Record of Habitats Regulations Appraisal
October 2016
Record of Habitat Regulations Appraisal for the Proposed South-east Scotland Strategic Development Plan
Legislative requirement to undertake Habitats Regulation Appraisal
Article 6(3) of the EC Habitats Directive requires that “any plan (or project), which is not directly connected with or necessary to the management of a
European 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 European site. The plan-making body shall agree to the plan only after having ascertained
that it will not adversely affect the integrity of the site concerned, unless in exceptional circumstances the provisions of Article 6(4) are met.” This
procedure is applied in Scotland through the Conservation (Natural Habitats, &c.) Regulations 1994 (as amended), and is known as a ‘Habitats Regulations
Appraisal’ (HRA).
In Scotland, European sites which are to be considered in the appraisal process are Special Protection Areas (SPA) classified under the Birds Directive and
Special Areas of Conservation (SAC) designated under the EC Habitats Directive 1992. These form an EU-wide network of protected areas known as Natura
2000 sites. Scottish Government policy affords the same level of protection to proposed SACs and SPAs which have been approved by Scottish Ministers for
formal consultation and the effects on these sites should also be appraised.
Scottish Planning Policy (2014) states that any development plan or proposal likely to have a significant effect on these sites which is not directly connected
with or necessary to their conservation management must be subject to an “appropriate assessment” of the implications for the conservation objectives.
Such plans or proposals may only be approved if the competent authority has ascertained by means of an “appropriate assessment” that there will be no
adverse effect on the integrity of the site.
Key Stages of Appraisal
This HRA was carried out in line with the following guidance:
Habitats Regulations of Plans, Guidance for Plan-making Bodies in Scotland version 3.0 January 2015 (SNH 2015).
The Scottish Natural Heritage guidance suggests an HRA process of potentially 13 stages. This HRA follows these stages to the extent that is required, based
on the findings at each stage.
1
Stage 1: Decide whether the plan is subject to Habitats Regulations Appraisal
In Scotland the appraisal of the effect of the land use on European sites is required by part IVA (regulations 85A of the conservation (Natural Habitats, &c.)
Regulations 1994 as amended.
Stage 2: Identify European sites that should be considered in the appraisal
Table 1 lists the possible sites that could have been included in this appraisal. It includes all sites within or adjacent to the SESplan boundary and sites
outside the boundary where there the possibility of likely significant effects from the plan has been considered due to potential impacts on mobile species
and/or the aquatic and marine environment. A number of sites have been screened out at this stage, largely because their location with respect to areas of
change and their particular qualifying interests mean that a pathway between the interests of the site and an effect from the plan is not conceivable. This
leaves a smaller list of sites that will be subject to further appraisal as follows:
Din Moss – Hoselaw Loch SPA, Fala Flow SPA ,Firth of Tay and Eden Estuary SPA & SAC, Firth of Forth SPA, Forth Islands SPA, Gladhouse Reservoir SPA,
Greenlaw Moor SPA, Imperial Dock Lock Leith SPA, River Tweed SAC, River Teith SAC, Westwater SPA, Outer Firth of Forth & St Andrews Bay Complex draft
SPA, Firth of Tay and Eden Estuary SAC, Isle of May SAC, Moray Firth SAC
Stage 3. Gather information about the European sites
Information on the above European sites, including details of the qualifying interests, conservation objectives and site condition, were obtained from SNH’s
SiteLink Web Portal and through discussions with SNH.
Map-based information on the presence and boundaries of European sites was obtained from SNH’s Natural Spaces Portal: www.snh.org.uk/snhi
Stage 4. Discussions on the method and scope of the appraisal
The list of European sites to be included and the general approach to this appraisal was agreed through discussions with Scottish Natural Heritage.
Stage 5. Screening the plan for likely significant effects on a European site
The screening stage is a series of systematic steps to ensure that those areas of the plan that pose a potential risk of significant effects to European sites are
‘screened in’ and subject to further appraisal.
2
The results of the screening exercise for likely significant effects are shown in Table 3. This indicates whether each policy, proposal or site allocation will
have:
• a likely significant effect (red);
• a minor residual effect (orange) or
• no likely significant effect (green)
on any of the relevant European sites as a result of potential impacts on the sites’ qualifying interests. In making those decisions, consideration has been
given to the potential reasons for screening a policy or proposal in or out suggested by the SNH guidance, summarised in Table 2.
Stage 6. Applying mitigation measures at screening stage to avoid likely significant effects
No likely significant effects were identified. See Table 3.
Conclusion
All elements of this plan have been screened out in terms of requiring an appropriate assessment. This is because the plan comprises:
•
•
•
general policy statements unlikely to have a significant effect on a site
projects proposed by other plans and which would proceed irrespective of whether this plan was approved/adopted
projects/proposals for which effects on any particular European site cannot be identified because not enough is known about the location of the
proposal and its nature and scale
In addition, there were no minor residual effects identified by this appraisal. Consequently, there is no requirement to consider the effects of this plan in
combination with other plans or projects.
3
Table 1. European sites to be considered for further appraisal
Natura Site
Din Moss – Hoselaw Loch SPA
Features Summary (see Site
Link for full list of qualifying
features and conservation
objectives)
Marine and coastal habitats
Grey Seal
Raised Bog
Woodland
Upland Habitat
Vascular Plants
Geese
Dogden Moss SAC
Fala Flow SPA
Raised Bog
Geese
N
Y
Firth of Tay and Eden Estuary
SAC
Firth of Tay and Eden Estuary
SPA
Firth of Forth SPA
Estuary Habitats and Harbour
Seal
Wading Birds, Waterfowl,
Marsh Harrier
Wading Birds, Waterfowl
Y
Forth Islands SPA
Seabirds
Y
Gladhouse Reservoir SPA
Geese
Y
Greenlaw Moor SPA
Geese
Y
Imperial Dock Lock Leith SPA
Common Tern
Y
Berwickshire & North
Northumberland Coast SAC
Blawhorn Moss SAC
Borders Woods SAC
Craigengar SAC
Inclusion Reason:
in HRA? NCP - No conceivable pathway between effects of the plan and the site
MS - Possible impacts on parts of the feeding area of mobile qualifying
interests
N
NCP
N
N
N
NCP
NCP
NCP
Y
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
NCP
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
MS - Developments affecting the coast could theoretically impact on
Harbour seals depending on nature and scale .
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
Within an area recognised as being important for strategic growth.
Y
Y
4
Natura Site
Isle of May SAC
Langholm – Newcastleton Hills
SPA
Moorfoot Hills SAC
Moray Firth SAC
Outer Firth of Forth & St
Andrews Bay Complex draft
SPA
Peeswit Moss SAC
River Teith SAC
River Tweed SAC
St Abb’s Head to Fast Castle SPA
St Abb’s Head to Fast Castle SAC
Threepwood Moss SAC
Westwater SPA
Whitlaw & Branxholme SAC
Features Summary (see Site
Link for full list of qualifying
features and conservation
objectives)
Grey Seal
Reef Habitat
Hen Harrier
Inclusion Reason:
in HRA? NCP - No conceivable pathway between effects of the plan and the site
MS - Possible impacts on parts of the feeding area of mobile qualifying
interests
Y
MS - Developments affecting the coast could theoretically impact on
Harbour Seals depending on nature and scale.
N
NCP
Upland Habitat
Bottlenose Dolphin
Sandbank
Seabirds
N
Y
Raised Bog
Lamprey & Salmon
N
Y
Otter, Lamprey, Salmon,
Freshwater Habitats
Sea Cliffs
Seabirds
Raised Bog
Waterfowl
Y
Fens, Mires, Non-vascular
plants
Y
N
N
N
Y
N
NCP
MS - Developments affecting the coast could theoretically impact on
Bottlenose Dolphins depending on nature and scale.
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
NCP
MS - Outside SESplan area. Qualifying interests migrate via River Forth
Developments affecting the coast could theoretically impact on Lamprey
and Salmon depending on nature and scale.
Within area covered by plan.
NCP
NCP
NCP
MS - Developments could theoretically impact on feeding areas depending
on nature, scale and location.
NCP
5
Table 2. Potential reasons for screening out policies and proposals as having no Likely Significant Effect
Reason for screening out
A
B
C
D
E
F
G
Description
Policies for which effects on any particular European site cannot be identified, because it is too general or vague
and it is not known where, when or how the proposal may be implemented or where effects may occur, or
which sites if any may be effected
Projects referred to in but not proposed by the plan
Projects and other proposals which make provision for change but have already been granted planning
permission
Projects or proposals intended to protect the natural environment, including biodiversity, or to conserve or
enhance the natural, built or historic environment, where enhancement measures will not be likely to have any
negative effect on a European site
Policies which will not themselves lead to development or change such as design or other qualitative criteria
Policies or proposals which make provision for change but which could have no conceivable effect on a
European site because:
• there is no link or pathway with the qualifying interest or
• any effect would be positive effect or
• it would not otherwise undermine the conservation objectives of
the site
Policies or proposals which make provision for change but could have no significant effect on a European site
because any potential effects would be insignificant and therefore ‘minor residual’ in nature or so restricted or
remote from the site that they would not undermine the conservation objectives for the site
6
Table 3. Screening for likely significant effects on a European site
Plan section
Screening
Likely significant effect.
Minor residual effect.
No likely significant effect.
Reason(s) (see
Table 2)
No likely significant effect.
A
Strategic Growth 2018-2030: need for growth largely met by land already identified in
existing and proposed plans
Rural Growth Areas: These identify those settlements in the Scottish Borders with
potential for long term growth
Growth Beyond 2030 – Long Term growth corridors shown on map as indicative
arrows
Placemaking in the City Region: “SESplan member authorities will ensure that communities
No likely significant effect.
A
No likely significant effect.
A, B
No likely significant effect.
A
No likely significant effect.
A, B, D
Strategic Cross Boundary Transport Improvements
See detailed policy approach under ‘ Better
Connected Place’ below.
No likely significant effect.
See ‘ Place for Communities’ below.
B, D
See below
The Spatial Strategy
Most growth in and around Edinburgh and in Long Term Growth Corridors.
are involved in the design and shaping of development at an early stage, using tools such as
the Place Standard to engage local people in conversations about what places should be like.
Development should take account of the Placemaking Principles set out in Table 3.1. Local
Development Plans will include development frameworks, masterplans and design briefs that
are aligned with relevant community plans and have been developed jointly with local people.
Local Development Plans will be guided by the Placemaking Principles detailed in Table 3.1.
and ensure that all international, national and locally designated areas are afforded the
appropriate level of protection.”
Green Belts & Related Countryside Designations
Cross Boundary Green Networks: Assessed below under ‘ Place for Communities’
7
Placemaking Principles Table 3.1
Key Areas of Change. These parts of the plan and associated Figures include:
•
•
•
No likely significant effect.
See below.
A, D, E
See below
No likely significant effect Table 4.1
‘Significant Business Clusters’ describe a range
of opportunities and locations. Most are
related to existing plans and projects
proposed elsewhere. None of the clusters are
described in terms that would realistically
allow effects on any particular European site
to be identified because there is no detail on
how the proposal may be implemented and
the location of the clusters is indicative.
No likely significant effect.
A
No likely significant effect.
A
Summaries of transport projects referred to on maps but not proposed by the
plan.
Significant Business Clusters proposed by the plan, but explained in more
detail in later section
Green Network Priority Areas proposed by the plan, but explained in more
detail in later section
These are assessed below in turn against the section of the plan where these are set
out in more detail
A Place to do Business
Significant Business Clusters. This section includes a list of sites against which the
following approach applies: SESplan member authorities will promote investment in the
locations identified in Table 4.1. Local Development Plans will safeguard their future expansion
by identifying and safeguarding sufficient land and supporting infrastructure including public
transport and walking and cycling provision. Local Development Plans will adopt a flexible
approach to allow for new long term employment opportunities. Local Development Plans will
also consider whether to identify local based business clusters.
Rural Economy: SESplan member authorities will therefore support the continued operation,
diversification and expansion of rural businesses.
Employment Land Supply: Local Development Plans will identify and safeguard a sufficient
supply of employment land taking account of market demands and existing infrastructure. This
land should be able to deliver sites which are serviced or serviceable over the plan period.
Local Development Plans will identify and safeguard large scale employment sites where
necessary in line with the spatial strategy and, where appropriate, within the significant
business clusters. Local Development Plans will support diversification and re-categorisation of
existing employment sites where this facilitates wider business opportunities, mixed-uses or an
increased density of development, whilst ensuring an overall sufficient supply of employment
land is maintained.
A
8
Responsible Resource Extraction:
SESplan member authorities will establish a Minerals Working Group. This group will review
the aggregate resources of the city region (based on Scottish Government minerals survey data
and relevant locally sourced information) to ensure there is a sufficient aggregates landbank of
permitted reserves for construction aggregates of at least 10 years. Local Development Plans
will use the relevant monitoring information to identify and safeguard sufficient construction
aggregates to form a land bank of reserves for a minimum of 10 years. These should be in
locations where there are deposits of sufficient scale and quantity for commercial extraction
and which could be worked without unacceptable environmental or amenity impacts in
accordance with Scottish Planning Policy. Local Development Plans will identify coal, oil and
gas reserves to support a diverse energy mix, giving sufficient weight to the avoidance of long
term environmental impacts and greenhouse gas emissions from their use. Local Development
Plans will identify former mineral sites and the potential means of restoration and
regeneration in accordance with the vision and spatial strategy of the Strategic Development
Plan.
A Low Carbon Economy: Local Development Plans will identify, as appropriate, opportunities
to co-locate sources of high heat demand (e.g. housing) with sources of heat supply (e.g.
biomass power plants) and to locate new development where passive solar heating and solar
power generation can be maximised. Local Development Plans will apply these 2km separation
zones up to a maximum of 2km from an identified settlement envelope or edge. SESplan
member authorities will establish a Cross-boundary Windfarm Working Group to explore the
potential for a plan-led approach to identifying strategic capacity for wind farms and
repowering opportunities (i.e. replace old turbines with new ones) in areas where there are
likely to be cross-boundary effects. Relevant member authorities will pursue a collaborative
plan-led approach to re-powering in order to minimise the impact on key cross-boundary
assets. Local Development Plans will also set out the full range of additional considerations
they will apply to wind farm proposals based on the particular characteristics of each area. In
doing so, they should liaise closely with neighbouring authorities to identify and establish a
consistent policy approach to key strategic cross-boundary assets. These assets will include,
but will not be limited to, the Pentland Hills Regional Park, the Lomond Hills Regional Park, the
Lammermuir Hills and the Firth of Forth.
Onshore Wind Spatial Framework
Zero Waste: Local Development Plans will support proposals which encourage recycling and
recovery of waste where these are in accordance with the Zero Waste Plan and take account of
environmental, transport, economic and amenity factors. Opportunities for co-location with
other uses which can make use of any recovered heat will be supported.
No likely significant effect.
A
No likely significant effect.
A
No likely significant effect.
No likely significant effect.
A
A
9
A Place for Communities
Increasing Housing Delivery: Housing Targets Figure 5.1, Tables 5.1, 5.2
Increasing Housing Delivery: Local Development Plans will set out the proportion of
affordable housing that will be sought on market sites, taking into account relevant local
factors. Affordable housing will also be developed by housing associations and councils,
making best use of the public estate. SESplan member authorities will ensure that Local
Housing Strategies and Local Development Plans enable the types of homes that will address
the needs of a growing, ageing population and the growth in the number of smaller
households. SESplan member authorities will work together through the South East Scotland
Housing Forum to update housing need information for these communities.
Increasing Housing Delivery 2018-2030 Period: Local Development Plans will ensure that
there is a sufficient supply of housing land to meet the Housing Land Requirements over the 10
year period from the expected date of plan adoption. City of Edinburgh Local Development
Plan will give priority to brownfield sites in the urban area within the Green Belt's inner
boundary and ensure all allocations are consistent with this Strategic Development Plan.
SESplan member authorities will also consider deallocating sites carried over from multiple
plan cycles where action taken has proved ineffective in making them deliverable over a
number of plan periods. SESplan member authorities will also consider deallocating sites where
they are not required to meet plan objectives or consider changing such sites to long term
growth opportunities.
SESplan member authorities will monitor the availability of effective housing land in relation to
the SESplan Housing Market Area and by Local Authority Area. This will be monitored and
updated annually through the housing land audit. They will maintain a five year effective
housing land supply at all times measured against the five year housing supply targets. These
are calculated by multiplying the annual average housing supply targets (Table 5.1) by five.
Where a SESplan member authority determines there is a shortfall in the five year effective
land supply, they will consider permitting proposals for additional housing supply, subject to
the following criteria:
Development must be consistent with the spatial strategy of the development plan;
The scale of the proposal and the proportion of affordable and market housing in the
development must reflect the type (market or affordable) and scale of the shortfall identified;
Development must demonstrate that a significant proportion of the total number of homes
No likely significant effect.
No likely significant effect.
A
A
No likely significant effect Para. 5.8 of SESplan A, B
identifies that there is sufficient housing land
supply to meet the Housing Supply
Requirements for the 2018-2030 period in
East Lothian, Fife, Midlothian, Scottish Borders
and West Lothian. This is due to the existing
land supply set out in LDPs based on housing
requirements in the previous SDP. In other
words, SESplan 2 is not proposing any
additional land allocations and therefore this
aspect of the plan cannot have any LSE. It
identifies that Edinburgh LDP will have to
identify additional sites because there is a
shortfall. However, SESplan 2 does not
provide any specific indication of where this
additional land might be, beyond stating that
(in Para 5.9) “City of Edinburgh LDP will give
priority to brownfield sites in the urban area
within the Green belt’s inner boundary ..”. It is
therefore not possible to know where, or how
CEC will meet the shortfall in housing land
supply and therefore it is not possible to
identify where effects may occur, or which
sites if any may be effected .
10
proposed will be completed in the next five years
The scale, location and design of development must take account of the Placemaking
Principles (Table 3.1);
Development must align with any SESplan member authority guidance on green networks;
Development must align with green belt objectives or the objectives of other designations
fulfilling a similar function (Para. 3.6); and
Development must demonstrate that any infrastructure required is already committed and
funded, or will be delivered by the developer
Thriving Town Centres: Local Development Plans will support all uses in town centres that
generate significant footfall such as retail and commercial leisure, offices, community, cultural
facilities and opportunities for town centre living.
No likely significant effect.
A
No likely significant effect.
A
Local Development Plans will also encourage the development of an evening/ night-time
economy in town centres.
Local Development Plans will identify, taking account the hierarchy of centres in Table 5.4, a
network of centres including town centres, local centres and commercial centres and explain
how they can complement each other. Local Development Plans will apply a Town Centre First
policy. This means that when planning for any use that generates significant footfall, locations
should be considered in the following order of preference:
Town Centres (including the City Centre and
Strategic Centres)
Edge of town centre
Other commercial centres identified in the
development plan; and
• Out of centre locations that are easily accessible by a choice of transport modes or
will be made so by investment delivered by relevant development
Enhanced Green Network: Green Network Priority Areas Member authorities will prepare
frameworks for these areas that will:
• Identify and safeguard those elements of the green network that provide, or have the
potential to provide, the greatest benefits for people and nature
•
•
•
•
•
11
•
•
Identify strategic enhancements to green networks that will add value to existing
settlements, developments for which land has already been allocated and any new
allocations in subsequent Local Development Plans
Provide an additional context for planning decisions SESplan member authorities will
prepare Strategic Frameworks for the two Cross-Boundary Green Network Priority
Areas and adopt these as Supplementary Guidance to the Strategic Development Plan
within one year of plan approval. SESplan member authorities will prepare nonstatutory Frameworks for the other Green Network Priority Areas and incorporate the
key elements of these frameworks into the relevant Local Development Plan at the
first opportunity.
A Better Connected Place
Supporting Non-car Travel: Development should take account of the needs of people before
the movement of cars. Therefore in addition to the Placemaking Principles set out in Table 3.1,
new development should be designed in accordance with Designing Streets to ensure that noncar travel is an easy and convenient choice.
Local Development Plans will ensure that large scale housing development is located where
there is good access to town centres and employment locations by walking and cycling routes
and by public transport. Where new infrastructure is needed to enable this access, Local
Development Plans will ensure that this is delivered ahead of, or as part of, new development.
Developments should be designed so that the density, use and layout helps reduce the need to
travel by car. Developments should include clear and direct links to public transport nodes and
good access to walking and cycling networks. Development close to public transport nodes and
interchanges should be at higher development
densities.
Walking and Cycling
A range of strategic and functional routes are proposed
No likely significant effect.
A
No likely significant effect. Some of the
proposed new routes may be adjacent to or
go through Natura sites. However, this plan
only identifies these routes in a very indicative
way. The exact routes have not yet been
determined. Consequently we have no
information about the specification of the
works needed, whether any new river crossing
points are needed, when the work will be
carried out or the nature or scale of the work.
It is not therefore possible to ascertain if,
A
12
Strategic Transport Improvements 2018-2030
Edinburgh - Glasgow Rail Improvements
East Coast Mainline: Ongoing and Planned
Improvements
Edinburgh-Glasgow via Shotts Rail Line
Electrification
East Linton and Reston Rail Stations on new Edinburgh-Berwick service
Edinburgh Waverley Capacity Improvements
Levenmouth Rail Link
A801 Improvements
Tram extensions: York Place to Newhaven
City Centre to Edinburgh BioQuarter, Newcraighall
and Queen Margaret University
Newhaven to Granton
Roseburn to Granton
Ingliston to Newbridge
A1 Junction Improvements
A92 Junction Improvements
Dunfermline Northern Relief Road & Western
Distributor Road
A701 Relief Road and A702 Link
Winchburgh Rail Station
Winchburgh M9 Junction
M9 J3 Upgrade
Potential Strategic Cross-Boundary Projects
A720 Improvements, including Sheriffhall Junction
- Junction Upgrades, Intelligent Transport Systems
and Non-Car alternatives
Improvements associated with trunk road
when or where effects may occur.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in
SEStrans Regional Transport Strategy 20152025.
No likely significant effect. Proposed in SDP1.
B
B
No likely significant effect. Proposed in SDP1.
B
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
B
B
B
B
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
B
B
B
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
B
B
B
B
No likely significant effect. Proposed in SDP1.
B
No likely significant effect.
A
B
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approaches to Edinburgh including Junction
Upgrades and Non-Car Alternatives such as Park
and Ride Schemes
Edinburgh Orbital Bus and Associated Park and Ride Sites
Edinburgh Cross Rail Services
Strategic Longer Term Projects
High Speed Rail to England
A1 Dualling between Dunbar and Berwick Upon Tweed
Borders Rail Extension to Hawick and Carlisle
Dunfermline-Alloa Passenger Rail Link
East Coast Main Line: formation of four line section of track between Blindwells and
Drem, including new station and over bridge for Blindwells
New trunk road interchange on the A1(T) at Adniston
National Transport Developments
Funding Transport Infrastructure
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in
SEStrans Regional Transport Strategy 20152025.
B
B
No likely significant effect. Proposed in NPF3
and no further detail set out in SDP2.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in
Scottish Borders Proposed Plan.
No likely significant effect. Proposed in SDP1.
No likely significant effect. Proposed in SDP1.
B
No likely significant effect. Exact location of
junction not known, but if assumed to be
somewhere with 1km of West Adniston, there
is no link with any of the qualifying interests of
the relevant sites.
No likely significant effect. Proposed in NPF3
and no further detail set out in SDP2.
No likely significant effect.
A,F
B
B
B
B
B
A
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