The proposed allocations at Langport and Martock would potentially lead to the loss of the finite amount of available functionally linked land to Somerset Levels and Moors SPA and Ramsar site. The HRA states that the functionally linked habitats in question (i.e. agricultural land) are common, widespread and easily recreated, or managed in a more favourable manner and the HRA proposes that the assessment of whether the site and neighbouring land constitute a significant area of supporting habitat should be postponed to the planning application stage. However, in line with the provided quote from Advocate-General Kokott ‘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.’ We maintain that as the sites are known and an (in combination) assessment of the current function of the land as supportive habitat for the SPA can now be made, that this level of assessment is required at the plan level. We therefore strongly advise that this assessment is undertaken to inform the appropriate Assessment at the Regulation 19 stage, together with an assessment of whether and how suitable mitigation could be delivered in case the development would lead to the loss of functionally linked land. This would satisfy the requirements of the Habitats Regulations and demonstrate the deliverability of the allocations.