Natural England recognise that Biodiversity Net Gain (BNG) is well referenced throughout Warrington Local Plan but consider more could be done to prepare for mandatory net gain in line with the Environment Act.

The ecological networks and opportunity areas of the borough could be more clearly identified and mapped which going forward, can be advanced into more detailed Local Nature Recovery Strategy in line with the Environment Act.

NE concerned that there is no policy protection in the Plan from development on peat. Development on peat may cause irreversible damage, it will prevent wetland habitat/bog restoration that is vital for resilient ecological networks and will have significant carbon emission implications.

Policy INF2 ? Transport Safeguarding:- Natural England do not agree with the justifications for screening out impacts associated with this policy: Rixton Clay Pits SAC - Great Crested Newts which are designated species are known to travel distances up to 500m, therefore, it is not appropriate to assume there will be no likely significant effects (LSE) on developments 200m away. Manchester Mosses SAC - New transport schemes may lead to a change in movement of traffic and it is not clear if this could impact routes that are closer than 200m to designated sites. Mersey Estuary SPA/Ramsar ? It is possible that impacts to this site could be wider reaching than 200m, depending on the location of tributaries and functionally linked land.

Natural England advise that the air quality assessment section of the AA requires further work for the reasons set out below: The AA should include all pollutant types associated with road traffic, namely NOx, airborne NH3, nitrogen deposition, and acid deposition. The Technical Summary refers to a recent modelling update including the assessment of ammonia and using the NOx Defra Emissions Factor Toolkit which is welcome. However, the HRA doesn?t seem to reflect the results of this as neither are mentioned and results have not been presented. Screening results for all sites within 200m of the affected road network should be presented; The Technical Summary states that 2018 meteorological data has been used, it is not clear why this year was selected and why only one year?s data was used. We generally prefer to see 3-5 years of meteorological data used; The in-combination assessment should include all sites where there will be no LSE alone resulting from Warrington Local Plan. If a LSE alone is established, an in-combination assessment is not necessary until after the AA to assess residual effects. In the case of Manchester Mosses SAC, LSE alone has been determined therefore no in-combination assessment is required; The in-combination assessment should include other sources of pollutants (NOx, Ammonia or N Dep) e.g. industry and intensive agriculture; Paragraph 4.55 states that use of the minimum Critical Load range being used is very precautionary as it is appropriate in low precipitation environments. If this assumption is being used to support a conclusion of no adverse effect, then an evidenced justification is necessary; Within the AA for Holcroft Moss, the spatial scale and duration of the predicted impact and the ecological functionality of the affected area and any site survey information available could be considered (paras 5.53-5.57 in NEA001 Advising competent authorities on the assessment of road traffic emissions under the Habitats Regulations); Within the AA for Rostherne Mere, it is stated that the site is 170m away from the affected roads so nitrogen deposition would have fallen close to background levels at the site boundary and therefore no adverse effect on site integrity is concluded. Natural England suggest that this is quantified through air quality modelling results either in screening or AA as appropriate or through more detailed analysis of the designated sites (e.g. location of sensitive receptors); It is not clear why Mersey Estuary SPA/Ramsar has been included in the AA if there are no affected road networks within 200m of the designated site; 4.55 (d) refers to a small difference in vegetation composition which Natural England advise should be considered in more detail. The conservation objectives for Manchester Mosses SAC are to ?restore? bog habitat, therefore a loss of any existing species, or prevention of species re-establishment could potentially represent an adverse impact.

It is not clear if water quality impacts to Mersey Estuary SPA/Ramsar have been fully addressed as impacts can be far reaching due to tributaries.

Chapter 4.95 states that ?Development proposals that are located within 500m of the Rixton Clay Pits SAC are also required to make a financial contribution towards management of the SAC specifically with regard to management of fly-tipping and associated anti-social activities.? However, this text does not appear in policy OS3 Hollins Green. In addition, it is not clear if all developments have been considered in relation to urbanization effects on Rixton Clay Pits SAC, e.g. transport schemes.