BASE HEADER

The Evidence Base.
Page 20 of PPS12 states that the Core Strategy must be justified and goes on to say that the document must be founded on a 'robust and credible evidence base'. To be robust and credible, the information must be up-to-date and this may be tested when the Core Strategy comes to the examination in public stage.
A detailed appraisal of all options in respect of the natural and historic environment needs to be undertaken in order to provide a robust evidence base for decision-making.
Natural England welcomed the Warwick District Habitat Assessment carried out by the HBA project as part of the evidence base for the initial tranche of sites in the core strategy preferred options consultation. However, the same level of detail has not been available in full for the alternative sites proposed for the current consultation in order to enable a full appraisal of each option. We recommend that the HBA habitat assessment is extended to include all the proposed alternative sites. In addition to this we recommend that species, geological and landscape data should be screened from existing Warwickshire Local Record Centre data to complement the habitat data and the additional survey work that has been recommended within the Warwick District Habitat Assessment, such as potential Local Wildlife/Geological Site criteria assessments are undertaken prior to site selection.
Notwithstanding the points above, in terms of proximity to statutorily protected sites our initial comments are to note that Loes Farm, Guy's Cliffe is within 1km of Guy's Cliffe geological SSSI and Land at Baginton is about 2Km from Ryton and Brandon Gravel pits SSSI. Any possible indirect impacts should be evaluated.

Habitat Regulations Assessment (HRA)
As stated in our response to the core strategy preferred options consultation on the 24th September 2009, it is strongly recommended that Warwick District Council produce a screening report as soon as feasible regarding the possible requirement undertake a Habitats Regulations Assessment (HRA) of the draft core strategy. This is a requirement of regulation 85 of the Conservation (Natural Habitats &c.) (Amendment) Regulations (2007) which applies to the preparation of land use plans. The purpose of the assessment is to consider if the Core Strategy is likely to cause any significant adverse effects on the nature conservation interests of statutorily designated European protected sites in the vicinity of the District, alone and/or in-combination. Natural England will be happy to advise on how this screening should be undertaken. We attach a report detailing possible threats to the conservation objectives of SAC/SPAs in the West Midlands that may be of assistance.