Natural England, the Government’s adviser for the natural environment in England, have recommended that an EIA should be required before development work is carried out on the Treloar Meadows site.

Their recommendation was made within the Consultee Comments section of Planning Application 30021/064 | Request for Screening Opinion on EHDC’s website, and is shown below:

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Schedule 3(2) of the Town & Country Planning (Environmental Impact Regulations) 2011 requires consideration of the selection criteria for Schedule 2 EIA development and identification of ‘environmental sensitivity’. Natural England has identified that the proposed location of the development would be within, adjacent to or in close proximity to the South Downs National Park.

Having considered the information provided, and the landscape and ecological information submitted in support of the previously approved hybrid application for the site (Application Number: 30021/056) Natural England recommends that an EIA should be required.

Our primary concern is that the scheme may have the following significant environmental effects that would warrant an EIA:

Significant loss and damage to the Lord Mayor Treloar Hospital Site of Importance for Nature Conservation (SINC), a county wildlife site that supports species rich chalk grassland. Unimproved chalk grassland is a Priority Habitat under section 41 of the NERC ACT 2006.

Potential adverse impacts on the Ackender Wood and Alexandra Ancient Woodland SINC through recreational disturbance and direct impacts on ancient woodland buffer zones. Information about ancient woodland can be found in Natural England’s standing advice, updated January 2018:

In addition the scheme will need to re-consider potential impacts on views to and from the South Downs National Park, along with potential impacts to European Protected Species (EPS).

In relation to EPS, we recommend that a detailed assessment of the potential impacts on dormice and bat species, resulting from this proposal accompanies any subsequent planning application irrespective of whether an EIA is required. In order to provide this information there may be a requirement for surveys to be carried out at appropriate times of the year. Surveys should always be carried out by suitably qualified and where necessary, licensed consultants.

Should the Council decide that an EIA is not required, Natural England requests that a detailed assessment of the potential impacts of this proposal includes a detailed updated assessment of impacts of Priority Habitats and Ancient Woodland, with particular regard to how such impacts might be avoided. We would be happy to discuss the scope of these assessments with the applicant through our Discretionary Advice Service.

Natural England does not hold locally specific information on potential environmental planning constraints such as Local Sites, local landscape character or Local and National Biodiversity Action Plan species and habitats. We recommend that you seek further information from the appropriate bodies (which may include the local records centre, the local wildlife trust, local geoconservation group or other recording society). Information on these potential assets should be included, where appropriate in a detailed ecological and landscape assessment of the potential impacts of this proposal, in the event that your authority decides a full Environmental Impact Assessment is not necessary.

Should the proposal be amended in a way which significantly affects its impact on the natural environment then, in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, Natural England should be consulted again.