HMWP updated Habitats Regulations Assessment May 2026

Contents

• Non-technical Summary........................................................................................................ 3
• 1. Introduction.................................................................................................................... 4
• Purpose ............................................................................................................................ 4
• The updated Hampshire Minerals and Waste Plan............................................................ 4
• 2. Habitats Regulations Assessment Process .................................................................... 6
• Requirement for HRA ........................................................................................................ 6
• HRA Methodology and Baseline ..................................................................................... 7
• HRA Screening................................................................................................................ 13
• HRA Appropriate Assessment ......................................................................................... 15
• HRA Air Quality Addendum ............................................................................................. 17
• Additional Hydrological Information – Purple Haze .......................................................... 18
• Main Modifications........................................................................................................... 19
• 3. Conclusion................................................................................................................... 22
• Acronyms / initialisations..................................................................................................... 23
• Glossary.............................................................................................................................. 24
• Appendix 1: Natural England Response to Baseline and Methodology Report Consultation28
• Appendix 2: Natural England Response to Regulation 18 Consultation .............................. 30
• Appendix 3: Natural England Response to Regulation 19 Proposed Submission Plan Consultation........................................................................................................................ 47
• Appendix 4: Updated Appropriate Assessment of screened-in sites and policies ................ 61
• Table A4.1: Purple Haze (NFD03) ................................................................................ 62
• Table A4.2: Midgham Farm (NFD04)............................................................................ 97
• Table A4.3: Hamble Airfield (EAL02) .......................................................................... 119
• Table A4.4: Ashley Manor Farm (NFD01) .................................................................. 143
• Appendix 5: Natural England Response to Main Modifications Consultation ..................... 150

Non-technical Summary

1. Hampshire County Council, New Forest National Park Authority, Portsmouth City Council, South Downs National Park Authority and Southampton City Council (collectively referred to as the ‘Hampshire Authorities’) have worked in partnership to undertake an update of the Hampshire Minerals and Waste Plan (HMWP), which will guide minerals and waste decision-making in the Plan area.

2. This report summarises the Habitats Regulations Assessment (HRA) of the HMWP update to support its adoption by the Hampshire Authorities. HRA is a statutory requirement for the Hampshire Authorities to undertake in relation to the update of the HMWP.

3. The current HMWP was adopted in October 2013. The National Planning Policy Framework (NPPF) requires that Local Plans should be reviewed to assess whether they require updating at least once every five years¹.

4. A second review of the 2013 HMWP in 2020 recommended updating the HMWP to reflect national policy changes, the Hampshire 2050 Vision for the Future, and to ensure that the Plan is delivering a steady and adequate supply of minerals and enabling sustainable waste management provision. It was subsequently decided by all partners that the HMWP would be subject to partial update. This is important as out of date plans limit the ability for planning authorities to enable the right development, in the right location, at the right time, and may lead to a greater number of planning applications determined at appeal.

5. During preparation it became apparent that the process had become a full update of the 2013 Plan. The updated HMWP will cover the period up to 2040 and, once adopted, will replace/supersede the currently adopted 2013 Plan.

6. HRA is an iterative process. The HRA has informed the updating of the Plan throughout its preparation, including policy wording and site allocation selection. The HRA has also been informed by changes made to the draft plan update at each stage. The HRA has also informed the preparation of the Sustainability Appraisal (SA) of the Plan update, which incorporates Strategic Environmental Assessment (SEA).

7. The HRA has concluded that the updated Plan, with main modifications, is compliant with the Habitats Regulations and would not be likely to result in significant effects on the integrity of any international site, either alone or in-combination with other plans or projects. Natural England agrees with this conclusion.

8. The updated Plan has been through statutory consultation and Examination in Public (EIP), and with the incorporation of main modifications, has been found sound by the Planning Inspectorate.

¹ National Planning Policy Framework (December 2023), Para. 33 - https://webarchive.nationalarchives.gov.uk/ukgwa/20231228093504/https://www.gov.uk/government/publications/national-planning-policy-framework--2

1. Introduction

Purpose

1.1 This report is the final HRA document and summarises the Habitats Regulations Assessment (HRA) of the update of the Hampshire Minerals and Waste Plan (HMWP), to support its adoption by the Hampshire minerals and waste planning authorities (Hampshire Authorities).

1.2 The Plan update has been through statutory consultation and Examination in Public (EIP), and with the incorporation of modifications set out in the Schedule of Main Modifications (see para. 1.3), has been found sound by the Planning Inspectorate.

1.3 This report should be read in conjunction with the following reports, which are available at: https://www.hants.gov.uk/landplanningandenvironment/strategic-planning/hampshire-minerals-waste-plan/minerals-waste-plan-partial-update-consultation/examination-library:

• (SD01) Submission Plan.
• (MD05) Schedule of Proposed Main Modifications.
• (HA14) HRA Revised Baseline and Methodology Report (September 2021) - Regulation 18 stage of Plan preparation.
• (HA15) HRA Screening Report (August 2022) - Regulation 18 stage of Plan preparation.
• (HA46) HRA Screening Report (Proposed Submission) December 2023 - Regulation 19 stage of Plan preparation.
• (HA47) HRA Appropriate Assessment (Proposed Submission) October 2023 - Regulation 19 stage of Plan preparation.
• (SD06) HRA Screening Report (Submission) July 2024 - Submission stage of Plan preparation.
• (SD07) HRA Appropriate Assessment (Submission) July 2024 - Submission stage of Plan preparation.
• (SD08) HRA Air Quality Addendum (July 2024) - Submission stage of Plan preparation.
• (MD11) HRA Main Modifications Addendum (October 2025) - Post Hearings Main Modifications Consultation.

The updated Hampshire Minerals and Waste Plan

1.4 Hampshire County Council, New Forest National Park Authority, Portsmouth City Council, South Downs National Park Authority and Southampton City Council (the Hampshire Authorities) worked in partnership to prepare an update of the HMWP, which will guide minerals and waste decision-making in the Plan area.

1.5 The current HMWP was adopted in October 2013². The National Planning Policy Framework (NPPF) requires that Local Plans should be reviewed to assess whether they require updating at least once every five years³.

1.6 A second review of the 2013 HMWP in 2020 recommended updating the HMWP to reflect national policy changes, the Hampshire 2050 Vision for the Future, and to ensure that the Plan is delivering a steady and adequate supply of minerals and enabling sustainable waste management provision. It was subsequently decided by all partners that the HMWP would be subject to partial update. This is important as out of date plans limit the ability for planning authorities to enable the right development, in the right location, at the right time, and may lead to a greater number of planning applications determined at appeal.

1.7 During preparation it became apparent that the process had become a full update of the 2013 Plan. The updated HMWP will cover the period up to 2040 and, once adopted, will replace/supersede the currently adopted 2013 Plan.

1.8 Minerals and waste planning issues are most appropriately addressed jointly so that strategic issues can be satisfactorily resolved. The updated HMWP covers those geographical parts of the Hampshire Authorities that are within the Plan boundary (see Figure 1.1).

Figure 1.1: Hampshire Authorities’ administrative areas within Hampshire

² Hampshire Minerals & Waste Plan (2013) - https://www.hants.gov.uk/landplanningandenvironment/strategic-planning/hampshire-minerals-waste-plan

³ National Planning Policy Framework (December 2023), Para. 33 - https://webarchive.nationalarchives.gov.uk/ukgwa/20231228093504/https://www.gov.uk/government/publications/national-planning-policy-framework--2

2. Habitats Regulations Assessment Process

Requirement for HRA

2.1 The need for HRA is set out in the Conservation of Habitats and Species Regulations 2017⁴ (as amended by the Conservation of Habitats and Species (Amendment) (EU Exit) Regulations 2019), commonly referred to as the Habitats Regulations. The Regulations transpose two pieces of retained European law – Directive 2009/147/EC on the conservation of wild birds (the Birds Directive) and Directive 92/43/EEC on the conservation of natural habitats and of wild fauna (the Habitats Directive) – into domestic law.

2.2 The Habitats Regulations requires that:

• any plan or project, which is not directly connected with or necessary to the management of a National Site Network (NSN) site,
• but would be likely to have a significant effect on such a site,
• either individually or in combination with other plans or projects,
• shall be subject to an ‘Appropriate Assessment’ of its implications for the NSN site,
• in view of the site’s Network objectives⁵.

2.3 As the update of the HMWP is not directly connected with or necessary to the nature conservation management sites covered by the Habitats Regulations, and as it is a land use plan, it has been subject to HRA.

2.4 Regulations 105 to 109 of the Habitats Regulations require competent authorities to assess the effects of ‘land use plans’ on International sites where the plans are not directly connected with or necessary to the management of those sites. This requirement applies to Local Development Documents including Development Plan Documents) and, as such, this requirement applies to the update of the HMWP.

2.5 Under Regulation 105, the assessment must determine whether or not a plan will adversely affect the integrity of the International site(s) concerned, either alone or in combination with other plans or projects. Plans can only be permitted having ascertained that there will be no adverse effect on the integrity of the site(s) in question.

2.6 Where effects on ecological integrity are identified, plan-makers must first consider alternative ways of achieving the plan’s objectives that avoid significant effects entirely. Where it is not possible to meet objectives through other means, mitigation measures that allow the plan to proceed by removing or reducing significant effects may be considered. If it is impossible to avoid or mitigate the adverse effect, the plan-makers must demonstrate, under the conditions of Regulation 107, that there are Imperative Reasons of Overriding Public Interest to continue with the proposal. In such cases, compensation would be necessary to ensure the overall integrity of the site network. This is widely perceived as an undesirable position and should be avoided if at all possible.

2.7 HRA is undertaken by the Competent Authority, which is the authority that has legally delegated powers of authority under Regulation 7 of the Habitats Regulations. In the case of the HMWP Update, Hampshire County Council, New Forest National Park Authority, Portsmouth City Council, South Downs National Park Authority and Southampton City Council are the minerals and waste planning authorities (MWPA) for their respective parts of the Plan area, and as such are the competent authorities for this HRA.

2.8 Sites which must be considered in the HRA process include Special Protection Areas (SPA) and Special Areas of Conservation (SAC), both part of the national site network (NSN) and designated under the Habitats Regulations. ‘Potential’ or ‘Possible’ SACs (pSACs), ‘Candidate’ SACs (cSACs) and ‘Potential’ SPAs (pSPAs) (i.e., sites that have yet to be formally ‘classified’ as SPAs or ‘designated’ as SACs but are proposed as such) are also considered as NSN sites.

2.9 Ramsar sites (internationally important wetland habitats recognised under the Ramsar Convention) mostly overlie SPA classifications and SAC designations in the UK. The criteria for listing a site as a Ramsar site are different to those used for SPAs and SACs, but the Ramsar criteria are of equal importance for the ecological functioning and integrity of the relevant site. National planning policy⁶ requires that Ramsar sites are also assessed within HRA.

2.10 For the purposes of the HRA of the HMWP update, NSN sites and Ramsar sites, are collectively referred to as ‘international sites’. Additionally, while the terminology relating to the designation, classification or listing of an international site varies depending on whether it is an SPA, SAC or Ramsar site, for the purposes of this HRA, ‘designations’ and ‘designated’ will be used to refer collectively to these terms.

2.11 HRA is an iterative process. The HRA has informed the preparation of the updated Plan throughout its preparation, including policy wording and site allocation selection. The HRA has also been informed by changes made to the draft Plan update. The HRA has also informed the preparation of the integrated Sustainability Appraisal (SA)/Strategic Environmental Assessment (SEA), particularly in relation to SA Objective 3: Protect, maintain and enhance biodiversity and geodiversity including natural habitats, flora and fauna, and protected species.

HRA Methodology and Baseline

2.12 The methodological basis for the HRA of the HMWP update relating to the potential of effects on the integrity of international sites is provided in detail in the HRA Revised Baseline and Methodology Report⁷.

2.13 The HRA methodology, agreed with Natural England, utilised the guidance provided in The Habitats Regulations Assessment Handbook⁸. This guidance is non-statutory, but “based on experience, good practice and authoritative published guidance”. The handbook had been updated regularly and therefore provided the most up-to-date guidance on interpretation of the Habitats Regulations and the process of HRA at the time of undertaking this HRA (the handbook will be discontinued from January 2026).

2.14 The four-stage approach to Habitats Regulations Assessment set out in ‘The Habitats Regulations Assessment Handbook’ is summarised in Figure 2.1, below.

Figure 2.1: Four stage approach to HRA

2.15 In line with similar assessments, a buffer of 10km was applied around the Plan area to help identify International sites that may be affected by the update of the HMWP. This includes International sites lying partially or wholly within 10km of the Plan boundary. Using this buffer, it is evident that 30 International sites lie partially or wholly within Plan boundary and 13 International sites lie outside the Plan area but wholly or partially within the 10km buffer. An additional International site outside the 10km buffer area is also considered based on the screening requirements of relevant local plan policy. Table 2.1 lists all relevant sites, and the identified International sites are shown geographically in Figures 2.2 – 2.5, below.

Table 2.1: Relevant International sites

Figure 2.2: All International Designated sites (including Ramsar sites) that lie wholly or partly within the Plan area and 10km buffer (a 5km buffer is also included for reference)

Figure 2.3: Designated SAC (Special Area of Conservation) sites that lie wholly or partly within the Plan area and 10km buffer (a 5km buffer is also included for reference)

Figure 2.4: Classified SPA (Special Protection Area) sites that lie wholly or partly within the Plan area and 10km buffer (a 5km buffer is also included for reference)

Figure 2.5: Listed Ramsar sites that lie wholly or partly within the Plan area and 10km buffer (a 5km buffer is also included for reference)

2.16 For each of the identified International sites, the Baseline and Methodology Report details the following information:

• Site description and locational information.
• International site Conservation Objectives.
• Component SSSI Units.
• European site condition (through SSSI Units).
• NSN site vulnerabilities and sensitivities.

2.17 Natural England, as the Statutory Nature Conservation Body, was formally consulted on Version 1 of the HRA Baseline and Methodology Report in June 2021 and their response is provided in Appendix 1. Their response states that “Natural England understands that the partial update of the Hampshire Minerals and Waste Plan has the potential to affect Habitats (European) sites, particularly as it may allocate proposed sites for development. We agree with the proposed methodology for assessing these impacts and advise where likely significant effects are identified they are evaluated through a full Appropriate Assessment.”

2.18 Subsequently, the HRA Revised Baseline and Methodology Report (August 2022) was submitted, along with the HRA Screening Report (August 2022), Draft Plan and other documents, as part of the Regulation 18 Draft Plan Consultation that ran for twelve weeks from 8 November 2022 to 31 January 2023. Natural England’s response to that consultation is provided in Appendix 2 and includes no further comments on the HRA Baseline and Methodology Report.

HRA Screening

2.19 Development management, minerals and waste policies and proposed site allocations were screened for their potential effects on the integrity of international sites both alone and in-combination with other plans and projects. Site integrity is defined as “the coherence of its structure and function across its whole area that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified”¹⁰.

2.20 The screening process followed the HRA baseline and methodology agreed with Natural England, as set out in the HRA Revised Baseline and Methodology Report (August 2022). The screening process is detailed in the HRA Screening Report (Submission) July 2024¹¹.

2.21 The objective of this stage of the HRA was to ‘screen out’ elements of the Plan that were unlikely to have any significant effect on any international site, either alone or in-combination with other plans or projects; and to identify any aspects of the Plan that could have such an effect, so that mitigation measures can be considered at the next stage of HRA. Significant effect is defined as “…any effect that may reasonably be predicted as a consequence of a plan or project that may affect the conservation objectives of the features for which the site was designated, but excluding trivial or inconsequential effects”¹².

2.22 The following potential development hazards were identified and considered as part of the screening process for both minerals (M) and waste (W) activities:

• Land take (M&W).
• Removal of supporting habitat (M&W).
• Noise; vibration; lighting; dust; (M&W).
• Water pollution (M&W).
• Leachate (W).
• Changes in surface / groundwater hydrology (M).
• Water use (W).
• Traffic (M&W).
• Emissions of aerial pollutants / air quality (M&W).
• Impact of building (W).
• Litter; vermin (W).
• Recreational displacement impacts (M&W).

2.23 To determine if site allocation proposals were likely to have any significant effects on international sites, the following issues were considered:

• Could the proposals affect the qualifying interest of the international site (is the site sensitive to the effect).
• The probability of the effect happening.
• The likely consequences for the site’s Conservation Objectives (as defined by Natural England) if the effect occurred.
• The magnitude, duration and reversibility of the effect.

2.24 It is a requirement of the Habitats Regulations that the impacts and effects of any land use plan being assessed are not considered in isolation but in-combination with other plans and projects that may also be affecting the international site(s) in question. It is neither practical nor necessary to assess the ‘in-combination’ effects of the Plan within the context of all other plans and projects within the region. Principal plans and projects considered as part of the screening of proposed minerals and waste site allocations, and listed individually in the HRA Screening Assessment (Submission) July 2024, include:

• Hampshire and neighbouring local authority Local Plans.
• Hampshire and neighbouring Local Transport Plans.
• Neighbouring Minerals and Waste Plans.
• Relevant Nationally Significant Infrastructure Projects.

2.25 The decision-making process under the Habitats Regulations is underpinned by the precautionary principle, whereby the Competent Authorities (Hampshire Authorities) act to avoid potential harm in the face of scientific uncertainty. If it is not possible in a 'likely significant effect' test to rule out a risk of significant effect on a European site on the basis of available evidence, then it should be assumed a risk may exist and needs to be dealt with at the next stage of HRA. This precautionary approach was taken at all stages of the HRA assessment, where faced with scientific uncertainty.

2.26 Screening tables were used to systematically screen Policies and draft/proposed site allocations, which are set out in the aforementioned HRA Screening Reports.

2.27 When undertaking a screening assessment for an HRA, the ‘People Over Wind’ judgement (Sweetman Ruling)¹³ is of particular relevance, which ruled that mitigation cannot be taken into account when considering the screening test for Likely Significant Effects. If significant effects are considered likely a site or policy must, therefore, be screened-in for further consideration. This approach was followed for all stages of screening of the HMWP update.

2.28 The HRA Screening Report (August 2022) was provided for comment to statutory consultees, including Natural England, as part of the public ‘Regulation 18 Draft Plan Consultation’ that ran for twelve weeks from 8 November 2022 to 31 January 2023. In their response to the consultation (Appendix 2), Natural England stated, in relation to the Screening Report – “Natural England concur with the impact pathways listed and discussed within the screening report.” The HRA Screening Report (Proposed Submission) December 2023 was submitted as part of the Regulation 19 Consultation (Natural England’s response to this consultation is provided in Appendix 3). Subsequently, the HRA Screening Report (Submission) July 2024 formed part of the HMWP update Submission to the Planning Inspectorate and subject to Examination in Public (EiP).

2.29 Of the 36 minerals and waste proposed allocation sites included with the Draft Plan at the Regulation 18 Consultation stage, twenty-four sites were screened in, as having the potential to have a likely significant effect on International sites, requiring further consideration in an Appropriate Assessment. Furthermore Policy 20: Local land-won aggregates and Policy 29: Locations and sites for waste management were also screened in for listing screened in sites¹⁴.

2.30 A number of proposed minerals site allocations and all waste site allocations were removed from the Draft Plan update just prior to and following the Regulation 18 Draft Plan Consultation. The reasons for those sites not being taken forward in the Proposed Submission Plan are set out in Table 7.1 of the HRA Screening Report (Submission)¹⁵, with more detailed reasoning provided in the Proposal Study¹⁶. Site allocations (mineral site allocations) taken forward in the Submission Plan are as follows:

• Hamble Airfield (EAL02)
• Ashley Manor Farm (NFD01)
• Purple Haze (NFD03)
• Midgham Farm (NFD04)
• Andover Sidings (TSV09)

2.31 Following re-screening for the Regulation 19 Consultation, Andover sidings was screened out with the other four sites screened in. In addition, Policy 20 continued to be screened in for referencing screened in sites, but Policy 29 was then screened out as no screened in waste site allocations had been taken forward.

HRA Appropriate Assessment

2.32 Following the Regulation 18 Consultation, an Appropriate Assessment was undertaken for screened-in Policy 20 and the four screened in minerals site allocations, as follows:

• Hamble Airfield (EAL02)
• Ashley Manor Farm (NFD01)
• Purple Haze (NFD03)
• Midgham Farm (NFD04)

2.33 The HRA Appropriate Assessment (Submission) report¹⁷ sets out the Appropriate Assessment process in detail. The Appropriate Assessment followed the HRA methodology agreed with Natural England, as set out in the HRA Revised Baseline and Methodology Report.

2.34 In assessing the effects of screened-in proposed site allocations, the Appropriate Assessment considered a number of assumptions relating to the following types of impacts, set out in Section 4 of the HRA Appropriate Assessment Submission Report:

• Physical damage / loss of habitat.
• Indirect disturbance from noise, vibration and/or light pollution.
• Changes to water levels and water quality, including nutrient neutrality.
• Air pollution.
• Dust.
• Soil contamination.
• Invasive species / vermin / litter.
• Physical infrastructure.
• Recreational displacement.
• In-combination effects.

2.35 Potential effects tables (Tables 4.2 – 4.5 of the submission HRA Appropriate Assessment Report) were used to systematically assess the effects of proposed site allocations using mitigation/measures including relevant Development Considerations, Development Management Policies, HRA requirements, and Environment Agency permitting requirements. Further discussion is also included in relation to the consideration of the potential of in combination effects with other plans and projects. These tables, incorporating updates from the EiP Hearings and subsequent main modifications are presented in Appendix 4 of this document.

2.36 The Appropriate Assessment established the nature of the potential effects of screened-in site allocations on the integrity of international sites and concluded that the Submission Plan is compliant with the Habitats Regulations and would not result in likely significant effects on any International sites, either alone or in-combination with other plans or projects. For development coming forward on either the allocated sites or non-allocated sites, it is considered that there are sufficient mitigation and other measures set out in the Plan, or elsewhere, such as via planning proposal HRA requirements, regulatory requirements and development management processes.

2.37 Policy 20 was subject to Appropriate Assessment as a result of its reference to one or more screened-in sites. Based on the assessment’s conclusion for screened-in site allocations, the policy was deemed not likely to have a significant effect on any international site either alone or in-combination with other plans or projects.

2.38 It is a requirement of Regulation 105(2) of the Habitats Regulations that the relevant Statutory Nature Conservation Body (Natural England) is consulted at the Appropriate Assessment stage. The Appropriate Assessment report was provided to statutory consultees, including Natural England, for comment as part of the public ‘Regulation 19 Proposed Submission Consultation’ that ran for eight weeks from 9 January 2024 to 5 March 2024. Natural England’s response to the Regulation 19 Consultation is set out Appendix 3.

HRA Air Quality Addendum

2.39 Natural England’s response to the Regulation 19 Consultation stated that “We would expect the plan to address the impacts of air quality on the natural environment. In particular, it should address the traffic impacts associated with new development, particularly where this impacts on European sites and SSSIs.”

2.40 Furthermore, Natural England advise “that assessment, alone and in combination with other plans and projects, should be carried out in line with Natural England guidance that provides a simple step by step approach to assessing road traffic emissions under the Habitats Regulations. All designated sites that may be impacted by the affected road network within a reasonable buffer zone should be screened in for consideration under the Local Plan appropriate assessment.”

2.41 Natural England considered that the “submitted Appropriate Assessment leaves much of the assessment of impacts to ‘development considerations’. As the Minerals and Waste Planning Authority have not assessed these impacts themselves, or evidenced whether there is scope for appropriate avoidance and mitigation measures to be effectively secured, we currently have concerns that the sites may not be deliverable.”

2.42 Natural England “advises that one of the main issues which should be considered in the plan and the …HRA are proposals which are likely to generate additional nitrogen emissions as a result of increased traffic generation, which can be damaging to the natural environment.” Natural England also stated “that ammonia (NH3) from traffic emissions should also be assessed as the impact from this source on designated sites is currently unclear.”

2.43 For Purple Haze specifically, Natural England stated that they “disagree that a complete list of impact pathways has been appropriately assessed for Likely Significant Effects under the Habitats Regulations Assessment Screening report.” Furthermore, “We advise that this allocation has the potential to adversely affect European designated sites from air quality impacts. Natural England recommend that your Plan must demonstrate its air quality modelling to robustly support any conclusions of no adverse effect on designated site integrity. Without this information, Natural England cannot agree with the Plan’s Appropriate Assessment conclusions.”

2.44 For Midgham Farm specifically, Natural England “recommend that your Plan must demonstrate its air quality modelling to robustly support any conclusions of no adverse effect on designated site integrity. Without this information, Natural England cannot agree with the Plan’s Appropriate Assessment conclusions.”

2.45 In view of these comments an HRA Air Quality Addendum¹⁸ was prepared in liaison with Natural England. The purpose of this assessment and report was to consider and document potential air quality effects from traffic impacts, more fully, on International sites and their component SSSIs that relate to the HMWP update for all four screened in site allocations, and address Natural England’s relevant concerns.

2.46 The methodology, assumptions and thresholds employed in the air quality assessment and addendum, agreed with Natural England, are set out in the Addendum and will not be duplicated here.

2.47 The conclusion of the Addendum was that subject to the implementation of the relevant Development Management Policies, Development Considerations and appropriate mitigation measures, set out in the Addendum and in the Submission HRA Appropriate Assessment, the HMWP update site allocations could be developed for minerals extraction without being likely to have significant air quality effects on any International sites or component SSSI units, alone and in-combination with other plans and projects. Natural England agrees with this conclusion.

2.48 Following a meeting with Natural England on 12 June 2024, the revised HRA Air Quality Addendum was submitted to Natural England on 19 June 2024. An email was then received from Natural England on 24 June 2024 stating “We welcome the latest air quality addendum which is very much improved. Although some of the data is less relevant for designated sites impacts, based on the information provided and knowledge of the sites in question we can now agree with your overall conclusions that air quality impacts can be avoided for the Minerals and Waste Plan.”

2.49 The outcome and conclusion of the HRA Air Quality Addendum reinforces the conclusion of the HRA Submission Appropriate Assessment that the Submission Plan is compliant with the Habitats Regulations and would not result in likely significant effects on any International sites, either alone or in-combination with other plans or projects.

2.50 Both the HRA Screening and Appropriate Assessment reports were updated with the additional outcomes documented in the final HRA Air Quality Addendum to ensure that all three reports were consistent and up to date prior to their submission with the Submission Plan to the Planning Inspectorate.

Additional Hydrological Information – Purple Haze

2.51 A further email was received from Natural England on 1 July 2024 which outlined the following: “We have made significant progress since the Reg 19 consultation and I’m really pleased that many areas of concern have now been addressed for the Plan. The only remaining area of concern for us is the hydrology at Purple Haze, as this factor still has potential to affect the deliverability of the site. As this is our only outstanding area of concern, we wouldn’t usually question the soundness of the Plan at this stage, but would be satisfied with the Inspector determining whether the Plan gives sufficient certainty in effective delivery overall”

2.52 An updated draft Statement of Common Ground (SoCG) was sent to Natural England in April 2025 and comments were received. Natural England outlined its remaining area of disagreement as follows: “Natural England view that there remains significant uncertainty as to whether the Purple Haze site allocation could come forward without having adverse impacts on designated sites. Although there are many potential impacts on the environment from this allocation, the key current uncertainty lies in whether any mitigation would be capable of avoiding the potential hydrological impacts on designated site features. In Natural England’s view this brings into question whether this allocated site is deliverable.”

2.53 In order to progress the then planning application for Purple Haze and to inform the discussion on the site allocation, Hampshire County Council commissioned specialist hydrological advice. The advice concluded the following in relation to the site allocation¹⁹: “A development that would reduce its extent to the southern part of the site and would keep the same “dry” working conditions (i.e. excavation to not reach the groundwater table), would remove all impacts, because no activities would interact with the hydrological and hydrogeological pathways to Ebblake Bog. The exact boundary delineation between the northern and southern part will depend on outcome of the additional investigations (i.e. understanding generated on “surface water runoff zones” and additional ground investigations), but would approximately correlate with the upper most limit of the southern mire feeding into Ebblake Bog…”

2.54 A meeting was held between Hampshire County Council (on behalf of the Hampshire Authorities) and Natural England on 20 August 2025 to discuss the specialist hydrological advice, and the Hampshire Authorities proposed response which included further amendments to the Development Considerations and additional Development Considerations. These amendments are outlined in Para. 3.11 of the SoCG²⁰ and were agreed by Natural England at the meeting as being suitable additions to address its remaining concerns on hydrology. The additional specialist hydrological advice was considered further at the EIP hearing of 9 September 2025.

Main Modifications

2.55 Proposed modifications were discussed at the Submission Plan Examination Hearings 4 February to 13 February 2025 and 9 September 2025 (Purple Haze allocation specific hearing). A list of Main Modifications were subsequently provided in the Schedule of Proposed Main Modifications²¹.

2.56 The proposed Main Modifications were produced to address issues raised by the Inspector, or matters arising from representations through the Examination process, and are changes which, either alone or in combination with others, would materially alter the Plan or its policies.

2.57 The Main Modifications relate to the refinement of policy and supporting text to provide greater clarity or the updating of content where appropriate. These modifications do not influence the location, nature or scale of development, but instead add clarity, justification and additional detail in respect of policies and proposals previously included and subject to assessment.

2.58 An HRA of the Main Modifications was undertaken and presented as an HRA Addendum document²² to identify the potential of the Modifications to materially affect the conclusions of the Appropriate Assessment and/or result in a significant effect on any of the identified international sites in respect of the following potential impacts:

• Direct land take and removal of supporting habitat.
• Noise, vibration and lighting.
• Emission of aerial pollution and particulates (including traffic related).
• Water pollution and changes in surface / groundwater hydrology.
• Impact of built development.
• Traffic.
• Recreational related impacts.
• Invasive species, vermin and litter.

2.59 The assessment concluded that the proposed Main Modifications would not result in material changes to the Submission Plan from the perspective of the Habitats Regulations²³ and would not be likely to have a significant effect on the integrity of any international site or component SSSI unit, either alone or in-combination with other plans or projects.

2.60 The HRA Main Modifications Addendum was provided to statutory consultees, including Natural England, as part of the Regulation 24 Main Modifications public consultation that ran for ten weeks from 4 December 2025 to 12 February 2026. In their response to the consultation, Natural England stated that “We welcome the revisions included in the Main Modifications consultation,… We also support the changes to the Purple Haze and Midgham Farm allocations, which appropriately reflect the agreements set out in the Statement of Common Ground dated 9 October 2025”. Natural England’s response in full, dated 12 February 2026, is provided in Appendix 5.

2.61 The Inspector considered all comments received from the main modifications consultation and concluded that the updated HMWP is sound and can be adopted by the Hampshire Authorities, subject to making the modifications identified in the Schedule of Main Modifications. The Inspector’s Report is available on the HMWP Examination Library²⁴.

⁴ Conservation of Habitats and Species Regulations 2017 (as amended) - https://www.legislation.gov.uk/uksi/2017/1012/contents/made

⁵ Management objectives for the national site network which contribute to the conservation of UK habitats and species that are also of pan-European importance, and to the achievement of their Favourable Conservation Status within the UK.

⁶ National Planning Policy Framework (NPPF) December 2023 (para. 187) - https://webarchive.nationalarchives.gov.uk/ukgwa/20231228093504/https://www.gov.uk/government/publications/national-planning-policy-framework--2

⁷ (HA14) HRA Revised Baseline and Methodology Report (September 2021) - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRARevisedBaselineandMethodologyReport-September2021.pdf

⁸ Tyldesley, D. and Chapman, C., (2013) The Habitats Regulations Assessment Handbook, October 2018 edition (DTA Publications Ltd: Berkshire) - www.dtapublications.co.uk

⁹ Sussex Bat Special Area of Conservation Planning and Landscape Scale Enhancement Protocol. SDNPA and Natural England (unpublished draft): https://www.southdowns.gov.uk/wp-content/uploads/2018/04/TLL-15-Draft-Sussex-Bat-SAC-Protocol.pdf

¹⁰ Paragraph 20 of ODPM Circular 06/2005 on Biodiversity and Geological Conservation.

¹¹ (SD06) HRA Screening Report (Submission) July 2024 - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRAScreeningReport-July2024.pdf

¹² English Nature (1999) Habitats regulations HR3GN guidance note: The Determination of Likely Significant Effect under The Conservation (Natural Habitats &c) Regulations 1994. English Nature November 1999.

¹³ Court of Justice of the European Union - 12 April 2018 (Case C323/17).

¹⁴ (HA15) HRA Screening Report (August 2022) - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRA-ScreeningReport-August2022.pdf

¹⁵ (SD06) HRA Screening Report (Submission) July 2024 - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRAScreeningReport-July2024.pdf

¹⁶ (HA53) Mineral and Waste Site Proposal Study (October 2023) - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-SiteProposalStudy-ProposedSubmission-October2023.pdf

¹⁷ (SD07) HRA Appropriate Assessment (Submission) July 2024 - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRAAppropriateAssessment-July2024.pdf

¹⁸ (SD08) HRA Air Quality Addendum July 2024 - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRAAirQualityAddendum-July2024.pdf

¹⁹ (EX38) Technical Memo on hydrology at Purple Haze - https://documents.hants.gov.uk/mineralsandwaste/EX38-Specialist-advice-on-PurpleHazehydrology-030725.pdf

²⁰ (EX40) Statement of Common Ground between Hampshire Authorities and Natural England (28 August 2024) - https://documents.hants.gov.uk/mineralsandwaste/EX40-NaturalEnglandStatement-of-CommonGround-280825.pdf

²¹ (MD05) Schedule of Proposed Main Modifications - https://documents.hants.gov.uk/mineralsandwaste/MD05-HMWP-PartialUpdate-MainModifications.pdf

²² (MD11) HRA Main Modifications Addendum (October 2025) - https://documents.hants.gov.uk/mineralsandwaste/MD11-HMWP-PartialUpdate-HRA-MainModificationsAddendum.pdf

²³ Conservation of Habitats & Species Regulations 2017 (as amended) - https://www.legislation.gov.uk/uksi/2017/1012/contents

²⁴ Examination Library - https://www.hants.gov.uk/landplanningandenvironment/minerals-waste-planning/hampshire-minerals-waste-plan/minerals-waste-plan-partial-update-consultation/examination-library

3. Conclusion

3.1 In compliance with Regulation 105(1) of the Habitats Regulations, the Hampshire Authorities have, before the Plan is given effect, made an appropriate assessment of the implications of those components of the Plan that could potentially have a significant effect on the integrity of relevant international sites.

3.2 In compliance with Regulation 105(2), the Hampshire Authorities have, for the purposes of the assessment, consulted the appropriate nature conservation body (Natural England) and have had regard to its representations. These representations are set out in this document. The information included in the HRA and its conclusion are in accordance with the advice and recommendations of Natural England.

3.3 As required by Regulation 105(3), the Hampshire Authorities have taken the opinion of the general public, having provided the HRA for formal public consultation at various stages through plan preparation and have had regard to associated representations.

3.4 As required by regulation 105(4), the Hampshire Authorities have ascertained that the Plan update will not adversely affect the integrity of international sites, prior to giving it effect.

3.4 As required by Regulation 105(5), the Hampshire Authorities have provided comprehensive baseline information to support the HRA and documentation detailing all stages of the HRA process.

3.5 The Main Modifications required by the Planning Inspectorate following Examination in Public were subject to HRA followed by public consultation, and found to have no material effect on the conclusion of the Appropriate Assessment.

3.5 The HRA of the HMWP update concludes that the updated Plan would not be likely to result in significant effects on the integrity of any international site, either alone or in-combination with other plans or projects. Natural England agrees with this conclusion.

Signed:

(Laura McCulloch, Head of Spatial Planning, Hampshire County Council, on behalf of the Hampshire Authorities)

Date: 5 May 2026

Acronyms / initialisations

AA

Appropriate Assessment

EiP

Examination in Public

EU

European Union

HMWP

Hampshire Minerals and Waste Plan

HRA

Habitats Regulations Assessment

MWPA

Minerals and waste planning authority

NPPF

National Planning Policy Framework

NSN

National site network

SEA

Strategic Environmental Assessment

SA

Sustainability Appraisal

SAC

Special Area of Conservation

SPA

Special Protection Area

SSSI

Site of Special Scientific Interest

Glossary

Appropriate Assessment (AA)

A self-contained step in the wider decision-making process of Habitats Regulations Assessment (HRA), required under the Conservation of Habitats and Species Regulations 2017 (as amended). An appropriate assessment is only required where the competent authority determines that the plan or project is likely to, or may, have a significant effect on a National Site Network (NSN) site or Ramsar site, either alone or in combination with other plans or projects, and the plan or project is not directly connected with or necessary to the management of that site.

Competent Authority

A competent authority is any Minister, Government Department, public or statutory undertaker, public body of any description or person holding public office. Used in the Habitats Regulations to refer to the authority that is responsible for adopting, authorising or undertaking a plan or project.

Conservation Objectives

A statement of the nature conservation aspirations for a site, expressed in terms of the favourable condition that is sought for the species and/or habitats for which the site has been selected to attain.

Conservation Status

Four parameters are considered when assessing conservation status. For habitat these are range, area, structure and function (referred to as habitat condition) and future prospects. For species, the parameters are range, population, habitat (extent and condition) and future prospects. The Habitats Regulations define when the conservation status of the habitats and species it lists is to be considered as favourable.

Cumulative Impacts/Effects

Impacts/effects that result from the incremental changes caused by other past, present or reasonably foreseeable actions together with the plan or project in question.

Development Plan Document (DPD)

Spatial planning documents which are subject to independent examination.

Favourable Condition

The condition represented by the achievement of the conservation objectives; the desired condition for a designated habitat or a species on an individual site.

Favourable Conservation Status

The conservation status of habitats and species is ‘favourable’ where all that is necessary to sustain the habitats and species in the long term is in place.

Habitats Directive

Abbreviated term for European Council Directive 92/43/EEC on the Conservation of natural habitats and of wild fauna and flora (1992). It is the aim of this Directive to promote the conservation of certain habitats and species within the European Union and is implemented in the UK through the Habitats Regulations.

Habitats Regulations

Abbreviated term for The Conservation of Habitats and Species Regulations 2017 (as amended), which transposes the European Habitats Directive into UK legislation.

Habitats Regulations Assessment (HRA)

As required by the Habitats Regulations, the identification of any aspects of an emerging plan or project that would have the potential to cause a likely significant effect on National Site Network (NSN) sites and Ramsar sites (either alone or in combination with other plans and projects), and to begin to identify appropriate mitigation strategies where such effects are identified (see also Appropriate Assessment).

Habitats Sites

Habitats Sites are protected areas in the UK (like SACs and SPAs) designated under the Habitats Regulations for rare species/habitats, forming the UK National Site Network after Brexit, replacing the EU's Natura 2000 network. This network, also including Ramsar sites, ensures legal protection for biodiversity, requiring rigorous assessments (Habitats Regulations Assessments) for any plans or projects potentially affecting them. Habitats Sites are referred to as international sites in this document, for consistency.

In-Combination Effect

Effects, which may or may not interact with each other, but which could affect the same receptor or interest feature (i.e. a habitat or species for which a European Site is designated).

Integrity (of a site)

The coherence of a site’s ecological structure and function across its whole area that enables it to sustain the habitat, complex of habitats and/or levels of populations of the species for which it was classified.

Interest Feature

A natural or semi-natural feature for which an International site has been selected. This includes any Habitats Directive Annex I habitat, any Annex II species and any population of a bird species for which an SPA has been classified under the Birds Directive.

Local Development Documents (LDD)

Documents that form part of a statutory development plan (Development Plan Documents) or which amplify the policies of the statutory development plan (Supplementary Planning Documents).

Main Modifications

Following the Examination in Public (EIP) Hearings, the Planning Inspector required a number of changes to the Plan update, known as ‘Main Modifications’, which were considered necessary to address issues of soundness.

Mitigation

The process by which negative or harmful effects caused by a development are prevented or lessened by incorporating countermeasures into the design or operation.

National Planning Policy Framework (NPPF)

First published in March 2012, the NPPF sets out the Government’s planning policies for England and how these are expected to be applied.

National Site Network (NSN)

Under the Conservation of Habitats and Species (Amendment) (EU Exit) Regulations 2019, SACs and SPAs in the UK no longer form part of the EU’s Natura 2000 ecological network. The 2019 Regulations have created a national site network on land and at sea, including both the inshore and offshore marine areas in the UK. NSN sites along with Ramsar sites are collectively referred to as Habitats Sites by government and are referred to as international sites in this document for consistency.

Natural England

A non-departmental public body sponsored by the Department for Environment, Food and Rural Affairs (DEFRA), responsible for ensuring that England's natural environment, including its land, flora and fauna, freshwater and marine environments, geology and soils, are protected and improved. The body designates National Landscapes and National Parks, manages National Nature Reserves and notifies Sites of Special Scientific Interest, and is the Statutory authority with respect to the conservation/network objectives of the National Sites Network. It also has a responsibility to help people enjoy, understand and access the natural environment.

Precautionary Principle

An approach which takes avoiding action based on the possibility of significant environmental or other damage, even before there is conclusive evidence that the damage will occur.

Ramsar Site (Wetland of International Importance)

An internationally important wetland site designated under the Convention on Wetlands of International Importance (Ramsar, Iran - 1971), especially as wildfowl habitat. As a matter of government policy, Ramsar sites are afforded the same protection as sites designated under the Habitats Regulations. The first Ramsar sites in the UK were designated in 1976.

Regulation 18 Consultation

Initial consultation stage of the preparation/review of a Local Plan under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012.

Regulation 19 Consultation

Pre-submission publication representations stage of the preparation/review of a Local Plan under Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012.

Screening (HRA)

Determination of whether a plan or project (or parts therein) are likely to have a likely significant effect on the integrity of International sites alone or in-combination with other plans or projects and therefore whether an Appropriate Assessment is necessary.

Site of Special Scientific Interest (SSSI)

A site designated by Natural England as an area of special interest by reason of any of its flora, fauna, geological or physiographical features and of national importance. SSSIs are legally protected under the Wildlife and Countryside Act 1981.

Special Areas of Conservation (SAC)

Protected areas that are designated in England and Wales under The Conservation of Habitats and Species Regulations 2017 (as amended). The Regulations require the establishment of a network of important high-quality conservation sites (National Site Network), which includes SACs and SPAs. SACs are designated to make a significant contribution to conserving the habitats and species identified in Annexes I and II, respectively, of EU Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora, known as the Habitats Directive.

Special Protection Areas (SPA)

Protected areas that are classified in England and Wales under The Conservation of Habitats and Species Regulations 2017 (as amended). The Regulations require the establishment of a network of important high-quality conservation sites (National Site Network), which includes SPAs and SACs. SPAs are selected to protect one or more rare, threatened or vulnerable bird species listed in Annex I of EU Directive 2009/147/EC on the conservation of wild birds, known as the Birds Directive.

Strategic Environment Assessment (SEA)

A system of incorporating environmental considerations into policies, plans, programmes. It is intended to highlight environmental issues during decision-making about strategic documents such as plans, programmes and strategies. The SEA identifies the significant environmental effects that are likely to result from implementing the plan or alternative approaches to the plan. The Sustainability Appraisal of the Plan incorporates SEA. To be replaced in the future by Environmental Outcome Reports through the Levelling Up and Regeneration Act 2023.

Sustainability Appraisal (SA)

A systematic process, required under Section 19 of the Planning and Compulsory Purchase Act 2004, that must be carried out during the preparation of a Local Plan. Its role is to promote sustainable development by assessing the extent to which the emerging plan, when judged against reasonable alternatives, will help to achieve relevant environmental, economic and social objectives. The SA for the HMWP update also incorporates SEA.

Appendix 1: Natural England Response to Baseline and Methodology Report Consultation

The following text is Natural England’s response to a formal consultation of ‘Version 1 – June 2021’ of the HRA Baseline and Methodology Report:

Appendix 2: Natural England Response to Regulation 18 Consultation

Natural England’s response to the Regulation 18 consultation relating to the Regulation 18 HRA Screening Report and HRA Baseline and Methodology Report, is included below:

Appendix 3: Natural England Response to Regulation 19 Proposed Submission Plan Consultation

Appendix 4: Updated Appropriate Assessment of screened-in sites and policies

The potential effects of the screened-in allocated sites: Hamble Airfield, Ashley Manor Farm, Purple Haze, and Midgham Farm, on the integrity of international sites and their component SSSI units, alone, were assessed in the HRA Submission Appropriate Assessment²⁵, in Tables 4.2 – 4.5, respectively.

The potential effect of screened-in Policy 20 on the integrity of international sites, alone, is set out in paragraph 4.60, page 121 of the Submission Appropriate Assessment.

The potential effects of screened-in allocated sites and Policy 20 on the integrity of international sites and their component SSSI units, in combination with other plans and projects, is set out in paragraph 4.61, page 121 onwards, in the Submission Appropriate Assessment.

The conclusion of the Submission Appropriate Assessment was that subject to the implementation of mitigation and other measures outlined in assessment Tables 4.2 – 4.5, and through the development management processes, the Submission Plan would not be likely to have a significant effect on any international site or component SSSI unit, either alone or in combination with other plans or projects.

Based on the inclusion of the Main Modifications (MMs) in Policy 20 and the assessment of the four screened-in site allocations, the conclusion remains the same but with a significantly increased level of confidence.

Based on the provision of updated Development Considerations and estimated yields for all four site allocations and additional hydrological information and modified proposed restoration for Purple Haze, updated Appropriate Assessment tables are provided below for information, set out as follows:

• Table A4.1: Purple Haze.
• Table A4.2: Midgham Farm.
• Table A4.3: Hamble Airfield.
• Table A4.4: Ashley Manor Farm.

²⁵ HMWP: Partial Update – HRA Appropriate Assessment (Submission) July 2024 - https://documents.hants.gov.uk/mineralsandwaste/HMWP-PartialUpdate-HRAAppropriateAssessment-July2024.pdf

Table A4.1: Purple Haze (NFD03)

Elements of the following text and the Development Considerations in the table incorporate the Main Modifications (MMs). Text that has been added since the Submission Appropriate Assessment is bold and underlined and text that is deleted is struck through.

Appendix 5: Natural England Response to Main Modifications Consultation

A summary of this document can be made available in large print, in Braille or audio cassette. Copies in other languages may also be obtained. Please contact the Minerals and Waste Policy Team at Hampshire County Council by email HMWP.consult@hants.gov.uk or by visiting hants.gov.uk.