was required provided that Whitehill-Bordon (responsible for the vast majority of new development within the 5km zone) mitigated for its own impacts at the project level. South Downs Local Plan policy (developed in agreement with Natural England and considered sound by the planning inspector at Examination) treats other new housing developments within 5km on a case-by-case basis in determining whether mitigation is required, with the decision as to the need for mitigation being based upon consideration of the scale of development and its proximity to the SPA.

6.12     Since the issue was already analysed and discussed in detail as part of the Joint Local Plan Examination, the same conclusions of no adverse effect on integrity can apply to Rogate and Rake NP provided the housing identified in the Local Plan does not materially alter the quanta on which the South Downs Local Plan HRA is based. Since four dwellings at Rake will not materially alter the housing numbers assessed in the adopted Local Plan, it is considered that the conclusion remains valid[16]. In addition, the mitigating Policy NE1 mirrors the relevant policy of the adopted South Downs Local Plan and requires that ‘new development must conserve and, wherever possible, enhance the natural environment… In the north of the parish, development proposals resulting in a net increase in residential units within 5km of any boundary of the Wealden Heath Phase II SPA will require a project-specific Habitats Regulations Assessment screening to determine whether a likely significant effect on the integrity of the site will result and any requirements for mitigation are identified’.

6.13     Rook Clift SAC is a rural site isolated from any large settlements. The SDNP HRA identified two settlements within 5km of the SAC. At that time there was expected to be small amounts of new housing at South Harting (13 dwellings) and Rogate (11 dwellings), amounting to a total of 24 new houses[17]. It was concluded that such a small number of dwellings would not result in a material change in recreational activity at the site. In addition, the Natural England Site Improvement Plan for Rook Clift SAC does not identify recreational pressure as a site vulnerability. As such, no adverse effects would result from increased recreational pressure as a result of the Rake and Rogate NP. While an additional four dwellings are being delivered in this Neighbourhood Plan (at Rake) that does not materially change the Local Plan analysis.

6.14     It is therefore reasonable to conclude that the appropriate policy measures are in place to ensure there are no impacts to European Site integrity due to increased residential development within Rogate and Rake.

Air quality

6.15     Increased residential development within Rogate Parish could decrease air quality through increased emissions from vehicle exhausts. There are two measures of relevance regarding air quality impacts from vehicle exhausts. The first is the concentration of oxides of nitrogen (known as NOx) in the atmosphere. In extreme cases NOx can be directly toxic to vegetation but its main importance is as a source of nitrogen, which is then deposited on adjacent habitats. The guideline atmospheric concentration advocated by Government for the protection of vegetation is 30 micrograms per cubic metre (µgm^-3), known as the Critical Level, as this concentration relates to the growth effects of nitrogen derived from NOx on vegetation.

6.16     The second important metric is a measure of the rate of the resulting nitrogen deposition. The addition of nitrogen is a form of fertilization, which can have a negative effect on woodlands and other habitats over time by encouraging more competitive plant species that can force out the less competitive species that are more characteristic. Unlike NOx in atmosphere, the nitrogen deposition rate below which we are confident effects would not arise is different for each habitat. The rate (known as the Critical Load) is provided on the UK Air Pollution Information System (APIS) website (www.apis.ac.uk) and is expressed as a quantity (kilograms) of nitrogen over a given area (hectare) per year (kgNha^-1yr^-1).

6.17     Emissions of NOx and resulting deposition can have community level impacts to habitats and European Sites. Habitats that are particularly sensitive to elevated nitrogen levels include woodlands such as those at East Hampshire Hangers SAC and Rook Clift SAC. Elevated nitrogen deposition in general has driven strong biogeochemical responses in woodlands with many authors documenting reductions in soil carbon-nitrogen ratio, acidification and increased nitrate leaching[18] and understory plants can be negatively affected by nitrogen inputs.

6.18     However, it is important to note that the impact of nitrogen deposition on vegetation composition of woodlands is poorly understood partly due to the strong confounding influence that tree canopy structure places on ground flora species richness, cover and other parameters that might illustrate the influence of nitrogen deposition. The canopy does this through interception of light, rainfall and pollution and the effect of woodland management upon this structure also has a big influence on groundflora.

6.19     Other protected habitats and species that are supported at East Hampshire Hangers SAC, but not the primary reason for site selection, includes semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia), (note that this includes the priority feature "important orchid rich sites"). These grasslands are found on thin, well-drained, lime-rich soils associated with chalk and limestone. A large number of rare plants are associated with this habitat, including the Annex II species Early gentian Gentianella anglica that is also supported by the SAC. By definition this habitat type is unfertilised and is therefore susceptible to nitrogen deposition. The rare plant species that are supported by this habitat are therefore adapted to nutrient poor-conditions and impacts such as nitrogen deposition from increased vehicle emission could have likely significant effects to species richness and composition.

6.20     A second habitat that is also highly impacted by increased soil fertility from nitrates is heathland. The routes that nitrogen deposition impacts habitats and vegetation described above are through toxicity and the movement of nitrogen through varying trophic levels. Another route of affect is through nitrogen acidification. A study undertaken by Maskell et al (2010)[19] observed that with increasing acid deposition from NOx there was a decrease in species richness within heathland. Acid deposition can have serious impacts to the health of soil structure and the microbial communities found here. These species carryout a natural decaying process known as nitrification (converting ammonium to nitrate) that generates acidity. However, when in combination with acid deposition from NOx pollution the soil pH may become too acidic for specialised plant communities to survive and therefore result in a net decrease in biodiversity[20]. Acidification tends to be more of an issue for acid substrates (which have poor buffering capacity (i.e. heathland)) than neutral or calcareous substrates.

Discussion

6.21     Again, due to the small scale of development within the Rogate and Rake NP increased residential development and associated air quality impacts to European Sites are assessed in combination. As describes in Table 2, increased residential development (Policies H1, H2, H3, H4 and H6) and associated car parking facilities (Policy T3) could increase atmospheric pollutants through the release of chemicals from vehicle emissions. The issue of air quality is extensively addressed in the SDNP HRA where the nature of the transport within the South Downs is inherently ‘in combination’ with growth of the surrounding authorities, including 11 dwellings at Rogate. That HRA concluded that:

·         At its closest Kingley Vale SAC is 125m from the B2141. Given the distance from the road and its minor nature, NOx concentrations within the SAC are currently well below the critical level and are forecast to reduce further up to 2033.

·         For Wealden Heaths Phase 2 SPA, an increase in nitrogen deposition equivalent to 0.1% of the critical load is a sufficiently small amount (equivalent to 1 milligram deposited per square metre, spread over a year[21]) that it is ecologically insignificant, and no retardation of improvement would occur.

·         Only minor roads such as the B3006 lie within 200m of the East Hampshire Hangers SAC, nitrogen deposition rates and NOx concentrations have fallen fairly consistently since 2005 and are expected to continue falling to 2033.

6.22     While an additional four dwellings are being delivered in this Neighbourhood Plan (at Rake) that does not materially change the Local Plan analysis. As such, it can be concluded that no adverse effect upon the SPA would result from increased development provided by the NP ‘in combination’ with growth from other sources. In addition, Policy NE1 prevents ‘any new development from contributing to, or increasing the risk of, soil, air, water, light or noise pollution or land instability’.

6.23     In addition, Rook Clift SAC is a remote site that does not lie within 200m of any roads that would constitute journey to work routes for residents of the National Park. The SAC is therefore not expected to be impacted by direct air quality issues due to increase residential development within Rogate and Rake Parish.

Urbanisation

6.24     Urbanisation impacts result from increased populations within close proximity to sensitive European sites. The detail of the impacts is distinct from the trampling, disturbance and dog-fouling that results specifically from recreational activity (considered in the subsequent section relating to Recreational Pressure and Disturbance). The list of urbanisation impacts can be extensive, but core impacts can be singled out:

·         Increased fly-tipping,

·         Cat predation, and

·         Uncontrolled fires.

6.25     Concerning aspects of urbanisation (particularly predation of the chicks of ground-nesting birds by domestic cats); the South Down’s HRA analysis for housing delivery allowed for a total of 287 dwellings to be delivered in the National Park within 5km of the Wealden Heaths Phase 2 SPA. This assessment did not include the housing allocations at Rake now outlined by the Rogate and Rake NP. However, none of the proposed dwellings are within 400m of the SPA.

 

 

7.    Conclusion

7.1       It is concluded that the appropriate safeguarding policies already exist within the Local Plan and Neighbourhood Plan. Therefore, no adverse effect would occur on the integrity of European Sites.

 

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