Habitat Regulations Assessment Report€¦ · Chapter 11 South West London Waterbodies SPA& Ramsar Site 120 Chapter 12 Thames Basin Heaths SPA 135 Chapter 13 Thursley, Ash, Pirbright

Surrey Waste Local Plan

Habitat Regulations Assessment Report Report on the assessment of the new Surrey Waste Local Plan in respect of the requirements of the Conservation of Habitats & Species Regulations 2017 (as amended)

Final

January 2020

Statement of Purpose

This Habitat Regulations Assessment report has been prepared by Surrey County Council’s

Principal Environmental Assessment Officer, who is part of the Natural Environment &

Assessment Team within the County Council’s Planning service. Planning is part of the

Highways, Tranport & Environment Directorate.

The Minerals & Waste Policy Team has commissioned the report, and the Habitat

Regulations Assessment of which it forms the final output, as part of the preparation of the

new Surrey Waste Local Plan.

The report evaluates the extent to which the new Waste Local Plan has the potential to give

rise to ‘likely significant effects’ on Special Protection Areas (SPAs), Special Areas of

Conservation (SACs) (and Ramsar Sites) in Surrey and the surrounding area. The report is

prepared in response to the requirements set out in the Conservation of Habitats & Species

Regulations 2017 (Statutory Instrument 2017 No.1012) (as amended by The Conservation of

Habitats & Species & Planning (Various Amendments) (England & Wales) Regulations 2018

(Statutory Instrument 2018 No.1307)).

The final HRA report has been amended to incorporate and take account of relevant

information included within the Statement of Common Ground agreed between Surrey

County Council and Natural England on 8 August 2019.

Statement of Limitations

This report has been prepared for the sole use of Surrey County Council’s Minerals & Waste

Policy Team (“Client”). No other warranty, expressed or implied, is made as to the

professional advice included in this report or any other services provided by the County

Council’s Natural Environment & Assessment Team.

The preparation of this report was undertaken during January 2020, and is based on the

information available to the Natural Environment & Assessment Team during that period of

time. The scope of this report is accordingly factually limited by these circumstances.

Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final

Contents

Page

Chapter 1 Introduction & Approach 1

Part A Assessment for European Sites >10km from development

locations identified in the Surrey WLP

Chapter 2 The Mens SAC 13

Chapter 3 Woolmer Forest SAC 25

Part B Assessment for European Sites <10km from development

locations identified in the Surrey WLP

Chapter 4 Ashdown Forest SAC 43

Chapter 5 Ashdown Forest SPA 53

Chapter 6 East Hampshire Hangers SAC 59

Chapter 7 Ebernoe Common SAC 72

Chapter 8 Mole Gap to Reigate Escarpment SAC 86

Chapter 9 Richmond Park SAC 102

Chapter 10 Shortheath Common SAC 108

Chapter 11 South West London Waterbodies SPA& Ramsar Site 120

Chapter 12 Thames Basin Heaths SPA 135

Chapter 13 Thursley, Ash, Pirbright & Chobham SAC 161

Chapter 14 Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA (including Thursley & Ockley Bog Ramsar Site)

183

Chapter 15 Wealden Heaths Phase 2 SPA 202

Chapter 16 Wimbledon Common SAC 213

Chapter 17 Windsor Forest & Great Park SAC 224

Chapter 18 Summary of HRA Conclusions 237

The following are provided as separate documents:

Appendix A Preliminary Screening of SPAs & SACs against Surrey WLP Allocated Sites & ILAS

Appendix B Assessment of Air Quality Impacts & Summary of Key Recommendations for the Proposed Site Allocations & the Identified ILAS located within 10 kilometres of one or more SPAs or SACs

Appendix C Thermal Treatment Facility Proxies for use in the Air Quality Modelling to inform the HRA Process; Wind Roses for Airports & Airfields relevant to wind conditions in the county of Surrey


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Abbreviations

AA Appropriate Assessment PC Process Contribution

APIS Air Pollution Information System PEC Predicted environmental concentration

BC Borough Council PRN Primary Route Network

BP Business park RBBC Reigate & Banstead Borough Council

CC County Council RBC Runnymede Borough Council

CD&E Construction, demolition & excavation (waste) RBMP River Basin Management Plan

C&I Commercial & Industrial (waste) SAC Special Area of Conservation

COSA Conservation Objectives Supplementary Advice SBC Spelthorne Borough Council

CPA County Planning Authority SHBC Surrey Heath Borough Council

CRC Community recycling centre SIP Site Improvement Plan

DC District Council SPA Special Protection Area

DMRB Design Manual for Roads & Bridges SPD Supplementary Planning Document

DPD Development Plan Document SRN Strategic Road Network

EBC Elmbridge Borough Council SSSI Site of Special Scientific Interest

EEBC Epsom & Ewell Borough Council STW Sewage treatment works

EfW Energy from waste SWLP Surrey Waste Local Plan

EU European Union TCPA Town & Country Planning Act

GBC Guildford Borough Council TDC Tandridge District Council

HGV Heavy Goods Vehicle TE Trading estate

HRA Habitat Regulations Assessment WaBC Waverley Borough Council

ILAS Industrial Land Areas of Search WDA Waste Disposal Authority

IE Industrial estate WLP Waste Local Plan

LA Local Authority WoBC Woking Borough Council

MVDC Mole Valley District Council WPA Waste Planning Authority

MRF Materials recycling / recovery facility WRA Waste Regulation Authority

MSW Municipal Solid Waste WTS Waste Transfer Station

NPA National Park Authority


Schedule of Allocated Sites & Industrial Land Areas of Search (ILAS)

Strategic Sites (Surrey Waste Local Plan, Policy 11a)

Site 1 Oakleaf Farm, Horton Road, Stanwell Moor SBC

Site 2 Former Weylands Treatment Works, Lyon Road, Walton on Thames EBC

Site 3 Land north east of Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford GBC

Site 4 Land west of Leatherhead Sewage Treatment Works, Randalls Road, Leatherhead MVDC

Site 5 Land west of Lambs Business Park, Terracotta Road, Tilburstow Hill Road, South Godstone TDC

Site for Household Waste Materials Recycling Facility (Surrey Waste Local Plan, Policy 11b)

Site 6 Land at Trumps Farm, Kitsmead Lane, Longcross RBC

Industrial Land Areas of Search (Surrey Waste Local Plan, Policy 10)

ILAS01 Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park, Weybridge; & Byfleet Industrial Estate, Byfleet Road / Oyster Lane, Woking

EBC

ILAS02 Hersham Trading Estate, Lyon Road, Walton on Thames EBC

ILAS03 Molesey Industrial Estate, Central Avenue, West Molesey EBC

ILAS04 Longmead Industrial Estate, Longmead Road, Epsom EEBC

ILAS05 Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford GBC

ILAS06 Woodbridge Meadows Industrial Estate, Guildford GBC

ILAS07 Land north & south of Lysons Avenue, Ash Vale GBC

ILAS08 Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old Portsmouth Road, Peasmarsh GBC

ILAS09 Land at Burnt Common Warehouse, London Road, Send GBC

ILAS10 Land near Dorking West Station, Curtis Road / Station Road, Dorking MVDC

ILAS11 Holmethorpe Industrial Estate, Redhill RBBC

ILAS12 Perrywood Business Park, Honeycrock Lane, Salfords RBBC

ILAS13 Salfords Industrial Estate, Brighton Road / Bonehurst Road, Salfords RBBC

ILAS14 Thorpe Industrial Estate, Ten Acre Lane, Egham RBC

ILAS15 Byfleet Road, Employment Allocation, New Haw, Byfleet RBC

ILAS16 Windmill Road Industrial Area, Sunbury-on-Thames SBC

ILAS17 York Town Industrial Estate, Doman Road / Stanhope Road, Camberley SHBC

ILAS18 Hobbs Industrial Estate, Felbridge TDC

ILAS19 Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh WaBC

ILAS20 Coxbridge Business Park, Alton Road, Farnham WaBC

ILAS21 Farnham Trading Estate (incl. land north of Water Lane), Water Lane, Farnham WaBC

ILAS22 Monument Way East Industrial Estate, Woking WoBC


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Chapter 1 Introduction & Approach

1-A Introduction & legal context

1.1 The requirement for plans and programmes to be assessed in respect of their capacity to

give rise to adverse impacts on the features of qualifying interest (e.g. particular habitats or

species) of sites that have been designated for protection under the European Union (EU)

Habitats Directive1 or Wild Birds Directive2, derives from Articles 6(3) and 6(4) of the

Habitats Directive3.

“3. Any plan or project not directly connected with or necessary to the management of the site

but likely to have a significant effect thereon, either individually or in combination with

other plans or projects, shall be subject to appropriate assessment of its implications for the

site in view of the site's conservation objectives. In the light of the conclusions of the

assessment of the implications for the site and subject to the provisions of paragraph 4, the

competent national authorities shall agree to the plan or project only after having

ascertained that it will not adversely affect the integrity of the site concerned and, if

appropriate, after having obtained the opinion of the general public.

4. If, in spite of a negative assessment of the implications for the site and in the absence of

alternative solutions, a plan or project must nevertheless be carried out for imperative

reasons of overriding public interest, including those of a social or economic nature, the

Member State shall take all compensatory measures necessary to ensure that the overall

coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory

measures adopted.

Where the site concerned hosts a priority natural habitat type and/or a priority species, the

only considerations which may be raised are those relating to human health or public safety,

to beneficial consequences of primary importance for the environment or, further to an

opinion from the Commission, to other imperative reasons of overriding public interest.”

1.2 The requirement for ‘appropriate assessment’ of plans and programmes prior to their

adoption or implementation has been transposed into UK domestic legislation via

Regulation 63 of the Conservation of Habitats & Species Regulations 2017 (Statutory

Instrument 2017 No.1012) (as amended by Statutory Instrument 2018 No.1307).

1 Commission of the European Communities, 1992. Directive on the Conservation of Natural Habitats & Wild Flora & Fauna (92/43/EEC). Official Journal of the European Communities: Brussels. 2 Commission of the European Communities, 2009. Directive on the Conservation of Wild Birds (2009/147/EC). Official Journal of the European Communities: Brussels. Directive 2009/147/EC is the codified version of the original Directive 79/4069/EEC adopted by the EU in 1979. 3 The text of Article 6(3) of the Habitats Directive states that, “Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives. In the light of the conclusions of the assessment of the implications for the site and subject to the provisions of paragraph 4, the competent national authorities shall agree to the plan or project only after having ascertained that it will not adversely affect the integrity of the site concerned and, if appropriate, after having obtained the opinion of the general public.”


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1.3 As a matter of policy in the UK, the same level of protection afforded to sites designated

under either the EU Wild Birds Directive (Special Protection Areas or SPAs) or the EU

Habitats Directive (Special Areas of Conservation or SACs) is extended to sites (Ramsar

Sites) designated under the Ramsar Convention on Wetlands of International Importance4.

There are two Ramsar Sites located wholly or partly within the county of Surrey, the

Thursley & Ockley Bogs Ramsar Site and the South West London Waterbodies Ramsar Site.

1-B Purpose of the Habitats Regulations Assessment

1.4 Article 6(3) of the Habitats Directive specifies three key questions (see below) that need to

be asked of the proposed plan prior to any decision being made as to whether or not it

should proceed. The relevant legislation does not specify any particular procedure to be

followed when assessing the implications of a plan for the integrity of sites of European

nature conservation importance. Methodological guidance5 on appropriate assessment

produced by the EU identifies four key stages of the process: screening; appropriate

assessment; assessment of alternative solutions; and, assessment of compensation and

imperative reasons of over-riding public interest.

1.4.1 Is the plan directly connected with or necessary to the management of the

SPA or SAC?

If the answer to this question is ‘yes’ then the plan may proceed with no

further assessment. If the answer to this question is ‘no’ then some level of

further assessment is required.

For the Surrey Waste Local Plan (WLP), the answer to the question is ‘no’, as its

purpose is to provide for future waste management capacity, and it therefore

has no direct role in the management of European sites.

1.4.2 Is the plan likely to have a significant effect on the SPA or SAC, in view of the

site's conservation objectives, either alone or in combination with other

plans or projects?

If the answer to this question is ‘no’ then the plan may proceed with no further

assessment. If the answer to this question is ‘yes’ or ‘possibly’ then further

assessment is required in order to determine whether the likely significant

effects would have an adverse impact on the integrity of the SPA or SAC

concerned.

For the Surrey WLP, the answer to the question is ‘yes’, as its implementation

will result in the development of new waste management facilities at locations

distributed across the county. The development that would proceed could

include a range of operations (e.g. the disposal of waste by means of direct or

4 UNESCO, 1971. Convention on Wetlands of International Importance especially as Waterfowl Habitat. Agreed at Ramsar, Iran, on 2 February 1971. 5 European Commission - Environment DG, November 2001. Assessment of plans & projects significantly affecting Natura 2000 sites: Methodological guidance on the provisions of Article 6(3) & (4) of the Habitats Directive 92/43/EEC. Prepared for the Commission by the Impacts Assessment Unit, School of Planning, Oxford Brookes University.


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indirect incineration, the composting of green waste, etc.) that could give rise

to direct or indirect impacts on the integrity of European designated sites

1.4.3 Can it be ascertained that the plan will not adversely affect the integrity of

the SPA or SAC concerned?

If the answer to this question is ‘yes’ then the plan may proceed. If the answer

to this question is ‘no’ then the plan may not proceed, unless in line with

Article 6(4) imperative reasons of overriding public importance can be

demonstrated and appropriate compensatory measures be put in place to

protect the overall integrity and coherence of the SPA or SAC concerned.

1.5 This document provides a record of the appropriate assessment for the Surrey WLP, and an

answer to the third question listed above (paragraph 1.4.3).

1-C Defining the scope of the Habitats Regulations Assessment

1.6 The geographical extent of the Surrey WLP is defined by the borders of the county of

Surrey. However, given that the Plan involves waste related development, which could

include the construction and operation of facilities that make use of incineration,

gasification or pyrolysis as methods of waste disposal, it is necessary to initially consider all

SPAs, SACs and Ramsar Sites that are situated wholly or partly within 10 kilometres of the

Surrey county boundary (see Table 1-B and Figures A-1 and A-2 in Appendix A to this

report).

1.7 The distance of 10 kilometres reflects the criteria used by the Environment Agency when

considering the impacts of industrial installations that will give rise to emissions of

pollutants as part of the permitting process (source: https://www.gov.uk/guidance/air-

emissions-risk-assessment-for-your-environmental-permit ).

1.8 Policy 11 of the Surrey WLP allocates six sites (see Table 1-A) as potentially suitable

locations for future waste related development. The emerging Plan does not indicate the

types or scales of waste related development that might be appropriately accommodated

on five of the proposed site allocations (Policy 11a), but has identified future capacity gaps

with respect to the treatment of waste by means of energy recovery, by means of

composting, by means of recycling or recovery, by means of anaerobic digestion, and with

respect to the bulking and sorting of waste materials. The sixth allocated site (Policy 11b) is

specifically identified as a suitable location for a dry mixed recyclables facility with capacity

to deal with between 50,000 tonnes per annum (tpa) and 120,000 tpa of household waste.

Five of the six allocated sites were allocated for waste related development under policy

WD2 or Policy WD5 of the adopted Surrey Waste Plan (2008).

https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit

https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit


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Table 1-A: Relationship of Surrey WLP site allocations to SPAs & SACs

Surrey WLP Site Allocations SPAs & SACs located within 10km

Sites allocated under Policy 11a (Strategic Sites)

Site 1: Oakleaf Farm, Horton Road, Stanwell Moor

[Spelthorne BC area] [NGR 50442 174356] [Site Area: 9.4 ha]

South West London Waterbodies SPA – closest component of the SPA is the Staines Moor SSSI, some 0.02 kilometres to the south – all seven components of the SPA are located within 10 kilometres of the site.

Windsor Forest & Great Park SAC – the SAC commences some 5.96 kilometres to the west of the site.

Site 2: Land at the former Weylands Treatment Works, Molesey Road, Walton on Thames

[Elmbridge BC area] [NGR 512563 165682] [Site Area: 5.7 ha]

South West London Waterbodies SPA – closest component of the SPA is the Knight & Bessborough Reservoirs SSSI, some 1.97 kilometres to the north east – four of the seven components of the SPA are located within 10 kilometres of the site.

Thames Basin Heaths SPA – closest component of the SPA is Ockham & Wisley Commons SSSI, located some 7.08 kilometres to the south west – only one of the thirteen components of the SPA is located within 10 kilometres of the site.

Richmond Park SAC – the SAC commences some 7.81 kilometres to the north east of the site.

Wimbledon Common SAC – the SAC commences some 9.97 kilometres to the north east of the site.

Site 3: Land to the north east of Slyfield Industrial Estate, Moorfield Road, Guildford

[Guildford BC area] [NGR 500624 152397] [11.0 ha]

Thames Basin Heaths SPA – closest component of the SPA is Whitmoor Common SSSI, some 1.19 kilometres to the north west – five of the thirteen components of the SPA are located within 10 kilometres of the site.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Ash to Brookwood Heaths SSSI, some 4.69 kilometres to the north west – two of the four components of the SAC are located within 10 kilometres of the site.

Site 4: Land to the west of Leatherhead STW, Randalls Road, Leatherhead

[Mole Valley DC area] [NGR 514661 157718] [Site Area: 4.6 ha]

Mole Gap to Reigate Escarpment SAC – the SAC commences some 2.96 kilometres to the south of the site.

Thames Basin Heaths SPA – closest component of the SPA is Ockham & Wisley Commons SSSI, some 5.50 kilometres to the north west – only one of the thirteen components of the SPA is located within 10 kilometres of the site.

Site 5: Land to the west of Lambs Business Park, Terra Cotta Road, South Godstone

[Tandridge DC area] [NGR 534949 148437] [3.0 ha]

Mole Gap to Reigate Escarpment SAC – the SAC commences some 8.36 kilometres to the north west of the site.

Site allocated under Policy 11b (Household Waste Materials Recycling Facility)

Site 6: Land to the south of the M3 motorway & north of the former Trumps Farm Landfill, Kitsmead Lane, Longcross, Chertsey

[Runnymede BC area] [NGR 499303 166281] [Site Area: 6.6 ha]

South West London Waterbodies SPA – closest component of the SPA is the Thorpe Park No.1 Gravel Pit SSSI, some 3.06 kilometres to the north east – five of the seven components of the SPA are located within 10 kilometres of the site.

Thames Basin Heaths SPA – closest component of the SPA is Chobham Common SSSI, some 1.41 kilometres to the south west – five of the thirteen components of the SPA are located within 10 kilometres of the site.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Chobham Common SSSI, some 1.41 kilometres to the south west – two of the four components of the SAC are located within 10 kilometres of the site.

Windsor Forest & Great Park – the SAC commences some 3.01 kilometres to the north west of the site.


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1.9 Policy 10 of the Surrey WLP identifies twenty-two industrial land areas of search (ILAS) (see

Table 1-B) as potentially suitable locations for future waste related development. The

emerging Plan does not indicate the types or scales of waste related development that

might be appropriately accommodated on the identified ILAS but has identified future

capacity gaps with respect to the treatment of waste by means of energy recovery, by

means of composting, by means of recycling or recovery, by means of anaerobic digestion,

and with respect to the bulking and sorting of waste materials.

Table 1-B: Relationship of ILAS identified under Policy 10 of the Surrey WLP to SPAs & SACs

ILAS identified by the Surrey WLP

SPAs & SACs located within 10km

ILAS01: Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park, Weybridge; & Byfleet

Industrial Estate, Byfleet Road/ Oyster Road, Woking

South West London Waterbodies SPA – closest component of the SPA is the Thorpe Park No.1 Gravel Pit SSSI, some 5.8 kilometres to the north west – four of the seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – closest component of the SPA is Ockham & Wisley Commons SSSI, some 2.3 kilometres to the south east – three of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – Chobham Common SSSI, some 6.1 kilometres to the north west, is the only component of the SAC located within 10 kilometres of the ILAS.

ILAS02: Hersham Trading Estate, Lyon Road, Walton

on Thames

South West London Waterbodies SPA – closest component of the SPA is the Knight & Bessborough Reservoirs SSSI, some 1.9 kilometres to the north – four of the seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – Ockham & Wisley Commons SSSI, some 6.9 kilometres to the south west, is the only component of the SPA located within 10 kilometres of the ILAS.

Richmond Park SAC – the SAC commences some 8.2 kilometres to the north east of the ILAS.

ILAS03: Molesey Industrial Estate, Central Avenue,

West Molesey

South West London Waterbodies SPA – closest component of the SPA is the Knight & Bessborough Reservoirs SSSI, some 0.03 kilometres to the west – four of the seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – Ockham & Wisley Commons SSSI, some 9.6 kilometres to the south west, is the only component of the SPA located within 10 kilometres of the ILAS.

Richmond Park SAC – the SAC commences some 6.7 kilometres to the north east of the ILAS.

Wimbledon Common SAC – the SAC commences some 9.0 kilometres to the north of the ILAS.

ILAS04: Longmead Industrial Estate, Longmead

Road, Epsom

Mole Gap to Reigate Escarpment SAC – the SAC commences some 7.3 kilometres to the south of the ILAS.

Richmond Park SAC – the SAC commences some 8.5 kilometres to the north west of the ILAS.

Wimbledon Common SAC – the SAC commences some 8.6 kilometres to the north of the ILAS.

ILAS05: Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford

Thames Basin Heaths SPA – closest component of the SPA is Whitmoor Common SSSI, some 0.8 kilometres to the north west – five of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Ash to Brookwood Heaths SSSI, some 4.2 kilometres to the north west – two of the four components of the SAC are located within 10 kilometres of the ILAS.


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ILAS06: Woodbridge Meadows Industrial Estate,

Guildford

Thames Basin Heaths SPA – closest component of the SPA is Whitmoor Common SSSI, some 2.2 kilometres to the north – four of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 9.7 kilometres to the south west of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Ash to Brookwood Heaths SSSI, some 5.0 kilometres to the north west – three of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS07: Land north & south of Lysons Avenue, Ash Vale

Thames Basin Heaths SPA – closest component of the SPA is Ash to Brookwood Heaths SSSI, some 0.4 kilometres to the east – eight of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 9.7 kilometres to the south of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Ash to Brookwood Heaths SSSI, some 0.4 kilometres to the east – three of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS08: Riverwey Industrial Estate, Astolat Business

Park & Weyvern Park, Old Portsmouth Road,

Peasmarsh

Thames Basin Heaths SPA – closest component of the SPA is Whitmoor Common SSSI, some 6.8 kilometres to the north – two of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 6.6 kilometres to the south west of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Thursley, Hankley & Frensham Commons SSSI, some 6.6 kilometres to the south west – two of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS09: Land at Burnt Common Warehouse,

London Road, Send

Thames Basin Heaths SPA – closest component of the SPA is Whitmoor Common SSSI, some 3.6 kilometres to the west – six of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Ash to Brookwood Heaths SSSI, some 7.5 kilometres to the west – three of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS10: Land near Dorking West Station, Curtis Road /

Station Road, Dorking

Mole Gap to Reigate Escarpment SAC – the SAC commences some 1.7 kilometres to the north east of the ILAS.

ILAS11: Holmethorpe Industrial Estate, Redhill

Mole Gap to Reigate Escarpment SAC – the SAC commences some 2.5 kilometres to the north east of the ILAS.

ILAS12: Perrywood Business Park, Honeycrock Lane,

Salfords

Mole Gap to Reigate Escarpment SAC – the SAC commences some 6.0 kilometres to the north west of the ILAS.

ILAS13: Salfords Industrial Estate, Brighton Road /

Bonehurst Road, Salfords

Mole Gap to Reigate Escarpment SAC – the SAC commences some 6.1 kilometres to the north of the ILAS.

ILAS14: Thorpe Industrial Estate, Ten Acre Lane,

Egham

South West London Waterbodies SPA – closest component of the SPA is the Thorpe Park No.1 Gravel Pit SSSI, some 0.7 kilometres to the south – all seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – closest component of the SPA is Chobham Common SSSI, some 5.5 kilometres to the south west – two of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Windsor Forest & Great Park SAC – the SAC commences some 4.8 kilometres to the west of the ILAS.


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ILAS15: Byfleet Road Employment Allocation,

New Haw, Byfleet

South West London Waterbodies SPA – closest component of the SPA is the Thorpe Park No.1 Gravel Pit SSSI, some 05.5 kilometres to the north west – four of the seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – closest component of the SPA is Ockham & Wisley Commons SSSI, some 2.9 kilometres to the south east – three of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

ILAS16: Windmill Road Industrial Area, Sunbury on

Thames

South West London Waterbodies SPA – closest component of the SPA is the Kempton Park Reservoirs SSSI, some 2.2 kilometres to the north east – all seven components of the SPA are located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – Ockham & Wisley Commons SSSI, some 9.8 kilometres to the south, is the only component of the SPA located within 10 kilometres of the ILAS.

Richmond Park SAC – the SAC commences some 9.7 kilometres to the east of the ILAS.

ILAS17: York Town Industrial Estate, Doman Road / Stanhope Road,

Camberley

Thames Basin Heaths SPA – closest component of the SPA is Castle Bottom to Yateley & Hawley Commons SSSI, some 0.6 kilometres to the west – ten of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest components of the SAC are the Ash to Brookwood Heaths SSSI, some 4.4 kilometres to the south east, and the Colony Bog & Bagshot Heaths SSSI some 4.4 kilometres east – three of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS18: Hobbs Industrial Estate, Felbridge

Ashdown Forest SPA – the SPA commences some 8.6 kilometres to the south east of the ILAS.

Ashdown Forest SAC – the SAC commences some 8.6 kilometres to the south east of the ILAS.

ILAS19: Land at Dunsfold Aerodrome, Stovolds Hill,

Cranleigh

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 8.7 kilometres to the north west of the ILAS.

Ebernoe Common SAC – the SAC commences some 8.8 kilometres to the south of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC –Thursley, Hankley & Frensham Commons SSSI, some 8.7 kilometres to the north west, is the only component of the SAC located within 10 kilometres of the ILAS.

ILAS20: Coxbridge Business Park, Alton Road, Farnham

Thames Basin Heaths SPA – closest component of the SPA is Bourley & Long Valley SSSI, some 3.2 kilometres to the north – three of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 4.8 kilometres to the south east of the ILAS.

East Hampshire Hangers SAC – the Upper Greensand Hangers: Wyck to Wheatley SSSI, some 6.0 kilometres to the south west, is the only component of the SAC located within 10 kilometres of the ILAS.

Shortheath Common SAC – the SAC commences some 9.4 kilometres to the south west of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Thursley, Hankley & Frensham Commons SSSI, some 4.8 kilometres to the south east – two of the four components of the SAC are located within 10 kilometres of the ILAS.


8



ILAS21: Farnham Trading Estate, Water Lane,

Farnham

Thames Basin Heaths SPA – closest component of the SPA is Bourley & Long Valley SSSI, some 2.1 kilometres to the north west – four of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA – the SPA commences some 4.8 kilometres to the south of the ILAS.

East Hampshire Hangers SAC – the Upper Greensand Hangers: Wyck to Wheatley SSSI, some 9.5 kilometres to the south west, is the only component of the SAC located within 10 kilometres of the ILAS.

Wealden Heaths Phase 2 SPA – the Devil’s Punch Bowl SSSI, some 9.7 kilometres to the south east, is the only component of the SPA located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Thursley, Hankley & Frensham Commons SSSI, some 4.8 kilometres to the south – two of the four components of the SAC are located within 10 kilometres of the ILAS.

ILAS22: Monument Way East Industrial Estate,

Woking

South West London Waterbodies SPA – the Thorpe Park No.1 Gravel Pit SSSI, some 8.3 kilometres to the north, is the only component of the SPA located within 10 kilometres of the ILAS.

Thames Basin Heaths SPA – closest component of the SPA is Horsell Common SSSI, some 0.7 kilometres to the north – six of the thirteen components of the SPA are located within 10 kilometres of the ILAS.

Thursley, Ash, Pirbright & Chobham SAC – closest component of the SAC is Chobham Common SSSI, some 4.1 kilometres to the north west – three of the four components of the SAC are located within 10 kilometres of the ILAS.

Windsor Forest & Great Park SAC – the SAC commences some 9.3 kilometres to the north west of the ILAS.

1.10 The geographical relationship of the allocated sites and the ILAS proposed under policies 10

and 11 of the Surrey WLP, and the European sites that are situated within the county, or

within 10 kilometres of the county boundary has informed the level of assessment carried

out in respect of the SPAs and SAC listed in Table 1-C.

1.10.1 For those SPAs and SACs situated within 10 kilometres of a proposed site

allocation or ILAS, the assessment considered whether development of the

identified land for waste management purposes could impact upon the

ecological integrity of the SPA or SAC. The assessment also addressed the

impacts that implementation of the other policies proposed as part of the Plan

could have on ecological integrity

1.10.2 For those SPAs and SACs with no proposed site allocations or ILAS located

within 10 kilometres of them the assessment focused on the impacts that

implementation of all the policies proposed as part of the Plan could have on

the ecological integrity of each designated site.


9

Table 1-C: European sites covered by the Habitat Regulations Assessment

European Site Summary SAC/SPA Location

Proposed SWLP Sites / ILAS <10km

Conclusion on need for further

assessment

Special Areas of Conservation

Ashdown Forest: East Sussex, 2,729.0 hectares. Ashdown Forest SSSI. Designated for the presence of Northern Atlantic wet heaths with Erica tetralix, European dry heaths, & the great crested newt

5.8 km south of Surrey boundary

ILAS18

Further assessment required in respect

of the policy framework & ILAS

East Hampshire Hangers: Hampshire, 569.7 hectares.

Coombe Wood & the Lythe SSSI, Noar Hill SSSI, Selborne Common SSSI, Upper Greensand Hangers: Empshott to Hawkley SSSI, Upper Greensand Hangers: Wyck to Wheatley SSSI, Wealden Edge Hangers SSSI, & Wick Wood & Worldham Hangers SSSI. Designated for the presence of semi-natural dry grasslands & scrubland facies on calcareous substrates (Festuco-Brometalia) (important orchid sites), Asperulo-Fagetum beech forests (on neutral to rich soils), Tilio-Acerion forests of slopes, screes & ravines (on base-rich soils associated with rocky slopes), Taxus baccata woods (yew) of the British Isles, & the Early gentian

2.7 km west of Surrey boundary

ILAS20; ILAS21



Ebernoe Common: West Sussex, 234.9 hectares. Ebernoe Common SSSI. Designated for the presence of Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion) (on acid soils), the Barbastelle bat, & the Bechstein`s bat


ILAS19



Mole Gap to Reigate Escarpment: Surrey, 887.7 hectares. Mole Gap to Reigate Escarpment SSSI; Designated for the presence of European dry heaths, stable xerothermophilous formations with Buxus sempervirens (natural box scrub) on rock slopes (Berberidion p.p.), semi-natural dry grasslands & scrubland facies on calcareous substrates (Festuco-Brometalia) (important orchid sites), Asperulo-Fagetum beech forests (on neutral to rich soils), Taxus baccata (yew) woods of the British Isles, the great crested newt, & the Bechstein`s bat

Within Surrey

Site 4 (Leatherhead STW)

Site 5 (Lambs Business Park)

ILAS04; ILAS10; ILAS11; ILAS12; ILAS13


of the policy framework, ILAS &

allocated sites

Richmond Park: Greater London, 846.7 hectares. Richmond Park SSSI. Designated for the presence of the Stag beetle

3.8 km north of Surrey boundary

Site 2 (Weylands TW)

ILAS02; ILAS03; ILAS04; ILAS16



allocated sites

Shortheath Common: Hampshire, 58.9 hectares. Shortheath Common SSSI. Designated for the presence of European dry heaths, transition mires & quaking bogs, bog woodland

4.1 km west of Surrey boundary

ILAS20



The Mens: West Sussex, 203.3 hectares. The Mens SSSI.

Designated for the presence of Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion) (on acid soils), & the Barbastelle bat


No


of the policy framework

Thursley, Ash, Pirbright & Chobham: Surrey, 5,138.0 hectares. Ash to Brookwood Heaths SSSI, Chobham Common SSSI, Colony Bog & Bagshot Heath SSSI & Thursley, Hankley & Frensham Commons SSSI. Designated for the presence of Northern Atlantic wet heaths with Erica tetralix, European dry heaths, depressions on peat substrates of the Rhynchosporion

Within Surrey

Site 3 (Slyfield IE)

Site 6 (Trumps Farm)

ILAS01; ILAS05; ILAS06; ILAS07; ILAS08; ILAS09; ILAS17; ILAS19; ILAS20;

ILAS21; ILAS22



allocated sites


10

European Site Summary SAC/SPA Location

Proposed SWLP Sites / ILAS <10km

Conclusion on need for further

assessment

Special Areas of Conservation

Wimbledon Common: Greater London, 348.3 hectares. Wimbledon Common SSSI. Designated for the presence of Northern Atlantic wet heaths with Erica tetralix, European dry heaths, & the Stag beetle

4.6 km north of Surrey

boundary


ILAS03; ILAS04



allocated sites

Windsor Forest & Great Park: Berkshire & Surrey,

1,687.3 hectares. Windsor Forest & Great Park SSSI. Designated for the presence of Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion) (on acid soils), old acidophilous oak woods with Quercus robur on sandy plains, & the Violet click beetle

Within Surrey (partial)

Site 1 (Oakleaf Farm)


ILAS14; ILAS22



allocated sites

Woolmer Forest: Hampshire & West Sussex, 666.7

hectares. Woolmer Forest SSSI. Designated for the presence of natural dystrophic lakes & ponds, Northern Atlantic wet heaths with Erica tetralix, European dry heaths, transition mires & quaking bogs, depressions on peat substrates of the Rhynchosporion

4.9 km west of Surrey

boundary No


of the policy framework

Special Protection Areas

Ashdown Forest: East Sussex, 3,207.1 hectares. Ashdown Forest SSSI. Designated for the presence of breeding populations of the European nightjar, & the Dartford warbler

5.8 km south of Surrey

boundary ILAS18(TA)



South West London Waterbodies: Berkshire, Greater London & Surrey, 828.1 hectares. Kempton Park Reservoirs SSSI, Knight & Bessborough Reservoirs SSSI, Staines Moor SSSI, Thorpe Park No 1 Gravel Pit SSSI, Wraysbury & Hythe End Gravel Pits SSSI, Wraysbury No 1 Gravel Pit SSSI & Wraysbury Reservoir SSSI. Designated for the presence of non-breeding populations of the Gadwall, & the Northern shoveler


Site 1 (Oakleaf Farm)



ILAS01; ILAS02; ILAS03; ILAS14; ILAS15; ILAS16);

ILAS22



allocated sites

Thames Basin Heaths: Berkshire, Hampshire & Surrey, 8,274.7 hectares. Ash to Brookwood Heaths SSSI, Bourley & Long Valley SSSI, Bramshill SSSI, Broadmoor to Bagshot Woods & Heaths SSSI, Castle Bottom to Yateley & Hawley Commons SSSI, Chobham Common SSSI, Colony Bog & Bagshot Heath SSSI, Eelmoor Marsh SSSI, Hazeley Heath SSSI, Horsell Common SSSI, Ockham & Wisley Commons SSSI, Sandhurst to Owlsmoor Bogs & Heaths SSSI, Whitmoor Common SSSI. Designated for the presence of breeding populations of the European nightjar, the Woodlark, & the Dartford warbler



Site 3 (Slyfield IE)

Site 4 (Leatherhead STW)


ILAS01; ILAS02; ILAS03; ILAS05 ILAS06; ILAS07; ILAS08; ILAS09; ILAS14; ILAS15; ILAS16; ILAS17; ILAS20; ILAS21; ILAS22



allocated sites

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1): Surrey, 1,869.9 hectares. Thursley, Hankley & Frensham Commons SSSI. Designated for the presence of breeding populations of the European nightjar, the Woodlark, & the Dartford warbler

Within Surrey ILAS06; ILAS07; ILAS08; ILAS19; ILAS20; ILAS21



Wealden Heaths Phase 2: Hampshire, Surrey & West

Sussex, 2,053.8 hectares. Bramshott & Ludshott Commons SSSI, Broxhead & Kingsley Commons SSSI, Devil’s Punch Bowl SSSI & Woolmer Forest SSSI. Designated for the presence of breeding populations of the European nightjar, the Woodlark, & the Dartford warbler


ILAS21




11

1-D Key Principles & Approach

1.11 The remainder of this report is divided into two parts, the first dealing with those SACs and

SPAs for which the focus of the assessment is solely the policy framework set out by the

Surrey WLP, and the second dealing with those SACs and SPAs that are situated within 10

kilometres of the site allocations (Policy 11(a & b)) and/or identified ILAS (Policy 10).

1.12 For each SAC and SPA covered by the assessment, their key characteristics (reasons for

designation, conservation objectives, condition of constituent SSSIs) are described, and the

threats and pressures (impact pathways) to which they are susceptible are identified. The

site relevant impact pathways have been drawn from the published Site Improvement Plan

(SIP) for each SPA and SAC, prepared by Natural England to provide guidance on the actions

that need to be taken to support the attainment of the published Conservation Objectives

for each SPA and SAC.

1.13 For those SPAs and SACs that are located within 10 kilometres of any of the allocated sites

or identified ILAS, and for which atmospheric pollution has been identified as a threat by

Natural England in the relevant SIP, information on designated site and habitat relevant

critical loads and background deposition rates for the identified pollutant of concern has

been compiled from the Air Pollution Information System (APIS) website

(http://www.apis.ac.uk).

1.14 For thermal treatment facilities the gap identified by the Surrey WLP is between 0.174

million tonne and 0.278 million tonnes by the end of the plan period (2033), which could be

met by facilities of a range of sizes and types distributed across the allocated sites, the

identified ILAS or on unallocated land within the county.

1.15 In order to examine the potential impacts of the use of thermal treatment technologies at

the proposed Surrey WLP site allocations situated within 10 kilometres of SACs and SPAs,

emissions from four different proxy facilities have been modelled for each of those

proposed site allocations (see Chapters 4 and 5 of the Surrey Waste Local Plan: Air Quality

Impact Assessment report, June 2018, AECOM, and Appendix C to this report for further

details).

1.16 No detailed air quality modelling has been undertaken with reference to the ILAS identified

under Policy 10 of the Surrey WLP, as it was considered unlikely that large scale thermal

treatment facilities would be brought forward within the context of existing industrial and

employment land.

1.17 Other Local Plans relevant to the areas in which the SPAs and SACs are located, that could

act in-combination with the policies and site specific proposals set out in the emerging

Surrey WLP, have been considered where appropriate.

http://www.apis.ac.uk/


12

1.18 On 8 August 2019 a Statement of Common Ground was agreed between Surrey County

Council and Natural England in respect of the Surrey Waste Local Plan. That Statement of

Common Ground includes information, as an appendix, parts of which are relevant to the

conclusions of the HRA. The Statement of Common Ground has therefore been

incorporated into the final HRA report, as Appendix D, and additional paragraphs have been

added to the conclusions section of Chapters 11 (South West London Waterbodies SPA &

Ramsar Site), 12 (Thames Basin Heaths SPA), and 13 (Thursley, Ash, Pirbright & Chobham

SAC), and to the relevant sections (18.K, 18.L and 18.M) of Chapter 18.


13

Part A Assessment for European Sites >10km from development locations identified in the Surrey WLP

Part A of the HRA report deals with those European Sites that are not located

within 10 kilometres of any of the sites proposed for allocation under Policy 11

or any of the ILAS identified under Policy 10 of the Surrey WLP.

The following SACS are covered by the chapters that comprise this part of the

HRA report.

Chapter 2 The Mens SAC

Chapter 3 Woolmer Forest SAC


14

Chapter 2 The Mens SAC

2.A Geographic & Development Context

2.A.1 Location of the SAC

2.1 The Mens SAC (see map) is located in West Sussex, and is composed of a single SSSI, The

Mens SSSI, and lies some 6.4 kilometres to the south of the Surrey / West Sussex boundary.

The SAC covers an area of 203.28 hectares, as stated on the SAC citation, and was

designated on 1 April 2005. The SAC is situated within an area administered by the South

Downs NPA, by Chichester DC, and by West Sussex CC. Within Surrey, the Waverley BC area

is located closest to the SAC.

2.2 The SAC is dissected by the A272 (Horsham Road / Petworth Road), which passes through

or within 200 metres of the SAC.

2.3 The SAC lies within two surface water catchments (see below), neither of which is wholly or

partly situated within the county of Surrey. One of those catchments (GB107041017590) is

fed by an upstream catchment (North River, GB10704107990) that is situated within

Surrey.

2.3.1 The ‘Kird’ (GB107041012300).

2.3.2 The ‘Arun’ (upstream Pallingham) (GB107041017590).

2.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC

2.4 The Mens SAC is not located within 10 kilometres of any of the six sites proposed for

allocation under Policy 11, or any of the twenty-two ILAS identified under Policy 10 of the

Surrey WLP (see Figure 2-A – a full size version can be found in Appendix A). The closest

proposed allocation is Site 3 (Land to the north east of Slyfield Industrial Estate, Moorfield

Road, Guildford), which lies some 26.1 kilometres to the north west of the SAC. The closest

ILAS is ILAS 19 (Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh), which lies some 10.4

kilometres to the north of the SAC. The SAC is located within 6.4 kilometres of the Surrey

county boundary, and it is therefore possible that waste related development, including

facilities for the thermal treatment of waste, could proceed within the county on land other

than that proposed for allocation or identified in the Surrey WLP, and be situated within 10

kilometres of the SAC.

http://magic.defra.gov.uk/MagicMap.aspx?startTopic=Designations&activelayer=sacIndex&query=Ref_CODE%3D%27UK0012716%27


15

Figure 2-A: The Mens SAC – Relationship to sites & ILAS proposed by the Surrey WLP

2.5 None of the sites proposed for waste related development in the adopted Surrey Waste

Plan, or in the Aggregates Recycling Joint DPD, are situated within 10 kilometres of the SAC.

None of the preferred areas for mineral working identified in the adopted Surrey Minerals

Plan are situated within 10 kilometres of the SAC. The Habitat Regulations Assessments

undertaken in respect of all three of those plans concluded that the ecological integrity of

the SAC would not be adversely affected by their implementation.

2.B Key Characteristics of the Designated Site

2.B.1 Reasons for Designation 2.6 The ecological interest of the SAC, and the particular habitats and species that are given as

reasons for its designation, is described as follows in the published citation.

Site Description

The Mens is an extensive area of mature beech Fagus sylvatica woodland rich in lichens, bryophytes, fungi & saproxylic (dead wood) invertebrates. It is developing a near-natural high forest structure, in response to only limited silvicultural intervention over the 20th century, combined with the effects of natural events such as the 1987 great storm. The site also supports an important population of barbastelle bat Barbastella barbastellus.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

The Mens SAC

The MensSAC

N

S

W E

Site 6: Trumps Farm

Site 1: Oakleaf Farm

50 km

40 km

30 km

20 km

Site 2: Weylands TW

Site 3: Slyfield IE

Site 4: Leatherhead STW

Site 5: Lambs BPILAS19

ILAS05;ILAS09ILAS06;

ILAS08

ILAS10ILAS20;ILAS21

ILAS01;ILAS15;ILAS22

ILAS04

ILAS02; ILAS03; ILAS16

ILAS07

ILAS17

ILAS18


ILAS14


16

Qualifying Habitats

The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:

Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion). (Beech forests on acid soils)

Qualifying Species

The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:

Barbastelle bat Barbastella barbastellus

2.B.2 Conservation Objectives

2.7 The published conservation objectives for the SAC are given below.

Conservation Objectives

Ensure that the integrity of the site is maintained or restored as appropriate, & ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

The extent & distribution of qualifying natural habitats & habitats of qualifying species

The structure & function (including typical species) of qualifying natural habitats

The structure & function of the habitats of qualifying species

The supporting processes on which qualifying natural habitats & the habitats of qualifying species rely

The populations of qualifying species, &,

The distribution of qualifying species within the site.

Qualifying Features

Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils (H9120.)

Barbastella barbastellus; Barbastelle bat (S1308)

2.B.3 Condition

2.8 Based on the information published by Natural England in the most recent condition survey

report for The Mens SSSI6 (see Table 2-A), the designated site extends to some 205.16

hectares, of which some 97.3 % is in ‘favourable’ condition, and some 2.7% is in

‘unfavourable – declining’ condition. The SSSI is composed of single main habitat type,

‘broadleaved, mixed & yew woodland’ (205.16 hectares).

6 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000537&ReportTitle=The%20Mens%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000537&ReportTitle=The%20Mens%20SSSI


17

Table 2-A: The Mens SSSI – Condition Survey Findings

Main Habitat Type

Condition Classification

Favourable Unfavourable –

Declining

Broadleaved, Mixed & Yew Woodland - Lowland

205.16 ha 199.67 ha

(97.3%) 5.48 ha (2.7%)

Totals 205.16 ha 199.67 ha

(97.3%) 5.48 ha (2.7%)

2.9 For the 5.48 hectares of the broadleaved, mixed and yew woodland habitat (SSSI unit

number 9, last surveyed on 6 June 2013) classified as exhibiting ‘unfavourable – declining’

condition, the condition survey report provides the following information.

Comments: Appropriate woodland management needs to be agreed.

Reasons for adverse condition: Forestry - Forestry & Woodland Management

2.C Identification of Impact Pathways & Screening Evaluation

2.10 The published Site Improvement Plan (SIP) for the SAC (6 March 2015) identifies the

following key pressures and threats to the site’s ecological integrity.

Changes in forestry and woodland management – discussed in section 2.C.1;

Changes in habitat connectivity – discussed in section 2.C.2;

Introduction or spread of invasive species – discussed in section 2.C.3;

Changes in land management – discussed in section 2.C.4;

Changes in air pollution (deposition of atmospheric nitrogen) – discussed in section

2.C.5;

Changes in public access /disturbance – discussed in section 2.C.6.

2.C.1 Forestry & woodland management

2.11 The features affected by changes in forestry and woodland management practices are the

beech forests on acid soils (H9120), the Barbastelle bat (S1308) population, and the

Bechsteins bat (S1323) population. The SIP (pp.4/11 to 5/11) offers the following

explanations of the nature of the identified pressures and threat:

“A small area of the site was clear felled without consent in the last ten years & needs restoring

to woodland.”

“Woodland management for SSSI features (lichens, invertebrates) which require higher light

levels may have a significant impact on the bat species. Additionally some management of the

beech woodland is necessary in places. More information about potential impacts on bat

species is required.”


18

2.12 The actions that have been identified as the principal means of addressing the pressures

and threat are concerned with restoring areas that have been clear-felled across the SAC

through natural regeneration/planting, investigating the potential impacts of woodland and

wood pasture management in and around the SAC, and across other nearby SACs, for other

designated features on bat species/populations, and implementing management inside the

SAC, in the surrounding area, and in nearby SACs where bat species are known to use the

habitat.

2.13 Screening Evaluation: There is no mechanism by which the forms of development covered

by the Surrey WLP would impact upon current or future forestry and woodland

management practices within the SAC.

2.14 The only points at which the forestry and woodland management regime implemented

across the SAC may interface with waste management operations and practices would be in

respect of a need for the removal and appropriate management of the waste materials that

will arise from time to time as a consequence of active woodland management (e.g. green

waste from thinning, coppicing, etc.). The provision of additional waste management

capacity within the county of Surrey would be unlikely to be situated in close enough

proximity to the SAC to be of significant benefit to the ongoing management of its

woodland habitats. Wastes arising from the management of the SAC would more likely be

dealt with by facilities situated in West Sussex.

2.15 Screening Conclusion: The implementation of the Surrey WLP, including through the

development of the sites allocated under Policy 11 or the ILAS identified under Policy 10,

would not give rise to direct or indirect significant impacts on forestry or woodland

management practices within the SAC, and therefore would not impact upon the condition

of those habitats. No further assessment is required in respect of the changes in forestry

and woodland management impact pathway.

2.C.2 Habitat connectivity

2.16 The feature affected by changes in habitat connectivity within and beyond the SAC is the

population of the Barbastelle bat (S1308). The SIP (pp.5/11 to 6/11) offers the following

explanation of the nature of the identified pressures and threats:

“The protected site is limited to a woodland core area where breeding colonies are known to

exist. The bats, however, rely on commuting & foraging habitat outside of the site & this needs

to be better understood, protected & appropriately managed. It would also be useful to

understand how this site relates to other bat SACs in the southern part of the UK to ensure

that they & the connecting habitats are managed appropriately to maintain favourable

populations.”

“Ebernoe Common & The Mens are similar SACs which lie within 5km of each other. It is likely

that the bat populations of both sites are genetically linked. Barbastelle bats are known to

commute more than 5km & there is continuous woodland cover between the sites to allow


19

Bechstein's to travel. There is a case to investigate whether the two sites should be treated

within one overarching N2K site. It would also be useful to understand (through genetic

analysis) how this site relates to other bat SACs in the southern part of the UK to ensure that

they & the connecting habitats are managed appropriately to maintain favourable

populations.”

2.17 The actions that have been identified as the principal means of addressing the pressures

and threats are concerned with:

(a) Identifying further areas (outside the core area of woodland/wood pasture) with

available, restored or created habitat that could suitably provide for foraging, for

swarming activity, for commuting to hibernating sites, and for improving connectivity

to related sites;

(b) Investigating whether Ebernoe Common SAC and The Mens SAC should be treated as

one overarching Natura 2000 site, including genetic analysis of how The Mens SAC

relates to other bat SACs in the southern part of the UK to ensure that they and the

connecting habitats are managed appropriately to maintain favourable populations;

and

(c) Implementing tailored management to habitats in and outside the SAC where bats

commute and forage.


by the Surrey WLP would impact, either negatively or positively, upon the connectivity of

the habitats of the SAC bat species, within the SAC, within the nearby Ebernoe Commons

SAC, and within the wider area in which the two SACs are located.

2.19 The Surrey WLP is concerned with the provision of additional waste management capacity

within the county of Surrey over a 15 year period, to meet projected growth in waste

arisings, and its implementation will typically involve the development of relatively small

sites with limited scope to contribute to habitat creation or enhancement. The Surrey WLP

would exert no influence over the management of the wider countryside within the county

of Surrey or beyond, or over the siting of development outside the boundaries of the

county of Surrey. As the SAC is not located within, or adjacent to the county of Surrey, its

habitats and those of the surrounding area would be unaffected by development brought

forward under the Surrey WLP.



would not give rise to direct or indirect significant impacts on the SAC with reference to

habitat connectivity within the designation or the wider area. No further assessment is

required in respect of the habitat connectivity impact pathway.


20

2.C.3 Invasive species

2.21 The feature affected by the incursion of invasive species into the SAC is the beech forests

on acid soils (H9120). The SIP (p.6/11) offers the following explanation of the nature of the

identified threat:

“Rhododendron is invading the south eastern edges of the site & surrounds the edges of the

site on the northern side.”

2.22 The actions that have been identified as the principal means of addressing the threat are

concerned with implementing a control plan to remove invasive rhododendron species

from the SAC.


by the Surrey WLP could act to enable or prevent the introduction of invasive plant species

into the SAC. The area of land covered by the SAC designation is situated beyond the

county of Surrey, so could not be affected by any waste related development brought

forward under the Surrey WLP, as no new facilities would be situated in sufficiently close

proximity to the SAC to act as a source from which invasive plant species could spread (e.g.

green waste arising from domestic gardens and horticultural businesses).



would not give rise to direct or indirect significant impacts on the SAC as a consequence of

the introduction of invasive plant species. No further assessment is required in respect of

the invasive species impact pathway.

2.C.4 Change in land management

2.25 The feature affected by any changes in land management is the Barbastelle bat (S1308)

population. The SIP (p.7/11) offers the following explanation of the nature of the identified

pressure/threat:

“Land management in the surrounding countryside will have an impact on foraging areas for

Barbastelle bats but at present the forage requirements i.e. how much habitat & of what type,

are poorly understood. Ultimately, inadequate foraging will impact on breeding success within

the site. Further investigation of foraging & bat commuting route requirements of notified bat

species is required, informing better management of mature hedgerows which need to be

restored and maintained in the area around the site.”

2.26 The actions that have been identified as the principal means of addressing the

pressure/threat are concerned with further investigation of the foraging and commuting

route requirements of the notified bat species (within and outside the SAC), with the aim of

informing improved management of foraging and commuting habitat in the surrounding

landscape.


21


by the Surrey WLP would impact upon current or future bat foraging and commuting routes

within and surrounding the SAC. The area of land covered by the SAC designation is

situated beyond the county of Surrey, so implementation of the Surrey WLP could not

interfere directly or indirectly with the functioning of existing or future bat foraging and

commuting routes, through the siting of development in locations coincident with, or

adjacent to, those routes.



would not give rise to direct or indirect significant impacts on land management practices

on the SAC that may affect the functioning of bat commuting and foraging routes. No

further assessment is required in respect of the changes in land management impact

pathway.

2.C.5 Air pollution: impact of atmospheric nitrogen deposition

2.29 The features affected by changes in the deposition of nutrient nitrogen from the

atmosphere are the beech forest on acid soils (H9120) habitat, and the Barbastelle bat

(S1308) population (due to changes in habitat composition and suitability). The SIP (p.7/11)

offers the following explanation of the nature of the identified threat:

“Nitrogen deposition exceeds the site-relevant critical load for ecosystem protection & hence

there is a risk of harmful effects, but the sensitive features are currently considered to be in

favourable condition on the site. This requires further investigation.”


concerned with further investigation of the potential impacts of atmospheric nitrogen

deposition on the SAC.

2.31 Screening Evaluation: The Surrey WLP could result in development that would give rise to

emissions of nitrogen containing compounds that could contribute to nutrient deposition.

The main sources would be waste management facilities (in particular those making use of

thermal treatment technologies to dispose of waste and recover energy), and vehicle

movements associated with the construction and operation of waste facilities.

2.32 In terms of the potential for point source emissions, from waste management facilities,

there is no risk of development at any of the six sites proposed for allocation under Policy

11 of the Surrey WLP giving rise to nutrient nitrogen deposition within the SAC at

concentrations that would exceed 1% of the site relevant critical loads for beech woodlands

(10kg N/ha/yr) or for the broadleaved deciduous woodland habitat of the SAC bat species

(10kg N/ha/yr), alone or in-combination. The closest proposed site allocation (Site 3 – Land

to the north east of Slyfield Industrial Estate, Moorfield Road, Guildford) is located some

26.1 kilometres to the north east of the SAC, and the closest ILAS (ILAS19 – Land at

Dunsfold Aerodrome, Stovolds Hill, Cranleigh) is 10.4 kilometres to the north, both of which

are beyond the distance (10 kilometres) for which assessment would be required by the


22

Environment Agency as part of the Environmental Permit consenting process. Any

contribution that emissions from a thermal treatment facility situated at either the closest

allocated site (Site 3) or the closest ILAS (ILAS 19) would make to nitrogen deposition at the

SAC would be undetectable.

2.33 It is possible that proposals for waste related development could be brought forward on

land situated within Surrey other than the proposed allocated sites or the identified ILAS,

which could include land located within 10 kilometres of the SAC. However, the land

situated in Surrey that lies within 10 kilometres of the SAC to the north and north west is

covered by the Metropolitan Green Belt designation, and the policy approach for the Surrey

WLP does not prefer non-allocated Green Belt land over allocated Green Belt sites. The land

within Surrey to the north east of the SAC is not within the Green Belt, but is rural in

character and would offer little in the way of previously developed land, and the policy

approach of the Surrey WLP prefers non-Green Belt previously developed land over

greenfield sites. It is therefore unlikely that a strategic waste management facility, as a

large scale (c.150,000 tonnes per annum or greater capacity) thermal treatment plant

would be classed, would be sited on unallocated land within 10 kilometres of the SAC. In

addition, Policy 14 of the Surrey WLP requires that all waste related planning applications

be supported by sufficient information for the Waste Planning Authority to be able to

ascertain whether the proposed development would result in significant adverse impacts

on the natural environment, including SACs. Policy 14 also limits the grant of planning

permission to those developments that have been demonstrated to have no significant

adverse impacts on the environment, which includes significant impacts on SACs.

2.34 In terms of the potential for diffuse emissions, traffic generated by waste related

development in Surrey would be unlikely to travel along the section of the A272 (Horsham

Road / Petworth Road) that passes through the SAC. For the closest site allocation (Site 3 –

Land to the north east of Slyfield Industrial Estate, Moorfield Road, Guildford), the

Transport Study for the Surrey WLP reports that development of a large scale (c.300,000

tpa capacity) energy from waste (EfW) facility would result in a 6% increase in annual

average daily traffic (AADT) on the section of the A320 (Woking Road) closest to that site

(Waste Local Plan – Transport Study: Site Assessments, Table 3.1, p.20). Section 3.3 (p.21)

of the Transport Study predicts that traffic generated by any waste related development at

the allocated site in Guildford would disperse to the strategic road network via the A320,

travelling south to the A3 in Guildford. It is not predicted that any traffic would disperse in a

manner that would result in it travelling along the A272 in West Sussex and through the

SAC.

2.35 No detailed assessment has been made of the likely impact of waste related development

at any of the ILAS identified under Policy 10 of the Surrey WLP on traffic levels on the local

or strategic road networks. The closest ILAS (ILAS 19 – Land at Dunsfold Aerodrome,

Stovolds Hill, Cranleigh) to the SAC is accessed via the A281 (Guildford Road), which links to

the A29 (Stane Street) and the A24 (London Road) to the south east, and to the A3 to the

north west. It is not anticipated that traffic arising from any waste related development

that might proceed at the closest ILAS (ILAS19) would disperse in a manner that would


23

result in significant numbers of additional vehicles travelling along the A272 in West Sussex

and through the SAC.

2.36 The HRA report (URS, May 2014) prepared in respect of the adopted Chichester DC Local

Plan concluded that there would be no significant impact, alone or in-combination, on the

integrity of the SAC as a consequence of that plan’s implementation, subject to the use of

appropriate mitigation measures (i.e. retention of hedgerows, tree-belts and other linear

habitats used by the SAC bat species, or the undertaking of bat surveys prior to ascertain

the SAC species use of any hedgerows, tree-belts or other linear habitats that would be

removed as a consequence of development). The published HRA reports (AECOM, 2016,

2017 and 2018) for the Waverley BC Local Plan concluded that implementation of the

policies and proposals set out in Parts 1 and 2 of that Plan would not give rise to significant

effects on the ecological integrity of the SAC, alone or in-combination.

2.37 Screening Conclusion: The implementation of the Surrey WLP would not give rise to direct

or indirect significant impacts on nutrient nitrogen deposition within the SAC, as a

consequence of emissions from point sources (waste facilities) or diffuse sources (traffic

arising from waste related development). No further assessment is required in respect of

the air pollution (emission and deposit of nitrogen) impact pathway.

2.C.6 Public access / disturbance:

2.38 The feature affected by disturbance from light pollution is the Barbastelle bat (S1308)

population. The SIP (p.7/11) offers the following explanation of the nature of the identified

pressure/threat:

“It is known that light pollution has an impact on bat species. The investigation would seek to

identify what light levels are presently & deduce whether they are having an impact on bat

movements/roosting availability in & around the SAC areas.”


pressure/threat are concerned with further investigation of the impact of light pollution on

the resident bat species.


by the Surrey WLP would impact upon the incidence and extent of light pollution within and

surrounding the SAC. The area of land covered by the SAC designation is situated beyond

the county of Surrey, so implementation of the Surrey WLP could not interfere directly or

indirectly with night-time light levels within the SAC as a consequence of development

within or adjacent to the SAC.


24




light pollution. No further assessment is required in respect of the disturbance impact

pathway.

2.D Conclusions

2.42 The assessment of the implications of the implementation of the Surrey WLP for the

ecological integrity of The Mens SAC has concluded that overall there would be no potential

for ‘likely significant effects’ to arise. None of the sites allocated under Policy 11 or the ILAS

identified under Policy 10 of the Surrey WLP are located within 10 kilometres of the SAC,

and it is unlikely that strategic waste management facilities of the types (i.e. thermal

treatment plants) with the potential to give rise to long range impacts would be brought

forward successfully on land that has not been identified as suitable for waste related

development by the Plan. In addition, Policy 14 (Development Management) of the Surrey

WLP provides protection for sensitive ecological sites at the planning application stage.

2.43 The assessment considered the six impact pathways identified as key threats and pressures

of concern with reference to the conservation objectives for the SAC. The conclusions

reached in respect of the likely impact of the Surrey WLP on the SAC via each pathway are

summarised in Table 2-B.

Table 2-B: Summary of assessment conclusions

Impact Pathway Conclusion Assessment

Level

Changes in forestry &

woodland management – see

section 2.C.1

No direct or indirect significant impacts on the SAC

likely to arise from implementation of the Surrey

WLP

Screening

Changes in habitat

connectivity – see section

2.C.2



WLP

Screening

Introduction or spread of

invasive species – see section

2.C.3



WLP

Screening

Changes in land management

– see section 2.C.4



WLP

Screening

Changes in air pollution

(deposition of atmospheric

nitrogen) – see section 2.C.5



WLP

Screening

Changes in public access

/disturbance – see section

2.C.6



WLP

Screening


25

2.E References

2.44 The following sources of information have been referred to as part of the assessment

process for The Mens SAC.

2.44.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna

and Flora: Citation for Special Area of Conservation (SAC) – The Mens SAC

(Natural England (English Nature), May 2005).

2.44.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the

EC Habitats Directive (includes candidate SACs, Sites of Community Importance

& designated SACs) – The Mens SAC (Joint Nature Conservation Committee

(JNCC), 25 January 2016).

2.44.3 European Site Conservation Objectives for The Mens Special Area of

Conservation (Site Code: UK0012716) (Natural England, 30 June 2014, v.2).

2.44.4 Site Improvement Plan: The Mens SAC (Natural England, 6 March 2015).

2.44.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source

Attribution section (http://www.apis.ac.uk/srcl ).

2.44.6 The Mens SSSI Condition Survey Report (Natural England, Designated Sites

website, accessed 30 May 2018).

2.44.7 Environment Agency Catchment Data Explorer website.

2.44.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,

June 2018

2.44.9 Habitat Regulations Assessment for the emerging Local Plan, URS for

Chichester District Council, May 2014

2.44.10 Habitat Regulations Assessment for the emerging Local Plan, AECOM for

Waverley Borough Council, 2016, 2017 and 2018.

http://www.apis.ac.uk/srcl

http://environment.data.gov.uk/catchment-planning/


26

Chapter 3 Woolmer Forest SAC



3.1 The Woolmer Forest SAC (see map) is located in Hampshire, and is composed of part of the

Woolmer Forest SSSI (1,298.52 hectares). The SAC covers an area of 666.68 hectares, as

stated on the SAC citation, and was designated on 1 April 2005. The SAC commences some

4.36 kilometres to the south west of the Surrey/Hampshire county boundary. The SAC is

situated within an area administered by the South Downs NPA, East Hampshire DC, and by

Hampshire CC. Within Surrey, the Waverley Borough Council area is located closest to the

SAC.

3.2 The SAC is bounded by a number of road links, including the following ‘A’ class roads.

3.2.1 The A3 (Portsmouth Road / London Road) – which passes through the

Woolmer Forest SSSI and adjoins the SAC designation.

3.2.2 The A325 (Petersfield Road / Farnham Road) – which passes through the

Woolmer Forest SSSI and adjoins the SAC designation.

3.3 The SAC is situated within a single surface water catchment, the Hollywater & Deadwater at

Bordon ( GB106039017690), which lies wholly outside the county of Surrey, and is not fed

by any upstream catchments that are situated in Surrey.


3.4 The Woolmer Forest SAC is not located within 10 kilometres of any of the six sites proposed

for allocation under Policy 11, or any of the twenty-two ILAS identified under Policy 10 of

the Surrey WLP (see Figure 3-A – a full size version can be found in Appendix A). The closest

proposed allocation is ‘Site 3 – Land to the north east of Slyfield Industrial Estate, Moorfield

Road, Guildford’, which lies some 26.7 kilometres to the north east of the SAC. The closest

ILAS (ILAS 20 – Coxbridge Business Park, Alton Road, Farnham), which lies some 12.9

kilometres to the north of the SAC. The SAC is, however, located within 4.4 kilometres of

the Surrey county boundary, and it is therefore possible that waste related development

could proceed within the county on land other than that proposed for allocation or

identified in the Surrey WLP, and be situated within 10 kilometres of the SAC.



27

Figure 3-A: Woolmer Forest SAC – Relationship to sites & ILAS proposed by the Surrey WLP




Plan are situated within 5 kilometres of the SAC. The HRAs undertaken in respect of all

three of those plans concluded that the ecological integrity of the SAC would not be

adversely affected by their implementation.

3.B Key Characteristics of the SAC

3.B.1 Reasons for Designation

3.6 The ecological interest of the SAC, and the particular habitats and species that are given as


Site Description

Woolmer Forest is located at the western end of the Weald. The majority lies on the coarse sands of the Folkestone beds. The drainage ditches & streams crossing the site have cut broad valleys into the sandy soils, interspersed with rounded hills & ridges.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Woolmer Forest SAC

Woolmer Forest SAC

Site 1: Oakleaf FarmSite 2: Weylands TWSite 3: Slyfield IESite 4: Leatherhead STWSite 5: Lambs BPSite 6: Trumps Farm

ILAS20

N

S

W E<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Woolmer Forest SAC

Woolmer Forest

SAC

N

S

W E

20 km

30 km

40 km

50 km

Site 6: Trumps Farm

Site 5: Lambs BP

Site 1: Oakleaf FarmSite 2: Weylands TW

Site 3: Slyfield IE


ILAS20

ILAS21

ILAS19

ILAS05; ILAS06;ILAS08;

ILAS07; ILAS17

ILAS01; ILAS09;ILAS10; ILAS15;ILAS22

ILAS02; ILAS03; ILAS04; ILAS11; ILAS16

ILAS12; ILAS13

ILAS14

ILAS18


28

Extensive areas of dry heathland vegetation occur on the tops of the hills & ridges. These areas are dominated by heather Calluna vulgaris & bell heather Erica cinerea, commonly with dwarf gorse Ulex minor, grasses such as wavy hair-grass Deschampsia flexuosa & sheep’s-fescue Festuca ovina, & a rich diversity of lichens. Humid heath occurs on less free-draining soils. It is dominated by heather & characterised by the presence of cross-leaved heath Erica tetralix & purple moor-grass Molinia caerulea.

Humid heath grades into areas of wet heath along the valley bottoms where both cross-leaved heath & purple moor-grass are abundant. These wet heath areas are also characterised by the presence of bog-mosses such as Sphagnum compactum, carnivorous plants such as round-leaved Drosera rotundifolia & oblong-leaved sundews D. intermedia, & common Eriophorum angustifolium & hare’s-tail cottongrasses E. vaginatum. A number of nationally scarce & uncommon plant species occur in patches of bare wet peat within the wet heath, often along tracks & pathways. These include the club-moss Lycopodiella inundata, white beak-sedge Rhynchospora alba & allseed Radiola linoides.

Within Woolmer Forest, Cranmer Pond is an example of an acid peat-stained pond. This 8 ha pond is thought to originate from peat-cutting, & has an average depth of 1m. The aquatic flora is comprised of bulbous rush Juncus bulbosus var. fluitans, which grows submerged & forms dense mats at the margins, & bog-mosses which grow in shallower areas. To the north & south of Cranmer Pond are areas of transition mires & quaking bogs.

Seepage mires & other waterlogged areas are minor features amongst predominantly wet heath habitat. Seepages are fed from a mix of acidic & calcareous sources, & give rise to a series of pool & hummock structures within the mire. White beak-sedge occurs along with a range of bog-mosses, common & hare’s-tail cottongrasses, bog asphodel Narthecium ossifragum, cranberry Vaccinium oxycoccos & the rare marsh clubmoss Lycopodiella inundata.

Qualifying Habitats


Depressions on peat substrates of the Rhynchosporion

European dry heaths

Natural dystrophic lakes & ponds. (Acid peat-stained lakes & ponds)

Northern Atlantic wet heaths with Erica tetralix. (Wet heathland with cross-leaved heath)

Transition mires & quaking bogs. (Very wet mires often identified by an unstable ‘quaking’ surface)





The extent & distribution of the qualifying natural habitats

The structure & function (including typical species) of the qualifying natural habitats, &,

The supporting processes on which the qualifying natural habitats rely


29

Qualifying Features

H3160. Natural dystrophic lakes & ponds; Acid peat-stained lakes & ponds

H4010. Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath

H4030. European dry heaths

H7140. Transition mires & quaking bogs; Very wet mires often identified by an unstable `quaking` surface

H7150. Depressions on peat substrates of the Rhynchosporion

3.B.3 Condition


report for the Woolmer Forest SSSI7 (see Table 3-A), that designated site extends to some

1,298.52 hectares, of which some 670.21 hectares is covered by the SAC designation. Those

SSSI units that are covered by the SAC designation are listed below.

Units in ‘Favourable’ Condition

Unit 17 112.88 ha Lowland dwarf shrub heath habitat

Unit 18 1.14 ha Standing open water & canals habitat

Unit 19 1.66 ha Standing open water & canals habitat



Unit 29 109.08 ha Coniferous woodland habitat

Unit 30 35.25 ha Coniferous woodland habitat

Units in ‘Unfavourable – recovering’ Condition

Unit 21 26.28 ha Lowland broadleaved, mixed & yew woodland habitat







3.9 The most recent condition survey results for those units of the SSSI (see Table 3-A for a

summary) covered by the SAC designation indicates that 64.4% of the SAC is in ‘favourable’

condition, 35.6% is in ‘unfavourable – recovering’ condition, and 35.6% is in ‘unfavourable –

no change’ condition. The SAC is composed of four main habitat types, ‘lowland dwarf

shrub heath’ (496.80 hectares), ‘coniferous woodland’ (144.33 hectares), ‘broadleaved,

7 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004188&ReportTitle=Woolmer%20Forest%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004188&ReportTitle=Woolmer%20Forest%20SSSI


30

mixed & yew woodland’ (26.28 hectares), and ‘standing open water & canals’ (2.80

hectares).

Table 3-A: Woolmer Forest SAC – Condition Survey Findings

Main Habitat Type Condition Classification

Favourable Unfavourable – Recovering

Dwarf shrub heath – lowland 496.80 ha

(74.1%)

258.33 ha

(38.5%)

238.47 ha

(35.6%)

Coniferous woodland 144.33 ha

(%)

144.33 ha

(21.5%)

0.0 ha

(0.0%)

Broadleaved, mixed & yew woodland – lowland

26.28 ha

(%)

26.28 ha

(3.9%)

0.0 ha

(0.0%)

Standing open water & canals 2.80 ha

(%)

2.80 ha

(0.4%)

0.0 ha

(0.0%)

Totals 670.21 ha 431.74 ha

(64.4%)

238.47 ha

(35.6%)


3.10 The published Site Improvement Plan (SIP) for the SAC (23 October 2014) for identifies the


Changes in land management practices – discussed in section 3.C.1;

Introduction or spread of invasive species – discussed in section 3.C.2;

Changes in local hydrology – discussed in section 3.C.3;

Changes in the location, extent and condition of the features for which the SAC is

designated – discussed in section 3.C.4;

Changes in military use of the land – discussed in section 3.C.5;

Changes in air pollution (deposition of atmospheric nitrogen) – discussed in section

3.C.6;

Changes in the risks of wildfire / arson – discussed in section 3.C.7;


3.11 The features affected by changes in land management practices are the wet heathland with

cross-leaved heath (H4010), European dry heaths (H4030), very wet mires often identified

by an unstable `quaking` surface (H7140), and depressions on peat substrates (H7150). The

SIP (pp.4/15 to 5/15) offers the following explanation of the nature of the identified threat:

“Parts of the complex have suffered from management neglect in the past & there are

ongoing management issues. Common issues are lack of structural diversity, bracken

encroachment & scrub development. Grazing is not practical in parts of the complex but viable


31

alternative means of management to meet objectives are not yet in place. Grazing may also

be constrained in parts because of resistance to fencing of common land.”


concerned with:

Improving habitat management to deliver effective heather management, scrub

control and bracken control.

Establishing site-based partnerships to improve communication over management

priorities and to advise and agree on annual work programmes.

Making changes to existing Higher Level Stewardship agreements in order to fit with

impending changes in use of military training areas.

Investigating possible biomass to bioenergy use of material produced as a result of

annual cutting of vegetation.


by the Surrey WLP would impact upon current or future land management practices within

the SAC. The only points at which the land management regime implemented across the

SAC may interface with waste management operations and practices would be in respect of

a need for the removal and appropriate management of the waste materials that will arise

from time to time as a consequence of active habitat management (e.g. green waste from

scrub clearance, disposal of fallen stock, etc.). The provision of additional waste

management capacity within the county of Surrey would be unlikely to be provided in close

enough proximity to the majority of the SAC to be of significant benefit to the ongoing

management of its habitats.




on the SAC. No further assessment is required in respect of the changes in land

management impact pathway.

3.C.2 Invasive Species

3.15 The features affected by the incursion of invasive plant species (Crassula helmsii) are the

acid peat-stained lakes and ponds (H3160). The SIP (p.5/15) offers the following

explanation of the nature of the identified pressure:

“Ponds & wetlands at Woolmer Forest are dominated by Crassula helmsii, adversely affecting

habitat quality. Control is particularly difficult because of presence of rare amphibians. It is

currently unclear to what extent the presence of Crassula is adversely affecting the dystrophic

lake interest feature & indeed whether effective control is feasible.”


32

3.16 The actions that have been identified as the principal means of addressing the pressure are

concerned with investigating the ecological impacts of Crassula helmsii on the dystrophic

pond and wet heath features and evaluating options for control, implementing control

measures to reduce the dominance of the invasive species, dependent on the outcome of

investigations and taking account of the need to protect natterjack toad and invertebrate

populations.


by the Surrey WLP could act to introduce invasive plant species into the SAC. The area of

land covered by the SAC designation is situated beyond the county of Surrey, so could not

be affected by any waste related development brought forward under the Surrey WLP, as

no new facilities would be situated in sufficiently close proximity to the SAC to act as a

source from which invasive plant species could be spread (e.g. green waste arising from

domestic gardens and horticultural businesses).





the changes in the invasive species impact pathway.

3.C.3 Hydrological changes

3.19 The feature affected by changes in hydrology is the wet heathland with cross-leaved heath

(H4010). The SIP (p.6/15) offers the following explanation of the nature of the identified

pressure:

“Parts of the wet heath & mire areas at Woolmer Forest are affected by the presence of

drainage ditches. The full impact of these has not yet been assessed but it is likely that they

are having adverse impacts.”


concerned with investigating and characterising the hydrological regime of the mires and

the potential implications of reversing the effects of drainage, preparing habitat restoration

plans for those mires affected by drainage, and implementing the mire restoration plans.


by the Surrey WLP would impact upon the hydrology of the habitats within the SAC. None

of the surface water catchments (see section 3.A.1 of this report) that coincide with the

SAC extend into Surrey, or are fed by waterbodies situated within Surrey. In respect of

surface waters, the SAC is hydrologically isolated from any areas of land within Surrey that

could be affected by waste related development.


33



would not give rise to direct or indirect significant impacts on the hydrology of the SAC or

the surrounding area. No further assessment is required in respect of the changes in

hydrology impact pathway.

3.C.4 Monitoring of Feature Location, Extent & Condition

3.23 The features affected are the acid peat-stained lakes and ponds (H3160), the wet heathland

with cross-leaved heath (H4010), the European dry heaths (H4030), and the very wet mires

often identified by an unstable `quaking` surface (H7140). The SIP (p.7/15) offers the

following explanation of the nature of the identified pressure:

“Work is needed by Natural England to clarify the conservation objectives for designated

features at Woolmer Forest, to improve the evidence base on the interest features, to identify

where these occur, & to provide greater linkage between objectives & military training use.”


concerned with commissioning a study to identify the core areas utilised by Annex 1 birds

for breeding and feeding, and to identify priorities for habitat enhancement, and providing

clear advice on nature conservation objectives and habitat management priorities.

3.25 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,

either negatively or positively, on the availability of information about the functioning of

the habitats that comprise the SAC. The Surrey WLP is concerned with the provision of

additional waste management capacity over the 15 year plan period, to meet identified

current and future gaps in capacity, and would present limited opportunities for the

collection of ecological data associated with the proposed development of specific sites or

areas of land within Surrey. None of the sites proposed for development under Policy 11 or

the ILAS identified under Policy 10 of the Surrey WLP are located within, or in close

proximity to (<2.5 kilometres), the SAC.



would not give rise to direct or indirect significant impacts on the SAC with reference to the

monitoring and ongoing evaluation of the SAC habitats. No further assessment is required

in respect of the feature of interest monitoring impact pathway.

3.C.5 Military Activities / Uses 3.27 The features affected by changes in military activities and uses are the acid peat-stained

lakes and ponds (H3160), the wet heathland with cross-leaved heath (H4010), European dry

heaths (H4030), and the very wet mires often identified by an unstable `quaking` surface

(H7140). The SIP (p.8/15) offers the following explanation of the nature of the identified

pressure:


34

“There is currently poor coordination between management for military training purposes &

nature conservation management at Woolmer Forest & scope for significant gains with closer

working between partners. The production of an integrated management plan is needed.”


concerned with preparing and implementing integrated management plans for military

training areas.


either negatively or positively, on the ways in which the Ministry of Defence (MoD)

manages those areas of land that it owns within the SAC designation. The Surrey WLP is

concerned with the provision of additional waste management capacity over the 15 year

plan period, to meet identified current and future gaps in capacity, and has no locus to

influence the land use management practices employed by the military on MoD land.




use of land within the SAC designation for military purposes. No further assessment is

required in respect of the military uses and activities impact pathway.

3.C.6 Air pollution: impact of atmospheric nitrogen deposition 3.31 The features affected by changes in nutrient nitrogen deposition from the atmosphere are

the wet heathland with cross-leaved heath (H4010), the European dry heaths (H4030), the

very wet mires often identified by an unstable ‘quaking’ surface (H7140), and the

depressions on peat substrates (H7150). The SIP (p.8/15) offers the following explanation of

the nature of the identified pressure:

“Nitrogen deposition exceeds the site-relevant critical load for ecosystem protection. The

aerial pollution may be promoting changes in species composition of mires towards Molinia &

sedge dominated systems rather than Sphagnum dominated; ponds may be losing

characteristic aquatic plant assemblage partly because of increasing nutrient status. This most

likely to be an issue at Woolmer Forest but could be a chronic problem at all sites in the

complex.”


concerned with controlling and reducing nitrogen emissions and deposition, and with

ameliorating the impacts of that deposition.







35

3.34 In terms of the potential for point source emissions from waste management facilities there

is no risk of development at any of the six sites proposed for allocation under Policy 11 of

the Surrey WLP giving rise to nutrient nitrogen deposition within the SAC, alone or in-

combination, at concentrations that would exceed 1% of the site relevant critical loads for

the SAC habitats (see below).

For the natural dystrophic lakes and ponds habitat the minimum site relevant critical

load for nutrient nitrogen is 3 kg/N/ha/yr.

For the transition mires and quaking bogs habitat the minimum site relevant critical

load for nutrient nitrogen is 10kg N/ha/yr.

For the depressions on peat substrates of the Rhyncosporion habitat the minimum site

relevant critical load for nutrient nitrogen is 10kg N/ha/yr.

For the wet heath with Erica tetralix the minimum site relevant critical load for

nutrient nitrogen is 10kg N/ha/yr.

For the dry heath the minimum site relevant critical load for nutrient nitrogen is 10kg

N/ha/yr.

3.35 The closest proposed site allocation (Site 3 – Land NE of Slyfield IE, Guildford) is located

some 26.7 kilometres to the north east of the SAC, and the closest ILAS (ILAS20 – Coxbridge

BP, Farnham) is some 12.9 kilometres to the north. Both are beyond the distance (10

kilometres) for which detailed assessment would be required by the Environment Agency

as part of the Environmental Permit consenting process. Any contribution that emissions

from a thermal treatment facility situated at either the closest allocated site (Site 3 – Land

NE of Slyfield IE, Guildford) or the closest ILAS (ILAS20 – Coxbridge BP, Farnham) would

make to nitrogen deposition at the SAC would be undetectable.


land situated within Surrey other than the proposed allocated sites or the identified ILAS,

which could include land situated within 10 kilometres of the SAC. However, all of the land

situated in Surrey that lies within 10 kilometres of the SAC is covered by the Metropolitan

Green Belt designation, and the policy approach for the Surrey WLP does not prefer non-

allocated Green Belt land over allocated Green Belt sites. It is therefore unlikely that a

strategic waste management facility, as a large scale (c.150,000 tonnes per annum or

greater capacity) thermal treatment plant would be classed, would be sited on unallocated

land within 10 kilometres of the SAC. In addition, Policy 14 of the Surrey WLP requires that

all waste related planning applications be supported by sufficient information for the Waste

Planning Authority to be able to ascertain whether the proposed development would result

in significant adverse impacts on the natural environment, including SACs. Policy 14 also

limits the grant of planning permission to those developments that have been

demonstrated to have no significant adverse impacts on the environment, which includes

significant impacts on SACs.


36


development at the closest proposed site allocation (Site 3 – Land NE of Slyfield IE,

Guildford) could travel along the section of the A3 that passes through the SAC to the south

west of Hindhead in Surrey. For that allocated site (Site 3), the Transport Study undertaken

for the Surrey WLP reports that development of a large scale (c. 300,000 tpa capacity)

energy from waste (EfW) facility would result in a 6% (838 additional vehicle movements)

increase in annual average daily traffic (AADT) on the section of the A320 (Woking Road)

closest to that proposed site (Waste Local Plan – Transport Study: Site Assessments, Table

3.1, p.20). Section 3.3 (p.21) of the Transport Study predicts that traffic generated by any

waste related development on the Slyfield Industrial Estate site would disperse to the

strategic road network south down the A320 to the A3. For the section of the A3 that

passes through the SAC to the south west of the Surrey/Hampshire boundary the reported

AADT for 2017 (Department for Transport Count Point 99197, A3 – Surrey/Hampshire

boundary to A325), is 38,695 vehicles. If all traffic from the proposed site allocation were to

travel along the section of the A3 to the south west of Hindhead that would equate to an

additional 838 vehicles (a 2.2% change in AADT) on the section of that road that passes

through the SAC, which is close to the 1,000 AADT threshold cited in the Design Manual for

Roads & Bridges (Volume 11, Section 3, May 2007). On a precautionary basis, and assuming

the worst case scenario for the development of the proposed site allocation (i.e. c.300,000

tpa capacity energy from waste plant), further consideration needs to be given to the

question of likely significant effects on the SAC from transport emissions.


at any of the ILAS identified under Policy 10 of the Surrey WLP on traffic levels on the local

or strategic road networks. Three of the identified ILAS (ILAS05 – Slyfield IE, Guildford;

ILAS06 – Woodbridge Meadows IE, Guildford; ILAS08 – Riverwey IE, Astolat BP & Weyvern

Park, Peasmarsh) are situated such that waste related development at those locations

could contribute to additional traffic on the A3. Should waste related development of any

scale proceed at one or more of ILAS05, ILAS06 or ILAS08, the traffic generated could act in-

combination with that arising from a strategic waste facility located on the allocated site in

Guildford (Site 3).



consequence of emissions from point sources (waste facilities). However, the potential for

indirect significant impacts as a consequence of diffuse pollution (from traffic arising from

waste related development) cannot be ruled out at the screening stage. Further assessment

is required in respect of the air pollution (emission and deposit of nutrient nitrogen) impact

pathway in respect of traffic emissions from one of the proposed allocated sites.


37

3.C.7 Wildfire / Arson 3.40 The features affected by the incidence of wildfire or arson are the wet heathland with

cross-leaved heath (H4010), the European dry heaths (H4030), and the very wet mires

often identified by an unstable ‘quaking’ surface (H7140). The SIP (p.8/15) offers the

following explanation of the nature of the identified threat:

“Wildfire is a natural hazard identified in the National Risk Assessment / Register &

Community Risk Registers. Wildfires in the south of England are likely to increase as identified

in the Climate Change Risk Assessment (CCRA). Wildfires can be a serious risk to human life,

residential & commercial property & critical national infrastructures, as well as being a high

risk threat to reptile populations, inverts & plant diversity resulting in significant habitat loss

for Annex 1 birds. Open heath is the predominant risk (dry & wet heath, peat habitats) as well

as young coniferous woodland. Impacts can last for many years for example by the wholesale

removal of all gorse & heather seedbank.”


concerned with completing wildfire risk assessments for all sites and preparing and

implementing wildfire management plans, and with embedding wildfire mitigation and

adaptation into local authority Local Development Plan policies and community risk

registers.


by the Surrey WLP would impact upon current or future fire management practices within

the SAC.

3.43 It is conceivable that certain types of waste management facility could present a fire risk to

designated sites, where those facilities were located in close proximity to the sensitive

habitats. There have been incidences of significant fires at waste recycling and storage

facilities that handle household, industrial and commercial wastes, and there have been

cases of spontaneous combustion occurring at green waste composting facilities due to

inappropriate stockpiling and management of the waste materials. None of the sites

proposed for allocation or the ILAS identified in the emerging Surrey WLP are in close

enough proximity to the SAC to present a genuine fire risk, and the land surrounding the

SAC lies outside the county of Surrey, and therefore beyond the influence of the Surrey

WLP. Land within Surrey in closer proximity to the SAC than the closest proposed site

allocation or identified ILAS falls within the Metropolitan Green Belt. It is therefore unlikely

that waste related development would be brought forward on non-allocated land in closer

proximity to the SAC than the closest proposed site allocation or identified ILAS, as strategic

waste management facilities would typically be classed as inappropriate development in a

Green Belt context.



would not give rise to direct or indirect significant impacts on fire management practices

within the SAC, and although waste related development could, in theory, present a fire


38

risk to the SAC, the site allocations proposed and ILAS identified are too distant to present a

credible threat and the Green Belt status of the land within Surrey closest to the SAC limits

the probability of waste development being brought forward in close proximity to the

sensitive habitats. No further assessment is required in respect of the wildfire and arson

impact pathway.

3.D Assessment of likely significant effects 3.45 The screening assessment has identified a single pathway (air pollution – atmospheric

deposition of nitrogen) by which waste related development at one of the sites proposed

for allocation (Site 3 – Land NE of Slyfield IE, Guildford’) and three of the ILAS (ILAS05;

ILAS06; ILAS08) identified in the Surrey WLP could potentially contribute to likely significant

effects on the SAC. The mechanism by which the development of the allocated site and the

three ILAS would contribute to the deposit of nutrient nitrogen on the SAC would be diffuse

pollution from traffic generated by the development and operation of waste management

facilities.

3.46 The worst case scenario for the development of the proposed site allocation (Site 3) is for a

c.300,000 tpa capacity energy from waste plant, generating an additional 838 vehicle

movements per day, which for the purposes of screening it has been assumed would all

travel to and from the facility on the section of the A3 that passes through the SAC. In

practice it is more likely that vehicles generated by any facility would disperse both north

and south along the A3. In combination with the development of Site 3, it is assumed that

smaller scale (50,000 tpa) waste management facilities would be constructed at all three

ILAS generating an additional 120 two-way vehicle movements per day (40 movements per

facility), and that all traffic would travel along the section of the A3 that passes through the

SAC.

3.47 In practice, development of the allocated site (Site 3) would not involve the construction

and operation of a large scale EfW facility with a c.300,000 tpa capacity. The allocated site

lies within a priority area for redevelopment identified in the Guildford BC Local Plan. Under

the Slyfield Area Regeneration Programme, the proposed Surrey WLP allocation would

accommodate a replacement sewage treatment works for Guildford, the current site of

which would then be redeveloped as housing, and a replacement community recycling

centre and waste transfer station, the current site of which would then be redeveloped for

industrial and commercial use. The site allocated under Policy 11 of the Surrey WLP also

encompasses an area of land safeguarded as the potential route of a new link road that

would connect the Slyfield area to Clay Lane to the north. There would be limited space left

on the allocated site to accommodate any additional waste management capacity.

3.48 The use of the allocated site (Site 3) to accommodate facilities that would replace existing

waste related development currently situated in the Slyfield area, that is to be displaced by

housing, industrial and commercial development as part of the Slyfield Area Regeneration

Plan, would be unlikely to substantially alter the volumes of operational traffic generated


39

by those facilities. Consequently there would be no discernible change in the contribution

that the waste related development currently situated on the Slyfield industrial estate

makes to traffic volumes on the section of the A3 that passes through the SAC. In practice it

is also unlikely that new waste management facilities would be developed on all three of

ILAS05, ILAS06 and ILAS08, or that traffic from any facilities that may be developed would

travel to and from those locations exclusively via the section of the A3 that passes through

the SAC.

3.49 The published HRA reports (URS, 2012 and 2013) for the East Hampshire DC Local Plan

concluded that implementation of the policies and proposals set out in that plan, subject to

deployment of the specified mitigation measures, would not give rise to significant effects

on the ecological integrity of the SAC, alone or in-combination. The published HRA reports

(AECOM, 2016, 2017 and 2018) for the Waverley BC Local Plan concluded that

implementation of the policies and proposals set out in Parts 1 and 2 of that plan, subject

to deployment of the specified mitigation measures, would not give rise to significant

effects on the ecological integrity of the SAC alone or in-combination.

3.50 It is concluded that allocation of Site 3 (Land NE of Slyfield IE, Moorfield Road, Guildford)

and identification of three ILAS (ILAS05 – Slyfield IE, Guildford; ILAS06 – Woodbridge

Meadows IE, Guildford; ILAS08 – Riverwey IE, Astolat BP & Weyvern Park, Peasmarsh) for

waste related development in the Surrey WLP would not give rise to significant impacts on

the integrity of the SAC as a consequence of the deposition of nutrient nitrogen from traffic

emissions.

3.E Conclusions


ecological integrity of the Woolmer Forest SAC has concluded that overall there would be

no potential for ‘likely significant effects’ to arise. None of the sites allocated under Policy

11 or the ILAS identified under Policy 10 of the Surrey WLP are located within 10 kilometres

of the SAC, and it is unlikely that strategic waste management facilities of the types (i.e.

thermal treatment plants) with the potential to give rise to long range impacts would be

brought forward successfully on land that has not been identified as suitable for waste

related development by the Plan. The SAC is dissected by a section of the A3 road, and the

A3 would also likely be a major transport link for one of the allocated sites (Site 3: Land

north east of Slyfield IE, Guildford) and three of the ILAS (ILAS05; ILAS06; ILAS08) identified

in the Surrey WLP. However, it is unlikely that 100% of traffic from that allocated site and

those three ILAS would travel along the section of the A3 that passes through the A3. In

addition, Policy 14 (Development Management) of the Surrey WLP provides protection for

sensitive ecological sites at the planning application stage.

3.52 The assessment considered the seven impact pathways identified as key threats and

pressures of concern with reference to the conservation objectives for the SAC. The

conclusions reached in respect of the likely impact of the Surrey WLP on the SAC via each

pathway are summarised in Table 3-B.


40



Level


practices – discussed in

section 3.C.1



WLP

Screening


invasive species – discussed

in section 3.C.2



WLP

Screening

Changes in local hydrology –

discussed in section 3.C.3



WLP

Screening

Changes in the location,

extent and condition of the

features for which the SAC is

designated – discussed in

section 3.C.4



WLP

Screening

Changes in military use of the

land – discussed in section

3.C.5



WLP

Screening



nitrogen) – discussed in

section 3.C.6 & section 3.D

One allocated site (Site 3) and three ILAS (ILAS05,

ILAS06, ILAS06) could give rise to additional traffic

on the A3. Potential for adverse impacts from

nutrient nitrogen deposition arising from traffic

emissions.

Traffic emissions unlikely to be major source of

additional deposition within the SAC – likely to

disperse to the wider network, unlikely that 100%

of traffic servicing Site 3 and the three ILAS would

travel along the section of the A3 that passes

through Woolmer Forest.

Overall conclusion of no likely significant impacts

on the SAC.

Screening

(Process

Emissions)

Assessment

of Likely

Significant

Effects

(Traffic

Emissions)

Changes in the risks of

wildfire / arson – discussed in

section 3.C.7



WLP

Screening

3.F References


process for the Woolmer Forest SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Woolmer Forest

SAC (Natural England (English Nature), May 2005).


41



& designated SACs) – Woolmer Forest SAC (Joint Nature Conservation

Committee (JNCC), 25 January 2016).

3.53.3 European Site Conservation Objectives for Ashdown Forest Special Area of


3.53.4 Site Improvement Plan: Woolmer Forest SAC & Wealden Heaths Phase 2 SPA

(Natural England, 23 October 2014).



3.53.6 Woolmer Forest SSSI Condition Survey Report (Natural England, Designated

Sites website, accessed 30 May 2018).



June 2018

3.53.9 Habitat Regulations Assessment for the emerging Local Plan, URS for East

Hampshire District Council, 2012 and 2013



3.53.11 Design Manual for Roads & Bridges, Volume 11 (Environmental Assessment),

Section 7 (Environmental Assessment Techniques), Highways England, May

2007.




42

Part B Assessment for European Sites <10km from development locations identified in the Surrey WLP

Part B of the HRA report deals with those European Sites that are located within 10 kilometres of one or more of the sites proposed for allocation under Policy 11 or any of the ILAS identified under Policy 10 of the Surrey WLP. The following SACS and SPAs are covered by the chapters that comprise this part of the HRA report.

Chapter 4 Ashdown Forest SAC

Chapter 5 Ashdown Forest SPA

Chapter 6 East Hampshire Hangers SAC

Chapter 7 Ebernoe Common SAC

Chapter 8 Mole Gap to Reigate Escarpment SAC

Chapter 9 Richmond Park SAC

Chapter 10 Shortheath Common SAC

Chapter 11 South West London Waterbodies SPA

Chapter 12 Thames Basin Heaths SPA

Chapter 13 Thursley, Ash, Pirbright & Chobham SAC

Chapter 14 Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA

Chapter 15 Wealden Heaths Phase 2 SPA

Chapter 16 Wimbledon Common SAC

Chapter 17 Windsor Forest & Great Park SAC


43

This page is left intentionally blank


44

Chapter 4: Ashdown Forest SAC


4.A.1 Location of the SAC 4.1 The Ashdown Forest SAC (see map) is located in the county of East Sussex, and lies some

5.8 kilometres to the south of the East Sussex / Surrey boundary. The SAC designation

covers parts of the area of land also covered by the Ashdown Forest SSSI designation.

According to the SAC citation, the designation extends across an area of 2,729 hectares,

and was designated on 1 April 2005. The SAC is situated within an area administered by

Wealden DC and by East Sussex CC. Within Surrey, the Tandridge DC area is located closest

to the SAC.

4.2 The SAC is dissected by a number of road links, including the following ‘A’ class roads.

4.2.1 The A22 (Eastbourne Road / Lewes Road) – which passes through the SAC.

4.2.2 The A275 (Lewes Road) – which passes through the SAC.

4.2.3 The A26 (Uckfield Road) – which passes along the south eastern boundary of

the SAC.

4.3 The SAC is situated across a number of different surface water catchments, none of which

lie wholly or partly within the county of Surrey, and none of which are fed by upstream

catchments that are situated in Surrey.

4.3.1 The Shortbridge Stream (GB107041012980).

4.3.2 The Pippingford Brook (GB106040018360).

4.3.3 The Medway at Weir Wood (GB106040018070).

4.3.4 The Friars Gate Stream (GB107041012980).

4.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC 4.4 The Ashdown Forest SAC is not located within 10 kilometres of any of the sites proposed for

allocation under Policy 11 of the Surrey WLP (see Figure 4-A – a full size version can be

found in Appendix A). The closest proposed allocation is Site 5 (Land to the west of Lambs

Business Park, Terra Cotta Road, South Godstone), which lies some 15.6 kilometres to the

north west of the SAC. The SAC is located within 10 kilometres of one of the ILAS (ILAS18 –

Hobbs Industrial Estate, Felbridge) identified under Policy 10 of the Surrey Waste Local Plan

(see Figure 4-A). The Plan does not specify the type or scale of waste related development

that could be accommodated on the identified ILAS.



45

Figure 4-A: Ashdown Forest SAC – Relationship to sites & ILAS proposed by the Surrey WLP




Plan are situated within 5 kilometres of the SAC. The Habitat Regulations Assessments

undertaken in respect of all three of those plans concluded that the ecological integrity of

the SAC would not be adversely affected by their implementation.




Site Description: Ashdown Forest contains one of the largest single continuous blocks of lowland heath in south-east England, with both dry heaths &, in a larger proportion, wet heath. The wet heath element provides suitable conditions for several species of bog-mosses Sphagnum spp., bog asphodel Narthecium ossifragum, deergrass Trichophorum cespitosum, common cotton-grass Eriophorum angustifolium, marsh gentian Gentiana pneumonanthe & marsh clubmoss Lycopodiella inundata. The site supports important assemblages of beetles, dragonflies, damselflies & butterflies, including the nationally rare silver-studded blue Plebejus argus.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Ashdown Forest SAC

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Ashdown Forest SAC

ILAS18

N

S

W E

Site 5: Lambs BP


Site 2: Weylands TWSite 3: Slyfield IE

Site 1: Oakleaf FarmSite 6: Trumps Farm

ILAS04

ILAS19

ILAS10 ILAS13ILAS12

ILAS21ILAS20

ILAS08


ILAS01; ILAS02;ILAS03; ILAS05;ILAS06; ILAS09;ILAS15; ILAS16;ILAS22

ILAS11

20 km

30 km

50 km

40 km


46

The dry heath in Ashdown Forest is dominated by heather Calluna vulgaris, bell heather Erica cinerea & dwarf gorse Ulex minor, with transitions to other habitats. It supports important lichen assemblages, including species such as Pycnothelia papillaria. This site supports the most inland remaining population of hairy greenweed Genista pilosa in Britain.

The damming of streams, digging for marl, & quarrying have produced several large ponds in a number of areas of the forest. Although often largely free of aquatic vegetation there may be localised rafts of broadleaved pondweed Potamogeton natans, beds of reedmace Typha latifolia & water horsetail Equisetum fluviatile. These species are particularly abundant in the marl pits. Some of the ponds have large amphibian populations, including the great-crested newt Triturus cristatus.

Qualifying Habitats: The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:

European dry heaths.


Qualifying Species: The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:

Great crested newt Triturus cristatus

4.B.2 Conservation Objectives 4.7 The published conservation objectives for the SAC are given below.

Conservation Objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;

The extent & distribution of qualifying natural habitats & habitats of qualifying species;

The structure & function (including typical species) of qualifying natural habitats;

The structure & function of the habitats of qualifying species;

The supporting processes on which qualifying natural habitats & the habitats of qualifying species rely;

The populations of qualifying species; &


Qualifying Features

H4010. Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath.

H4030. European dry heaths.

S1166. Triturus cristatus; Great crested newt.

4.B.3 Condition 4.8 Based on the information published by Natural England in the most recent condition survey

report for the Ashdown Forest SSSI8 (see Table 4-A for a summary), the designated site

extends to some 3,213.09 hectares, divided into 127 units. Some 20.31% (652.64 hectares)

of the SSSI is in ‘favourable’ condition, some 79.29% (2,547.55 hectares) is in ‘unfavourable

– recovering’ condition, and some 0.40% (12.93 hectares) is in ‘unfavourable – declining’

8 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001983&ReportTitle=Ashdown%20Forest%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001983&ReportTitle=Ashdown%20Forest%20SSSI


47

condition. The SSSI is composed of two main habitat types, ‘broadleaved, mixed and yew

woodland – lowland’ (1,150.45 hectares) and ‘dwarf shrub heath – lowland’ (2,062.67

hectares).

Table 4-A: Ashdown Forest SSSI – Condition Survey Findings

Main Habitat Type



Recovering Unfavourable –

Declining

Broadleaved, Mixed & Yew Woodland –

Lowland

1150.45 ha

(35.80%)

463.32 ha

(14.42%)

674.19 ha

(20.98%)

12.93

(0.40%)

Dwarf Shrub Heath - Lowland

2062.67

(64.19%)

189.31 ha

(5.89%)

1873.36 ha

(58.30%)

0.00 ha

(0.00%)

Total 3213.12 652.63 ha

(20.31%)

2547.55 ha

(79.29 %)

12.93 ha

(0.40%)

4.9 The SAC designation does not cover the whole of the SSSI, those units wholly or partly

excluded from the SAC are listed in Table 4-B.

Table 4-B: Ashdown Forest SSSI Units not covered by the SAC designation

Main Habitat Type




Declining


Lowland

11 units Units 80, 95 (part), 160

& 161 Units 96, 97, 132, 154,

158 & 159 Unit 155

489.64 ha 26.63 ha 450.08 ha 12.93 ha

4.10 For Unit 155, which was found to be in ‘unfavourable – declining’ condition, the reasons

given in the condition survey report for the poor condition of the unit were

grazing/browsing by deer, and inappropriate forestry management and scrub control.


4.11 The published Site Improvement Plan (SIP) (24 November 2014) for the SAC identifies the


Change in land management – discussed further in section 4.C.1;

Air pollution: impact of atmospheric nitrogen deposition – discussed further in section

4.C.2;

Hydrological changes – discussed further in section 4.C.3.


48

4.12 Those three pressures and threats define the main pathways by which adverse impacts

could arise and compromise the ecological integrity of the SAC, and therefore form the

basis of the screening stage of the HRA for the Surrey WLP in respect of the Ashdown

Forest SAC.


4.13 The features affected by changes in land management within the area of land covered by

the SAC designation are the wet heathland with cross-leaved heath (H4010), and the

European dry heaths (H4030). The SIP (p.3/9) offers the following explanation of the nature

of the identified pressure:

“Only one third of the heathland is currently grazed. Favourable condition requires a diverse

vegetation structure & grazing, in combination with some mechanical management, can

achieve this. The heathland would be improved by more cattle, less sheep & a few ponies. The

ability to target animals to specific areas would also be beneficial to the heathland. The sheep

will often tend to congregate close to the roads & their tight grazing has resulted in a grass

dominated sward in these areas, with some areas further away from the roads only lightly

grazed & dominated with Molinia tussocks.”

4.14 The actions identified in the SIP as the principal means of addressing the pressure are

concerned with establishing and maintaining appropriate grazing and land management

regimes across the SAC.


by the Surrey WLP would impact upon current or future grazing practices within the

Ashdown Forest SAC. The area of land covered by the SAC designation is situated beyond

the county of Surrey, so could not be affected by direct land take associated with the

implementation of the Surrey WLP.

4.16 The only points at which the land management regime implemented across the SAC may

interface with waste management operations and practices would be in respect of a need

for the removal and appropriate management of the waste materials that will arise from

time to time as a consequence of active habitat management (e.g. green waste from scrub

clearance, disposal of fallen stock, etc.). The provision of additional waste management


proximity to the SAC to be of significant benefit to the ongoing management of the

designated habitats. Wastes arising from the management of the SAC would more likely be

dealt with by facilities situated in East Sussex or West Sussex.


development of sites allocated under Policy 11 or the ILAS identified under Policy 10, would

not give rise to direct or indirect significant impacts on land management practices across

the SAC. No further assessment is required in respect of the changes in land management

impact pathway.


49


4.18 The features affected are the wet heathland with cross-leaved heath (H4010), and the

European dry heaths (H4030). The SIP (p.3/9) offers the following explanation of the nature


“Nitrogen deposition exceeds site relevant critical loads. Vegetation is becoming increasingly

grass dominated where previously it was heather dominated.”


concerned with controlling and reducing nitrogen emissions and the deposition of nitrogen,

and with ameliorating the impacts of that deposition.






4.21 In terms of the potential for emissions from waste management facilities there is no risk of

development at any of the six sites proposed for allocation under Policy 11 of the Surrey

WLP giving rise to nutrient nitrogen deposition within the SAC at concentrations that would

exceed 1% of the site relevant minimum critical loads (see Part B-2, Appendix B) for the

heathland habitats alone or in-combination. The closest site allocation (Site 5 – Lambs BP,

South Godstone) is 15.5 kilometres to the north west of the SAC, and beyond the distance

(10 kilometres) for which detailed assessment would be required by the Environment

Agency as part of the Environmental Permit consenting process. Any contribution that

emissions from a thermal treatment facility at the closest allocated site would make to

nitrogen deposition at the SAC would be undetectable.

4.22 One of the ILAS (ILAS18 – Hobbs IE, Felbridge) identified under Policy 10 of the Surrey WLP

is located within 10 kilometres of the SAC (8.6 kilometres to the north west). The

development of a thermal treatment facility on land located within ILAS18 could, in theory,

present a risk of nutrient nitrogen deposition on land within the SAC.


land situated within Surrey other than the allocated sites and identified ILAS, which could

include land situated within 10 kilometres of the SAC. However, all of the land situated in

Surrey that lies within 10 kilometres of the SAC is covered by the Metropolitan Green Belt

designation, and the policy approach for the Surrey WLP does not prefer non-allocated

Green Belt land over allocated Green Belt sites or identified ILAS. It is therefore unlikely

that a strategic waste management facility, as a large scale (c.150,000 tonnes per annum or

greater capacity) thermal treatment plant would be classed, would be sited on unallocated

land within 10 kilometres of the SAC.


50


development in Surrey would be unlikely to travel along the section of the A22 that passes

through the SAC. For the closest proposed site allocation (Site 5 –Lambs BP, South

Godstone), the Transport Study that has been undertaken for the Surrey WLP reports that

development of a large scale (c. 300,000 tpa capacity) EfW facility would result in a 4%

increase in AADT on the section of the A22 (Eastbourne Road) closest to that proposed site


of the Transport Study predicts that traffic generated by any waste related development at

Site 5 would disperse to the strategic road network via junction 6 of the M25 to the north

and via the A264 (Copthorne Road) and the M23 to the south. It is not predicted that any

traffic from Site 5 would travel along the A22 (Eastbourne Road) south of East Grinstead in

West Sussex and then on through the Ashdown Forest SAC. The closest identified ILAS to

the SAC is ILAS 18 (Hobbs IE, Felbridge) which is situated off the A22 (Eastbourne Road),

which links to the A264 to the south and to the A25 to the north. The A22 runs through the

SAC to the south east of East Grinstead, but given the close proximity of ILAS18 to the

settlements of Horley, Crawley, East Grinstead, Smallfield and Lingfield, it is likely that the

waste catchment for any facility that may be built at the ILAS would not extend as far to the

south east as the SAC.

4.25 Tandridge DC published the pre-submission (Regulation 19) version of the new Local Plan

for the district in June 2018, the only part of Surrey that lies within 10 kilometres of the

SAC. The HRA undertaken as part of the Tandridge DC Local Plan preparation process,

which considered the impacts of emissions to air, concluded that no adverse effect on the

integrity of the SAC would arise from the implementation of the development proposed in

the Plan, alone or in-combination with the Local Plans of adjoining authorities (Tandridge

DC, Our Local Plan: 2033 (Regulation 19), June 2018, paragraph 26.64, p.212).



consequence of emissions from diffuse sources (traffic arising from waste related

development). The potential for significant impacts as a consequence of point source

emissions from thermal treatment plant at ILAS18 (Hobbs IE, Felbridge) cannot be ruled out

at the screening stage. Further assessment is required in respect of the air pollution

(emission and deposit of nitrogen) impact pathway with reference to emissions from

development at ILAS18 (Hobbs IE, Felbridge).


4.27 The feature affected is the wet heathland with cross-leaved heath (H4010). The SIP (p.5/9)


“The botanical diversity of the wet heath (& valley mire systems & bogs encompassed within

it) has declined over the last few decades. We don't have sufficient information / evidence /

survey to understand why this is the case. It is also suspected that Rhynchospora alba SAC

habitat is present at Ashdown Forest, but the wet heath / bogs have declined in recent years &

our current level of survey information/evidence is inadequate.”


51


concerned with the undertaking of surveys and analyses of the sites hydrological and

botanical conditions.


by the Surrey WLP would impact upon the hydrology of the habitats within the Ashdown

Forest SAC. None of the surface water catchments (see section 2.A.1 of this report) that

coincide with the SAC extend into Surrey, or are fed by waterbodies situated within Surrey.

In respect of surface waters, the SAC is hydrologically isolated from any areas of land within

Surrey that could be affected by waste related development.


development of sites allocated under Policy 11 or the ILAS identified under Policy 10, would

not give rise to direct or indirect significant impacts on the hydrology of the SAC. No further

assessment is required in respect of the changes in hydrology impact pathway.

4.D Assessment of significant effects

4.31 The screening assessment has identified a single pathway (air pollution – atmospheric

nitrogen deposition) by which development at one of the ILAS (ILA18 – Hobbs IE, Felbridge)

identified under Policy 10 of the Surrey WLP could give rise to significant impacts on the

SAC. The mechanism by which development within ILAS18 could contribute to the deposit

of nutrient nitrogen would be point source pollution from a thermal treatment plant. The

Surrey WLP does not specify the type or scale of waste related development that could be

accommodated on the identified ILAS.

4.32 Emissions for a small scale thermal treatment facility at ILAS18 are estimated to account for

0.28% of the site relevant critical loads for the most sensitive habitats of the Ashdown

Forest SAC (see Part B2, Appendix B). At those concentrations nutrient nitrogen deposition

within the SAC would be less than 1% of the site relevant minimum critical loads for wet

heath with Erica tetralix (10kg N/ha/yr) or dry heath (10kg N/ha/yr), and significant effects

on the integrity of the SAC would be unlikely to occur. The estimated background

deposition rate for nutrient nitrogen within the area of the SAC closest to the ILAS is 14.7

kg/N/ha/yr (which exceeds the minimum critical loads for the sensitive habitats), and the

estimated emissions for a small-scale facility would account for only 0.19% of the estimated

background deposition. The predicted environmental concentration (PEC) (background plus

process contribution) of 14.728 kg/N/ha/yr would account for 147.28% of the site relevant

minimum critical loads, with the development of a thermal treatment plant at ILAS18

accounting for 0.19% of the PEC.

4.33 On a precautionary basis it is recommended that ILAS18 (Hobbs IE, Felbridge) be classed as

unsuitable for the development of thermal treatment facilities with a capacity of more than

50,000 tonnes per year. Implementation of Policy 14 of the Surrey WLP, which requires that

all waste related planning applications be supported by sufficient information for the WPA


52

to ascertain whether the proposed development would result in significant adverse impacts

on the natural environment, including SPA and SACs, will ensure that permitted

development does not compromise the ecological integrity of the SAC.

4.E Conclusions


ecological integrity of the Ashdown Forest SAC has concluded that overall there would be


11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS18 – Hobbs IE,

Felbridge) identified under Policy 10 of the Surrey WLP is 8.6 kilometres to the north west.

Development of a thermal treatment facility on land at ILAS18 could, in theory result in

nutrient nitrogen deposition within the SAC, and traffic arising from development within

the ILAS could also contribute to such deposition. Given the relationship of ILAS18 to

potential sources of waste (e.g. Horley, Crawley, East Grinstead, Smallfield, Lingfield) and to

the wider road network it is unlikely that any waste related development would result in

vehicle movements through the SAC. To address the risk of nutrient nitrogen deposition

from process emissions from thermal treatment of waste it is recommended that ILAS18 is

unsuitable for such development (subject to the conclusions of any project level

assessment).

4.35 The assessment considered the three impact pathways identified as key threats and



pathway are summarised in Table 4-C.

Table 4-C: Summary of assessment conclusions


Level

Change in land management –

discussed further in section 4.C.1

No direct or indirect significant impacts on the SAC likely

to arise from implementation of the Surrey WLP Screening

Hydrological changes – discussed

further in section 4.C.3

No direct or indirect significant impacts on the SAC likely

to arise from implementation of the Surrey WLP Screening



nitrogen) – see section 4.C.2 &

section 4.D

One ILAS (ILAS18) located within 10 km of the SAC.

Potential for adverse impacts from nutrient nitrogen

deposition arising from process emissions (thermal

treatment plant) and traffic emissions.

All scales of thermal treatment not recommended at

ILAS18.


additional deposition within the SAC – likely to disperse

to the wider network.

Overall conclusion of no likely significant impacts on the

SAC, subject to implementation of the recommended

decision rules (see part B-1, Appendix B) and the

requirements of Policy 14 (Development Management)

of the Surrey WLP in respect of all applications for

planning permission for waste related development.

Screening

(Traffic

Emissions)

Assessment of

Likely

Significant

Effects (Process

Emissions)


53

4.F References


process for the Ashdown Forest SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Ashdown Forest




& designated SACs) – Ashdown Forest SAC (Joint Nature Conservation




4.36.4 Site Improvement Plan: Ashdown Forest SAC & SPA (Natural England, 24

November 2014).



4.36.6 Ashdown Forest SSSI Condition Survey Report (Natural England, Designated




June 2018

4.36.9 Our Local Plan: 2033 (Regulation 19), Tandridge District Council, June 2018




54

Chapter 5: Ashdown Forest SPA

5.A Geographical & Development Context

5.A.1 Composition & Location 5.1 The Ashdown Forest SPA (see map) is located in the county of East Sussex some 5.8

kilometres to the south of that county’s boundary with Surrey. The SPA designation covers

the majority of the area covered by the Ashdown Forest SSSI designation. According to the

SPA Standard Data Form the SPA covers an area of 3,207.07 hectares, and was designated

on 25 August 1993. The SPA is situated within an area administered by Wealden DC and by

East Sussex CC. Within Surrey, the Tandridge DC area is located closest to the SPA.

5.2 The SPA is dissected by a number of road links, including three that form part of the

strategic road network.

5.2.1 The A22 (Eastbourne Road / Lewes Road) – which passes through the SAC.

5.2.2 The A275 (Lewes Road) – which passes through the SAC.

5.2.3 The A26 (Uckfield Road) – which passes along the south eastern boundary of

the SAC.

5.3 The SPA is situated across a number of different surface water catchments, none of which



5.3.1 The Shortbridge Stream (GB107041012980).

5.3.2 The Pippingford Brook (GB106040018360).

5.3.3 The Medway at Weir Wood (GB106040018070).

5.3.4 The Friars Gate Stream (GB107041012980).

5.A.2 Minerals & waste development plan proposals in Surrey relevant to the SPA 5.4 The Ashdown Forest SPA is not located within 10 kilometres of any of the sites proposed for

allocation under Policy 11 of the Surrey WLP (see Figure 4-A – a full size version can be

found in Appendix A). The closest proposed allocation is ‘Site 5 – Land to the west of Lambs

Business Park, Terra Cotta Road, South Godstone’, which lies some 15.6 kilometres to the

north west of the SPA. The SPA is located within 10 kilometres of one of the ILAS (ILAS18 –

Hobbs Industrial Estate, Felbridge) identified under Policy 10 of the Surrey WLP (see Figure

4-A). The Plan does not specify the type or scale of waste related development that could

be accommodated on the identified ILAS.

http://magic.defra.gov.uk/MagicMap.aspx?startTopic=Designations&activelayer=spaIndex&query=Ref_CODE%3D%27UK9012181%27


55

Figure 5-A: Ashdown Forest SPA – Relationship to sites & ILAS proposed by the Surrey WLP


Plan, or in the Aggregates Recycling Joint DPD, are situated within 10 kilometres of the SPA.


Plan are situated within 10 kilometres of the SPA. The Habitat HRAs undertaken in respect

of all three of those plans concluded that the ecological integrity of the SPA would not be


5.B Key Characteristics of the SPA

5.B.1 Reasons for Designation 5.6 The ecological interest of the SPA, and the particular species that are given as reasons for

its designation, is described as follows in the published citation.

Site Description

The Ashdown Forest SPA is an extensive area of common land on mainly sandy soils between East Grinstead in West Sussex and Crowborough in East Sussex. It comprises a mosaic of wet & dry heath, valley bog & woodland, & supports several uncommon plants, a rich invertebrate fauna & nationally important numbers of breeding nightjar & Dartford warbler. The boundary of the SPA is coincident with that of the Ashdown Forest SSSI.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Ashdown Forest SPA

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Ashdown Forest SPA

ILAS18

N

S

W E

Site 5: Lambs BP


Site 2: Weylands TWSite 3: Slyfield IE

Site 1: Oakleaf FarmSite 6: Trumps Farm

ILAS04

ILAS19

ILAS10 ILAS13ILAS12

ILAS21ILAS20

ILAS08


ILAS01; ILAS02;ILAS03; ILAS05;ILAS06; ILAS09;ILAS15; ILAS16;ILAS22

ILAS11

20 km

30 km

40 km

50 km


56

The site qualifies for designation under Article 4.1 of the EU Birds Directive by regularly supporting nationally important breeding populations of two Annex I species. The site supports 35 pairs of nightjar (1991-92 survey), representing 1.1% of the British population, & 20 pairs of Dartford warbler (1994 survey), representing 2.1% of the British population. Other regularly occurring Annex I species include woodlark Lullula arborea, hen harrier Circus cyaneus, & great grey shrike Lanius excubitor.

The diverse range of heathland & woodland habitats on the site supports an important assemblage of breeding species, some of which have declined in England over recent years. Notable species regularly breeding on the site include hobby Falco subbuteo, tree pipit Anthus trivialis, redstart Phoenicurus phoenicurus, stonechat Saxicola torquata, & wood warbler Phylloscopus sibilatric, in addition to nightjar & Dartford warbler.

Qualifying Species

Nightjar Caprimulgus europaeus

Dartford warbler Sylvia undata


5.7 The published conservation objectives for the SPA are given below.


Ensure that the integrity of the site is maintained or restored as appropriate, & ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring;

The extent & distribution of the habitats of the qualifying features

The structure & function of the habitats of the qualifying features

The supporting processes on which the habitats of the qualifying features rely

The population of each of the qualifying features, &,

The distribution of the qualifying features within the site.

Qualifying Features

A224 Caprimulgus europaeus; European nightjar (Breeding)

A302 Sylvia undata; Dartford warbler (Breeding)

5.B.3 Condition


report for the Ashdown Forest SSSI9 (see Table 5-A for a summary), the designated site

extends to some 3,213.09 hectares, divided into 127 units. Some 20.31% (652.64 ha) of the

SSSI is in ‘favourable’ condition, some 79.29% (2,547.55 ha) is in ‘unfavourable –

recovering’ condition, and some 0.40% (12.93 ha) is in ‘unfavourable – declining’ condition.

The SSSI is composed of two main habitat types, ‘broadleaved, mixed and yew woodland –

lowland’ (1,150.45 hectares) and ‘dwarf shrub heath – lowland’ (2,062.67 hectares).

9 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001983&ReportTitle=Ashdown%20Forest%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001983&ReportTitle=Ashdown%20Forest%20SSSI


57

Table 5-A: Ashdown Forest SSSI – Condition Survey Findings

Main Habitat Type




Declining


Lowland

1150.45 ha

(35.80%)

463.32 ha

(14.42%)

674.19 ha

(20.98%)

12.93

(0.40%)

Dwarf Shrub Heath - Lowland

2062.67

(64.19%)

189.31 ha

(5.89%)

1873.36 ha

(58.30%)

0.00 ha

(0.00%)

Total 3213.12 652.63 ha (20.31%)

2547.55 ha (79.29 %)

12.93 ha (0.40%)

5.9 For the 12.93 hectares of broadleaved, mixed and yew woodland habitat (SSSI unit number

155, last surveyed on 21 March 2014) classified as exhibiting ‘unfavourable – declining’

condition, the condition survey report provides the following explanation and analysis.

Comments: This woodland has suffered from storm damage & is very open, there are some lovely old trees present but the huge deer pressure has prevented any regeneration of new trees, there is virtually no shrub layer & the ground flora is very grassy as a consequence of the deer grazing. Some trees have been planted in tubes but they are not yet in leaf & it was unclear if they had survived. In addition there are low levels of small rhododendron regrowth scattered across the unit. This unit needs to have some deer control, tree planting & rhododendron control.

Reasons for adverse condition: Forestry – deer grazing/browsing; forestry – forestry & woodland management; Lack of corrective works – inappropriate scrub control


5.10 The published Site Improvement Plan (SIP) (24 November 2014) for the SPA identifies the

following key threat/pressure to the site’s ecological integrity.

Public access / disturbance – discussed further in section 5.C.1

5.11 That identified threat/pressure defines the main pathway by which adverse impacts could

arise and compromise the ecological integrity of the SPA, and therefore forms the basis of

the screening stage of the HRA for the Surrey WLP in respect of the Ashdown Forest SPA.

5.C.1 Public access / disturbance

5.12 Public access / disturbance: The features affected are the European nightjar (A224(B)), and

the Dartford Warbler (A302(B)). The SIP (p.4/9) offers the following explanation of the

nature of the identified threat:

“There is potential for increased visitor pressure (in particular dogs off leads) to impact on

breeding birds, particularly Nightjar which is a ground nesting bird, but also Dartford Warbler

as it can nest low in the gorse. There is some work going on to reduce this pressure, which is


58

currently funded by developers. Long-term monitoring is needed to establish impacts,

alongside actions to mitigate the disturbance in partnership with the existing work.”


concerned with the provision of advice and education to dog walkers, and with the

implementation of a survey and monitoring programme intended to gather data on the

distribution of the SPA bird species across the site.


by the Surrey WLP could result in changes in the number of visitors to the Ashdown Forest

SPA. The Surrey WLP is concerned with the provision of a policy framework within which

development consent decisions can be made in respect of future waste management

facilities within the county of Surrey. The closest site allocated for waste related

development in the Surrey WLP is located some 15.5 kilometres to the north west of the

SPA, with the closest identified ILAS (ILAS18 – Hobbs IE, Felbridge) some 8.6 kilometres to

the north west. Operational waste facilities would not typically be a source of prospective

visitors to the SPA, compared with, for example, new residential development.



would not give rise to additional visitors to the SPA, and would therefore not contribute to

any significant impacts arising from public access to, and disturbance of, the SPA bird

species. No further assessment is required in respect of the public access / disturbance

impact pathway.

5.D Conclusions


ecological integrity of the Ashdown Forest SPA has concluded that overall there would be



of the SPA, but one of the ILAS (ILAS18 – Hobbs IE, Felbridge) is 8.6 kilometres to the north

west. The primary issue of concern for the ecological integrity of the SPA identified in the

published SIP is that of public access and disturbance, the incidence of which would be

unaffected by the development of new waste management capacity on the identified ILAS

or on other land within Surrey.

5.17 The assessment considered the single impact pathway identified as key threats and

pressures of concern with reference to the conservation objectives for the SPA. The

conclusions reached in respect of the likely impact of the Surrey WLP on the SPA via the

identified pathway are summarised in Table 5-B.


59



Level



5.C.1

No direct or indirect significant impacts on the SPA


WLP

Screening

5.E References


process for the Ashdown Forest SPA.

5.18.1 EC Directive 79/409 on the Conservation of Wild Birds: Citation for Special

Protection Area (SPA) – Ashdown Forest SPA (Natural England (English Nature),

May 1994).

5.18.2 NATURA 2000 – Standard Data Form: Special Protection Area under the EC

Birds Directive – Ashdown Forest SPA (Joint Nature Conservation Committee

(JNCC), 25 January 2016).

5.18.3 European Site Conservation Objectives for Ashdown Forest Special Protection

Area (Site Code: UK9012181) (Natural England, 30 June 2014, v.2).

5.18.4 Site Improvement Plan: Ashdown Forest SAC & SPA (Natural England, 24

November 2014).

5.18.5 Ashdown Forest SSSI Condition Survey Report (Natural England, Designated





60

Chapter 6 East Hampshire Hangers SAC



6.1 The East Hampshire Hangers SAC (see map) is located in Hampshire, and is composed of a

complex of seven SSSIs (listed below). According to the SAC citation, the designation covers

an area of 569.68 hectares, and was designated on 1 April 2005. The SAC is situated within

an area administered by the South Downs NPA, by East Hampshire DC, and by Hampshire

CC. Within Surrey, the Waverley BC area is located closest to the SAC.

Coombe Wood & the Lythe SSSI, located in Hampshire and covering some 43.98

hectares. The SSSI lies some 6.8 kilometres to the west of the Surrey/Hampshire

county boundary.

Noar Hill SSSI, located in Hampshire and covering some 63.05 hectares. The SSSI lies

some 11.6 kilometres to the west of the Surrey/Hampshire county boundary.

Selborne Common SSSI, located in Hampshire and covering some 99.85 hectares. The

SSSI lies some 12.1 kilometres to the west of the Surrey/Hampshire county boundary.

Upper Greensand Hangers: Empshott to Hawkley SSSI, located in Hampshire and

covering some 37.65 hectares. The SSSI lies some 10.5 kilometres to the west of the

Surrey/Hampshire county boundary.

Upper Greensand Hangers: Wyck to Wheatley SSSI, located in Hampshire and covering

some 13.23 hectares. The SSSI lies some 2.8 kilometres to the west of the

Surrey/Hampshire county boundary.

Wealden Edge Hangers SSSI, located in Hampshire and covering some 222.24 hectares.

The SSSI lies some 13.2 kilometres to the west of the Surrey/Hampshire county

boundary.

Wick Wood & Worldham Hangers SSSI, located in Hampshire and covering some 91.85

hectares. The SSSI lies some 6.1 kilometres to the west of the Surrey/Hampshire

county boundary.

6.2 The SAC is dissected by a number of road links, including the following ‘B’ class roads.

6.2.1 The B3004 (Cakers Lane / Green Street / Forge Road) – which passes within

200 metres of the Wick Wood & Worldham Hangers SSSI.

6.2.2 The B3006 (Selborne Road) – which passes within 200 metres of the Upper

Greensand Hangers: Empshott to Hawkley SSSI, the Coombe Wood & the Lythe

SSSI, and the Selborne Common SSSI.



61

6.3 The SAC is situated across a number of different surface water catchments, none of which



6.3.1 The Western Rother (upstream Petersfield) (GB107041012840).

6.3.2 The Oakhanger Stream (GB106039017710).

6.3.3 The Slea (Kingsley to Sleaford) (GB106039017750).


6.4 The East Hampshire Hangers SAC is not located within 10 kilometres of any of the sites

proposed for allocation under Policy 11 of the Surrey WLP (see Figure 6-A – a full size

version can be found in Appendix A). The closest proposed allocation is ‘Site 3 – Land to the

north east of Slyfield Industrial Estate, Moorfield Road, Guildford’, which lies some 24.5

kilometres to the north east of the closest component part of the SAC (the Upper

Greensand Hangers: Wyck to Wheatley SSSI). Part of the SPA is located within 10 kilometres

two of the ILAS (see below) identified under Policy 10 of the Surrey WLP (see Figure 6-A).

The Plan does not specify the type or scale of waste related development that could be

accommodated on the identified ILAS. Full details of the relationship of the individual SSSIs

that together form the SAC to all the sites allocated under Policy 11 and all the ILAS

identified under Policy 10 of the Surrey WLP can be found in Appendix A (Tables A-1 to A-5)

to this report.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 6.0 kilometres to the north east

of the Upper Greensand Hangers: Wyck to Wheatley SSSI.

ILAS21 (Farnham Trading Estate (including land north of Water Lane), Water Lane,

Farnham), 9.5 kilometres to the north east of the Upper Greensand Hangers: Wyck to

Wheatley SSSI.

6.5 The Alton Road quarry at Farnham, which is allocated for development as a temporary

aggregate recycling facility under Policy AR2 of the adopted Aggregates Recycling Joint DPD,

and has planning permission for mineral working and infilling with waste (Planning

Permission WA/2014/0005), is located some 4.6 kilometres to the north of the Upper

Greensand Hangers: Wyck to Wheatley SSSI component of the SAC. The Alton Road quarry

is accessed from the north via a dedicated track that links to the A31. The Habitat

Regulations Assessments undertaken in respect of the Aggregates Recycling Joint DPD

concluded that the ecological integrity of the SAC would not be adversely affected by the

plan’s implementation.

6.6 None of the sites proposed for development in the adopted Surrey Waste Plan, and none of

the preferred areas for mineral working identified in the adopted Surrey Minerals Plan are

situated within 10 kilometres of the SAC. The Habitat Regulations Assessments undertaken

in respect of both of those plans concluded that the ecological integrity of the SAC would

not be adversely affected by their implementation.


62

Figure 6-A: East Hampshire Hangers SAC – Relationship to sites & ILAS proposed by the Surrey WLP




Site Description

This site supports beech Fagus sylvatica woodlands which are extremely rich in vascular plants, including white helleborine Cephalanthera damasonium, violet helleborine Epipactis purpurata, green-flowered helleborine E. phyllanthes & Italian lords-&-ladies Arum italicum.

The woods include areas with old pollards on former wood-pasture as well as high forest. There are transitions to mixed woodland including areas of small-leaved lime Tilia cordata on the steepest parts of the Upper Greensand scarp. The bryophyte flora is rich & includes several species that are rare in the lowlands. The Wealden Edge Hangers component of the site contains stands of yew Taxus baccata woodland.

Chalk grassland has developed in ancient quarries at Noar Hill & includes local species such as early gentian Gentianella anglica & an outstanding assemblage of orchids.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

East Hampshire Hangers SAC

East Hampshire

Hangers SAC

ILAS20

ILAS21

Site 6: Trumps FarmSite 4: Leatherhead STW

Site 5: Lambs BP

N

S

W E

Site 3: Slyfield IE

Site 1: Oakleaf Farm Site 2: Weylands TW

ILAS07

ILAS17

ILAS05; ILAS06;ILAS09; ILAS22

ILAS08

ILAS19



ILAS12;ILAS11

ILAS18

ILAS13

50 km

40 km

30 km

20 km


63

Qualifying Habitats


Asperulo-Fagetum beech forests. (Beech forests on neutral to rich soils).

Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia). (Dry grasslands & scrublands on chalk or limestone).

Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia) (important orchid sites). (Dry grasslands & scrublands on chalk or limestone, including important orchid sites)* (Annex I priority habitat).

Taxus baccata woods of the British Isles. (Yew-dominated woodland)* (Annex I priority habitat).

Tilio-Acerion forests of slopes, screes & ravines. (Mixed woodland on base-rich soils associated with rocky slopes)* (Annex I priority habitat).

Qualifying Species

Early gentian Gentianella anglica.










Qualifying Features

H6210. Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia) (important orchid sites); Dry grasslands & scrublands on chalk or limestone (important orchid sites)*

H9130. Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils

H9180. Tilio-Acerion forests of slopes, screes and ravines; Mixed woodland on base-rich soils associated with rocky slopes*

H91J0. Taxus baccata woods of the British Isles; Yew-dominated woodland*

S1654. Gentianella anglica; Early gentian


64

6.B.3 Condition


reports for the complex of SSSIs that together form the SAC10 (see Table 6-A for a

summary), the designated site extends to some 571.85 hectares, of which some 97.9% is in

‘favourable’ condition, some 1.3% is in ‘unfavourable – recovering’ condition, some 0.4% is

in ‘unfavourable – no change’ condition, and some 0.4% is in ‘unfavourable –declining’

condition. The majority of the SSSIs are composed of three main habitat types,

‘broadleaved, mixed and yew woodland’ (545.17 hectares), ‘calcareous grassland’ (19.96

hectares), and ‘neutral grassland’ (6.72 hectares).

Table 6-A: East Hampshire Hangers SAC complex of SSSIs – Condition Survey Findings

Main Habitat Type




No Change Unfavourable –

Declining


Lowland

545.17 ha

(95.3%)

540.37 ha

(94.5%)

3.45 ha

(0.6%)

0.96 ha

(0.2%)

0.39 ha

(0.1%)

Neutral Grassland – Lowland

6.72 ha

(1.2%)

0 ha

(0%)

3.72 ha

(0.6%)

1.19 ha

(0.2%)

1.81 ha

(0.3%)

Calcareous Grassland -

Lowland

19.96 ha

(3.5%)

19.49

(3.4%)

0.47 ha

(0.1%)

0 ha

(0%)

0 ha

(0%)

Totals 571.85 560.33 (97.9%)

7.64 ha (1.3%)

2.15 ha (0.4%)

2.20 ha (0.4%)

6.10 For the 0.39 hectares of broadleaved, mixed and yew woodland habitat (Upper Greensand

Hangers: Empshott to Hawkley SSSI unit number 13, last surveyed on 4 August 2010)

classified as exhibiting ‘unfavourable – declining’ condition, the condition survey report

provides the following explanation and analysis.

Comments: Small thin section of isolated woodland on a steep slope includes oak, ash, birch, cherry & mature larch. Shrub layer includes elder, hazel, sallow & bramble. Ground flora includes ramsons, nettles, ferns & a hybrid ivy. There is plenty of fallen & standing deadwood, natural processes ongoing. Negative indicators - the ivy species within this unit appears to be a garden hybrid which is blanketing the ground, including bare rock, currently spreading within the unit.

Reasons for adverse condition: Other – Other – Specify in comments [Note, the comments make reference to the presence of garden hybrid species of ivy, that is spreading within the unit ]

10 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000044&ReportTitle=Coombe%20Wood%20and%20The%20Lythe%20SSSI;

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003053&ReportTitle=Noar%20Hill%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003287&ReportTitle=Selborne%20Common%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000396&ReportTitle=Upper%20Greensand%20Hangers%20:%20Empshott%20to%20Hawkley%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000397&ReportTitle=Upper%20Greensand%20Hangers%20:%20Wyck%20to%20Wheatley%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004122&ReportTitle=Wealden%20Edge%20Hangers%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004170&ReportTitle=Wick%20Wood%20and%20Worldham%20Hangers%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000044&ReportTitle=Coombe%20Wood%20and%20The%20Lythe%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003053&ReportTitle=Noar%20Hill%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003287&ReportTitle=Selborne%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000396&ReportTitle=Upper%20Greensand%20Hangers%20:%20Empshott%20to%20Hawkley%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000396&ReportTitle=Upper%20Greensand%20Hangers%20:%20Empshott%20to%20Hawkley%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000397&ReportTitle=Upper%20Greensand%20Hangers%20:%20Wyck%20to%20Wheatley%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004122&ReportTitle=Wealden%20Edge%20Hangers%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004170&ReportTitle=Wick%20Wood%20and%20Worldham%20Hangers%20SSSI


65

6.11 For the 1.81 hectares of neutral grassland habitat (Coombe Wood & the Lythe SSSI unit

number 1, last surveyed on 16 May 2011) classified as exhibiting ‘unfavourable – declining’

condition, the condition survey report provides the following explanation and analysis.

Comments: The unit is not grazed & has become dominated by ruderal species such as thistles, nettles & dock. The thatch is becoming very thick & the scrub is encroaching the site. There are small areas of bird's-foot trefoil but it is decreasing in botanical interest.

Reasons for adverse condition: Agriculture – Undergrazing

6.12 For the 0.96 hectares of broadleaved, mixed and yew woodland habitat (Wick Wood &

Worldham Hangers SSSI unit number 2, last surveyed on 27 June 2013) classified as

exhibiting ‘unfavourable – no change’ condition, the condition survey report provides the

following explanation and analysis.

Comments: There were appropriate levels of tree canopy cover of native species, & signs of regeneration via saplings. The ground flora at this site were very variable with some coarser species present, & thus did not pass the target overall. There were fewer Blackthorn & Goat Willow trees observed than expected on this site. These would be desirable as supporting features for the Brown Hairstreak & Purple Emperor Butterflies

Reasons for adverse condition: [None given]

6.13 For the 1.19 hectares of neutral grassland habitat (Coombe Wood & the Lythe SSSI unit

number 10, last surveyed on 12 May 2011) classified as exhibiting ‘unfavourable – no

change’ condition, the condition survey report provides the following explanation and

analysis.

Comments: The majority of the field was species poor & the sward long due to lack of grazing. The field was dominated by buttercup, dock, nettles which suggests high nutrients. The botanical interest is concentrated in the lower part of the field which is wetter - yellow flag iris, common bistort & a very small area of meadow sweet. The woodland is encroaching into the meadow area & is dominated by nettles.

Reasons for adverse condition: Other - Other - Specify in comments [Note, the comments make reference to lack of grazing, nutrient enrichment]


6.14 The published Site Improvement Plan (SIP) (12 December 2014) for the SAC identifies the


Air pollution: impact of atmospheric nitrogen deposition (pressure) – discussed further

in section 6.C.1;

Invasive species (pressure) – discussed further in section 6.C.2;

Forestry & woodland management (pressure) – discussed further in section 6.C.3.


66

6.15 Those three pressures and threats define the main pathways by which adverse impacts

could arise and compromise the ecological integrity of the SAC, and therefore form the

basis of the screening stage of the HRA for the Surrey WLP in respect of the East Hampshire

Hangers SAC.


6.16 The features affected, directly or indirectly, by the deposition of atmospheric nitrogen on

the SAC habitats are, the dry grassland and scrubland on chalk or limestone (important

orchid sites) (H6210) habitats, the beech forest on neutral to rich soil (H9130) habitats, the

mixed woodland on base-rich soil associated with rocky slopes (H9180) habitats, the yew-

dominated woodland (H91J0) habitats, and the population of the early gentian (S1654). The

SIP (p.3/9) offers the following explanation of the nature of the identified pressure:


there is a risk of harmful effects, but the sensitive features are currently generally considered

to be in favourable condition on the site (those few that are unfavourable are unfavourable

for specific reasons unrelated to nitrogen). This requires further investigation.”

6.17 The actions identified as the principal means of addressing the pressure are concerned with

controlling and reducing nitrogen emissions and deposition, and with ameliorating the

impacts of that deposition.







there is no risk of development at any of the six sites allocated under Policy 11 of the Surrey

WLP giving rise to nutrient nitrogen deposition within the SAC at concentrations that would

exceed 1% of the site relevant critical loads (see Part B-3, Appendix B) for any of the

designated habitats or species. The closest site allocation (Site 3 – Land NE of Slyfield IE,

Guildford) is 24.5 kilometres to the north east of the SAC, beyond the distance (10

kilometres) for which detailed assessment would be required by the Environment Agency

as part of the Environmental Permit consenting process. Any contribution that emissions

from a thermal treatment facility at the closest allocated site would make to nitrogen

deposition at the SAC would be undetectable.

6.20 Two of the ILAS (ILAS20 – Coxbridge BP, Farnham; ILAS21 – Farnham TE, Farnham)

identified under Policy 10 of the Surrey WLP are located within 10 kilometres (6.0

kilometres north east and 9.5 kilometres north east respectively) of one of the SSSIs (Upper

Greensand Hangers: Wyck to Wheatley SSSI) that forms part of the SAC. The development

of thermal treatment facilities on land located within ILAS20 and ILAS21 could, in theory,

present risks of nutrient nitrogen deposition on land within the SAC.


67


land situated within Surrey other than the allocated sites and identified ILAS, which could

include land situated within 10 kilometres of the SAC. The Metropolitan Green Belt

planning designation does not extend across all of the land within Surrey that lies within 10

kilometres of the SAC, with areas of non-Green Belt land situated to the south and north of

Farnham. However, those areas are in close proximity to a number of SPAs (Thames Basin

Heaths SPA, Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA,

Wealden Heaths Phase 2 SPA) and another SAC (Thursley, Ash, Pirbright & Cobham SAC),

and to the Surrey Hills Area of Outstanding Natural Beauty (AONB) and the South Downs

National Park, and it is therefore unlikely that a strategic waste management facility, as a

large scale (c.150,000 tonnes per annum or greater capacity) thermal treatment plant

would be classed, would be sited on unallocated land in Surrey within 10 kilometres of the

SAC.


development in Surrey would be unlikely to travel along either of the ‘B’ class roads (B3004

and B3006) that pass through or close to parts of the SAC. For the closest proposed site

allocation (Site 3 – Land NE of Slyfield IE, Guildford), the Transport Study undertaken for the

Surrey WLP reports that development of a large scale (c. 300,000 tpa capacity) EfW facility

would result in a 6% increase in AADT on the section of the A320 (Woking Road) closest to

that allocated site (Waste Local Plan – Transport Study: Site Assessments, Table 3.1, p.20).

Section 3.3 (p.21) of the Surrey WLP Transport Study predicts that traffic generated by any

waste related development on Site 3 (Land NE of Slyfield IE, Guildford) would disperse to

the strategic road network southwards along the A320 to the A3. It is not predicted that

any traffic would leave the A3 at Compton and join the A31 (Hogs Back) to then leave the

A31 at Alton in Hampshire to travel east along the B3004 and then through, or within 200

metres of, parts of the East Hampshire Hangers SAC.


at any of the ILAS identified under Policy 10 of the Surrey WLP on traffic levels on local or

strategic road networks. Two of the identified ILAS (ILAS20 – Coxbridge BP, Farnham;

ILAS21 – Farnham TE, Farnham) are situated such that waste related development at those

locations could contribute to additional traffic on the section of A31 that passes north of

the SAC or on the section of the A325 that passes east of the SAC. However neither the A31

nor the A325 pass within 200 metres of any constituent part of the SAC, and it is unlikely

that traffic generated by the presence of waste management facilities on land at ILAS20

and/or ILAS21 would travel along either of the ‘B’ class roads (B3004 and B3006) that do

pass within 200 metres of parts of the SAC.


concluded that implementation of the policies and proposals set out the Plan would not

give rise to significant effects on the ecological integrity of the SAC, alone or in-

combination. The published HRA reports (AECOM, 2016, 2017 and 2018) for the Waverley

BC Local Plan concluded that implementation of the policies and proposals set out in Parts


68

1 and 2 of that Plan would not give rise to significant effects on the ecological integrity of

the SAC, alone or in-combination.




development). However, the potential for significant impacts as a consequence of point

source pollution from the development and operation of some scale and type of thermal

treatment plant on land at ILAS20 and/or ILAS21 cannot be ruled out at the screening

stage. Further assessment is required in respect of the air pollution (emission and deposit

of nitrogen) impact pathway with reference to facility emissions from waste facility

development on land at ILAS20 and/or ILAS21 (see section 6.D of this report).

6.C.2 Invasive species

6.26 The feature affected by the invasion of the SAC by a non-native hybrid species of ivy is the

mixed woodland on base-rich soils associated with rocky slopes (H9180) habitat. The SIP

(p.3/9) offers the following explanation of the nature of the identified pressure:

“A non-native hybrid ivy is smothering out the ground flora and spreading in one of the

hangers.”


removal of the non-native ivy, and improvement in the long-term management of the

affected woodland.


by the Surrey WLP could act to enable or prevent the introduction of invasive plant species

into the SAC. The area of land covered by the SAC designation is situated beyond the

county of Surrey, so could not be affected by any waste related development brought

forward under the Surrey WLP, as no new facilities would be situated in sufficiently close

proximity (<2.5 kilometres) to the SAC to act as a source of invasive plant species (e.g. from

green waste from domestic gardens or horticultural businesses).





the invasive species impact pathway.


6.30 The feature affected by poor woodland management practice is the mixed woodland on

base-rich soils associated with rocky slopes (H9180) habitat. The SIP (p.4/9) offers the



69

“A small portion of the SAC is in unfavourable condition due to lack of understorey. Attempts

at providing regeneration have been poorly implemented and in addition parts of this area are

thick with ruderal vegetation.”


further investigation of the causes of unfavourable condition, and with the development

and implementation of a woodland management plan.










proximity (<2.5 kilometres) to the SAC to be of significant benefit to the ongoing

management of its woodland habitats. Wastes arising from the management of the SAC

would more likely be dealt with by facilities situated in Hampshire or West Sussex.




management practices within the SAC, and therefore would not affect the condition of

those habitats. No further assessment is required in respect of the changes in forestry and

woodland management impact pathway.



nitrogen deposition) by which development at two of the ILAS (ILAS20 – Coxbridge BP,

Farnham; ILAS21 – Farnham TE, Farnham) identified under Policy 10 of the Surrey WLP

could give rise to significant impacts on the SAC. The mechanism by which development on

land within ILAS20 and/or ILAS21 could contribute to the deposit of nutrient nitrogen

would be emissions from thermal treatment plants. The Surrey WLP does not specify the

type or scale of waste related development that could be accommodated on the identified

ILAS.

6.36 Emissions for small scale thermal treatment facilities at ILAS20 and /or ILAS21 are

estimated to account for 1.68% and 0.56% respectively of the site relevant minimum critical

load for the most sensitive habitat (coniferous woodland – 5 kg/N/ha/yr) within the SAC

(see Part B3, Appendix B). The estimated background deposition rate for nutrient nitrogen

within woodland in the area of the SAC closest to the ILAS is 26.74 kg/N/ha/yr (which


70

exceeds the minimum critical loads for coniferous woodland ), and the estimated emissions

for a small-scale facility would account for only 0.31% (ILAS20) and 0.10% (ILAS21) of the

estimated background deposition. The PEC (background plus process contribution) of 26.74

kg/N/ha/yr would account for more than 530% of the site relevant minimum critical load

for both ILAS20 and ILAS21, with the development of thermal treatment plant accounting

for increases in the PEC of 0.31% and 0.10% respectively.

6.37 On a precautionary basis it is recommended that ILAS21 (Farnham TE, Farnham) be classed

as unsuitable for the development of thermal treatment facilities with a capacity of more

than 50,000 tonnes per year, and that ILAS20 (Coxbridge BP, Farnham) be classed as

unsuitable for any scale or type of thermal treatment facility. Implementation of Policy 14

of the Surrey WLP, which requires that all waste related planning application be supported

by sufficient information for the WPA to ascertain whether the proposed development

would result in significant adverse impacts on the natural environment, including SPAs and

SACs, will ensure that permitted development does not compromise the ecological integrity

of the SAC.

6.E Conclusions 6.38 The assessment of the implications of the implementation of the Surrey WLP for the

ecological integrity of the East Hampshire Hangers SAC has concluded that overall there

would be no potential for ‘likely significant effects’ to arise. None of the sites allocated

under Policy 11 are located within 10 kilometres of the SAC, but two of the ILAS (ILAS20 –

Coxbridge BP, Farnham; ILAS21 – Farnham TE, Farnham) identified under Policy 10 of the

Surrey WLP are 6.0 kilometres and 9.5 kilometres to the north east. Development of

thermal treatment facilities on land at ILAS20 and/or ILAS21 could, in theory result in


the two ILAS could also contribute to such deposition. Given the relationship of ILAS20 and

ILAS21 to the wider road network it is unlikely that any waste related development would

result in vehicle movements through the SAC. To address the risk of nutrient nitrogen

deposition from process emissions from thermal treatment of waste it is recommended

that ILAS20 is unsuitable for all scales of such development (subject to the conclusions of

any project level assessment) and that ILAS21 may accommodate a small scale (<50,000

tpa) facility (subject to the conclusions of any project level assessment) with reference to

the East Hampshire Hangers SAC.






71



Level




& section 6.D

Two ILAS (ILAS20 and ILAS21) located within 10 km

of the SAC. Potential for adverse impacts from

nutrient nitrogen deposition arising from process

emissions (thermal treatment plant) and traffic

emissions.

All scales of thermal treatment not recommended

at ILAS20 with reference to the EHH SAC, and only

small-scale (<50,000 tpa) facilities could be

accommodated at ILAS21.



disperse to the wider network.


on the SAC, subject to implementation of the

recommended decision rules (see part B-1,

Appendix B) and the requirements of Policy 14

(Development Management) of the Surrey WLP in

respect of all applications for planning permission

for waste related development.

Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)



section 6.C.2



WLP

Screening



6.C.3



WLP

Screening

6.F References


process for the East Hampshire Hangers SAC.


and Flora: Citation for Special Area of Conservation (SAC) – East Hampshire

Hangers SAC (Natural England (English Nature), May 2005).



& designated SACs) – East Hampshire Hangers SAC (Joint Nature Conservation


6.40.3 European Site Conservation Objectives for East Hampshire Hangers Special

Area of Conservation (Site Code: UK0030080) (Natural England, 30 June 2014,

v.2).


72

6.40.4 Site Improvement Plan: East Hampshire Hangers SAC (Natural England, 24

November 2014).



6.40.6 Coombe Wood & The Lythe SSSI Condition Survey Report (Natural England,

Designated Sites website, accessed 30 May 2018).

6.40.7 Noar Hill SSSI Condition Survey Report (Natural England, Designated Sites


6.40.8 Selborne Common SSSI Condition Survey Report (Natural England, Designated


6.40.9 Upper Greensand Hangers: Empshott to Hawkley SSSI Condition Survey Report

(Natural England, Designated Sites website, accessed 30 May 2018).

6.40.10 Upper Greensand Hangers: Wyck to Wheatley SSSI Condition Survey Report


6.40.11 Wealden Edge Hangers SSSI Condition Survey Report (Natural England,


6.40.12 Wick Wood & Worldham Hangers SSSI Condition Survey Report (Natural

England, Designated Sites website, accessed 30 May 2018).



June 2018








73

Chapter 7 Ebernoe Common SAC



7.1 The Ebernoe Common SAC (see map) is located in West Sussex, and is composed of a single

SSSI, the Ebernoe Common SSSI. The SAC covers an area of 234.05 hectares, as stated on

the SAC citation, and was first designated on 1 April 2005, with extensions to the SAC

designated on 10 December 2009. The SAC is situated some 3.1 kilometres to the south of

the Surrey/West Sussex county boundary. The SAC is situated within an area administered

by the South Downs NPA, Chichester DC and West Sussex CC. Within Surrey, the Waverley

BC area is located closest to the SAC.

7.2 The SAC is dissected by a number of local road links, and part of the site is situated within

200 metres of the A283 (London Road) – which forms the western boundary of the SSSI and

SAC for some 1.1 kilometres.

7.3 The SAC is situated within a single surface water catchment, of the Kird (GB107041012300),

which lies wholly outside the county of Surrey, and is not fed by any upstream catchments

that are situated in Surrey.


7.4 The Ebernoe Common SAC is not located within 10 kilometres of any of the sites proposed

for allocation under Policy 11 of the Surrey WLP (see Figure 7-A – a full size version can be

found in Appendix A). The closest proposed allocation is Site 3 (Land to the north east of

Slyfield Industrial Estate, Moorfield Road, Guildford), which lies some 23.3 kilometres to the

north of the SAC. The SAC is located within 10 kilometres of ILAS19 (Land at Dunsfold

Aerodrome, Stovolds Hill, Dunsfold) which is identified under Policy 10 of the Surrey WLP

(see Figure 7-A). The Plan does not specify the type or scale of waste related development

that could be accommodated on the identified ILAS.




Plan are situated within 5 kilometres of the SAC. The Habitat HRAs undertaken in respect of

all three of those plans concluded that the ecological integrity of the SAC would not be




74

Figure 7-A: Ebernoe Common SAC – Relationship to sites & ILAS proposed by the Surrey WLP





Site Description

Ebernoe Common has an extensive block of beech Fagus sylvatica high forest & former wood-pasture over dense holly Ilex aquifolium with a very rich epiphytic lichen flora, including Agonimia octospora & Catillaria atropurpurea. The beech woodland is associated with other woodland types, open glades & pools, which contribute to a high overall diversity. A maternity colony of Barbastelle bats Barbastella barbastellus utilises a range of tree roosts in the site, usually in dead tree stumps, but the species appears to be present throughout the year, with individuals utilising a range of roost sites in tree holes & under bark. The site also holds a maternity colony of Bechstein’s bats Myotis bechsteinii, mainly roosting in old woodpecker holes in the stems of live mature sessile oak Quercus petraea trees.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Ebernoe Common SAC

EbernoeCommon

SAC

ILAS19

N

S

W E

ILAS10


Site 3: Slyfield IE

Site 6: Trumps Farm Site 4: Leatherhead STW

Site 2: Weylands TW

ILAS08

ILAS20; ILAS21

ILAS07

ILAS17

ILAS18

ILAS05; ILAS06;ILAS09




20 km

30 km

40 km

50 km

Site 5: Lambs BP


75

Qualifying Habitats


Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion). (Beech forests on acid soils) Qualifying Species


Barbastelle bat Barbastella barbastellus

Bechstein’s bat Myotis bechsteinii










Qualifying Features

H9120. Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils

S1308. Barbastella barbastellus; Barbastelle bat

S1323. Myotis bechsteinii; Bechstein`s bat


report for the Ebernoe Common SSSI11 (see Table 7-A), the designated site extends to some

233.92 hectares, of which some 99.9% is in ‘favourable’ condition, and some 0.1% is in

‘unfavourable – recovering’ condition. The SSSI is composed of ‘broadleaved, mixed & yew

woodland – lowland’ habitat (233.92 hectares), and hosts maternity colonies of the

Barbastelle and Bechsteins bats.

11 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004246&ReportTitle=Ebernoe%20Common%20SSSI


76

Table 7-A: Ebernoe Common SAC – Condition Survey Findings

Main Habitat Type



Recovering

Broadleaved, Mixed & Yew Woodland 233.92 ha 233.68 ha

(99.9%)

0.25 ha

(0.1%)

Totals 233.92 ha 233.68 ha 0.25 ha

7.C Identification of Impact Pathways & Screening Evaluation 7.9 The published Site Improvement Plan (SIP) for the SAC (6 March 2015) identifies the


Changes in forestry and woodland management practices – discussed further in section

7.C.1;

Changes in off-site habitat availability– discussed further in section 7.C.2;

Changes due to habitat fragmentation – discussed further in section 7.C.3;

Changes in land management practices – discussed further in section 7.C.4;

Changes in local hydrological conditions – discussed further in section 7.C.5;

Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further

in section 7.C.6;

Changes in the incidence of public access / disturbance – discussed further in section

7.C.7.


7.10 The features affected by changes in forestry and woodland management practices within

the SAC are the beech forest on acid soil (H9120) habitat, the population of Barbastelle bat

(S1308), and the population of Bechsteins bat (S1323). The SIP (p.4/11) offers the following

explanation of the nature of the identified pressure/threat:

“Woodland management for SSSI features (lichens, invertebrates) which require higher light

levels may have a significant impact on the bat species. Additionally some management of the

beech woodland is necessary in places. More information about potential impacts on bat

species is required.”


pressure/threat are concerned with undertaking further investigation of the impacts of

woodland management on other qualifying features, and with the development and

implementation of a tailored habitat creation and restoration strategy.


77










proximity (<2.5 kilometres) to the SAC to be of significant benefit to the ongoing

management of its woodland habitats. Wastes arising from the management of the SAC

would more likely be dealt with by facilities situated in West Sussex.







7.C.2 Offsite habitat availability / management

7.15 The features affected by changes to offsite habitat availability and management are the

population of Barbastelle bat (S1308), and the population of Bechsteins bat (S1323). The

SIP (p.5/11) offers the following explanation of the nature of the identified pressure:

“The protected site is limited woodland core area where breeding colonies are known to exist.

The bats, however, rely on commuting & foraging habitat outside of the site & this needs to be

better understood, protected & appropriately managed. It would also be useful to understand

how this site relates to other bat SACs in the southern part of the UK to ensure that they & the

connecting habitats are managed appropriately to maintain favourable populations.”


concerned with identifying further areas (outside the core area of woodland/wood pasture)

with available, restored or created habitat that could suitably provide for foraging, for

swarming activity, for commuting to hibernating sites, and for improving connectivity to

related sites.


by the Surrey WLP would impact upon the provision of additional habitat outside the SAC

that is tailored to and managed for the two SAC bat species.


within the county of Surrey over a 15 year period, to meet projected growth in waste

arisings, and its implementation will typically involve the development of relatively small


78

sites with limited scope to contribute to habitat creation. The Surrey WLP would exert no

influence over the management of the wider countryside within the county of Surrey or

beyond.




creation or management of offside habitat suitable for the SAC bat species. No further

assessment is required in respect of the offsite habitat availability / management impact

pathway.

7.C.3 Habitat fragmentation

7.20 The features affected by habitat fragmentation are the population of Barbastelle bat

(S1308), and the population of Bechsteins bat (S1323). The SIP (p.5/11) offers the following

explanation of the nature of the identified threat:

“Ebernoe Common & The Mens are similar SACs which lie within 5km of each other. It is likely

that the bat populations of both sites are genetically linked. Barbastelle bats are known to

commute more than 5km & there is continuous woodland cover between the sites to allow

Bechstein's to travel. There is a case to investigate whether the two sites should be treated

within one overarching Natura 2000 site. It would also be useful to understand (through

genetic analysis) how this site relates to other bat SACs in the southern part of the UK to

ensure that they and the connecting habitats are managed appropriately to maintain

favourable populations.”


concerned with further investigation of the relationship of the SAC to other important bat

sites in the south of the UK, and with the development and implementation of tailored

habitat management programmes, particularly for areas outside the SAC, to support

commuting and foraging use.


by the Surrey WLP would impact, either negatively or positively, on the ability of existing

areas of habitat suitable for the SAC bat species and located close to the SAC, and the

ability of the SAC and the nearby The Mens SAC, to function as a coherent wider area of bat

habitat.


on land situated within the county of Surrey over a 15 year period, to meet projected

growth in waste arisings. The Surrey WLP would exert no influence over the siting of

development on land outside the boundaries of the county of Surrey. As the SAC is not

located within or adjacent to the county of Surrey, but lies some 3.1 kilometres to the south

of the county boundary, its habitats and those of the surrounding area of land would be

unaffected by development brought forward under the Surrey WLP.


79




habitat fragmentation. No further assessment is required in respect of the offsite habitat

availability / management impact pathway.


7.25 The feature affected by changes in land management practice is the population of

Barbastelle bat (S1308). The SIP (p.6/11) offers the following explanation of the nature of

the identified pressure/threat:

“Land management in the surrounding countryside will have an impact on foraging areas for

Barbastelle bats but at present the forage requirements (how much habitat & of what type)

are poorly understood. Ultimately, inadequate foraging will impact on breeding success within

the site. Further investigation of foraging & bat commuting route requirements of notified bat

species is required, informing better management of mature hedgerows which need to be

restored & maintained in the area around the site.”


pressure/threat are concerned with further investigation of the foraging and commuting

route requirements of the notified bat species (within and outside the SAC), with the aim of

informing improved management of foraging and commuting habitat in the surrounding

landscape.



or around the SAC.

7.28 The only points at which the land management regime implemented across the SAC may



time to time as a consequence of active habitat management (e.g. green waste from

hedgerow maintenance, etc.). The provision of additional waste management capacity

within the county of Surrey would be unlikely to be provided in close enough proximity to

the SAC to be of significant benefit to the ongoing management of its habitats. Wastes

arising from the management of the SAC would more likely be dealt with by facilities

situated close to the SAC and within West Sussex.




within the SAC or the surrounding area. No further assessment is required in respect of the

changes in land management impact pathway.


80


7.30 The feature affected by changes to the hydrology of the SAC is the population of Bechsteins

bat (S1323). The SIP (p.6/11) offers the following explanation of the nature of the identified

threat:

“Recent research has shown that water availability (ponds & streams) within Bechstein's

breeding sites is likely to be important. Housing development around the site & hydrological

changes in the local area could impact on the availability of these habitats.”


concerned with investigation of the hydrological setting of the SAC and the surrounding

area, with making improvements to the overall hydrological management of the SAC and

the surrounding area, and with the mitigation of the potential impacts of development.


by the Surrey WLP would impact upon the hydrology of the land covered by the SAC

designation. None of the surface water catchments (see section 7.A.1 of this report) that

coincide with the SAC extend into Surrey, or are fed by waterbodies situated within Surrey.

In respect of surface waters, the SAC is hydrologically isolated from any areas of land within

Surrey that could be affected by waste related development brought forward under the

Surrey WLP.



would not give rise to direct or indirect significant impacts on the hydrology of the SAC. No

further assessment is required in respect of the changes in hydrology impact pathway.


7.34 The features affected by the deposition of nutrient nitrogen from the atmosphere are the

beech forests on acid soils (H9120) habitat, the population of Barbastelle bat (S1308), and

the population of Bechsteins bat (S1323). The SIP (p.7/11) offers the following explanation

of the nature of the identified threat:





concerned with further investigation of the potential impacts of atmospheric nitrogen

deposition on the site.





81




development at any of the six sites allocated under Policy 11 of the Surrey WLP giving rise

to nutrient nitrogen deposition within the SAC at concentrations that would exceed 1% of

the site relevant critical loads for the designated features (see Part B4, Appendix B), alone

or in-combination. The closest site allocation (Site 3 – Land NE of Slyfield IE, Guildford) is

23.4 kilometres to the north east of the SAC, and beyond the distance (10 kilometres) for

which assessment would be required by the Environment Agency as part of the

Environmental Permit consenting process. Any contribution that emissions from a thermal

treatment facility at the closest allocated site would make to nitrogen deposition at the SAC

would be undetectable.

7.38 One of the ILAS (ILAS19 – Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh) identified

under Policy 10 is located within 10 kilometres of the SAC (8.8 kilometres to the north east).

The development of a thermal treatment facility on land located within ILAS19 could, in

theory present a risk of nutrient nitrogen deposition on land within the SAC.

7.39 It is theoretically possible that proposals for waste related development could be brought

forward on land situated within Surrey other than the allocated sites or identified ILAS,

which could include land situated within 10 kilometres of the SAC. However, land in Surrey

that lies within 10 kilometres of the SAC to the north and north west is covered by the

Metropolitan Green Belt designation, and the policy approach for the Surrey WLP does not

prefer non-allocated Green Belt land over allocated Green Belt sites. The land within Surrey

to the north east of the SAC is not within the Green Belt, but is rural in character and would

offer little in the way of previously developed land, and the policy approach of the Surrey

WLP prefers non-Green Belt previously developed land over greenfield sites. It is therefore

unlikely that a strategic waste management facility, as a large scale (c.150,000 tonnes per

annum or greater capacity) thermal treatment plant would be classed, would be sited on

unallocated land within 10 kilometres of the SAC.


development in Surrey would be unlikely to travel along the section of the A283 (Petworth

Road / London Road) that passes along part of the western perimeter of the SAC. For the

closest proposed site allocation (Site 3 – Land NE of Slyfield IE, Guildford), the Transport

Study that has been undertaken for the Surrey WLP reports that development of a large

scale (c. 300,000 tpa capacity) EfW facility would result in a 6% increase in annual average

daily traffic (AADT) on the section of the A320 (Woking Road) closest to that proposed site


of the Transport Study predicts that traffic generated by any waste related development on

Site 3 would disperse to the strategic road network via the A320, travelling south to the A3

in Guildford. It is not predicted that any traffic would disperse in a manner that would

result in it travelling along the A283 into West Sussex and close to the SAC.


82

7.41 The closest identified ILAS to the SAC is ILAS19 (Land at Dunsfold Aerodrome, Stovolds Hill,

Cranleigh) which is situated off the A281 which links to the A29 to the south east. There is

no direct linkage from the A281 or the A29 to the A283, and it is therefore unlikely that

waste related development on land within ILAS19 would lead to additional traffic on the

section of the A283 that passes within 200 metres of the SAC.

7.42 The HRA report (URS, May 2014) prepared in respect of the adopted Chichester DC Local

Plan concluded that there would be no significant impact on the integrity of the SAC,

subject to the implementation of appropriate mitigation measures (i.e. retention of

hedgerows, tree-belts and other linear habitats used by the SAC bat species, or the

undertaking of bat surveys prior to ascertain the SAC species use of any hedgerows, tree-

belts or other linear habitats that would be removed as a consequence of development).

The published HRA reports (AECOM, 2016, 2017 and 2018) for the Waverley BC Local Plan

concluded that implementation of the policies and proposals set out in Parts 1 and 2 of that

Plan would not give rise to significant effects on the ecological integrity of the SAC, alone or

in-combination.




development). The potential for significant impacts as a consequence of point source

pollution from the development and operation of some scale and type of thermal

treatment plant at ILAS19 (Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh) cannot be

ruled out at the screening stage. Further assessment is required in respect of the air

pollution (emission and deposit of nitrogen) impact pathway with reference to point source

emissions from ILAS19 (Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh).


7.44 The feature affected by disturbance arising from human activity and development

(specifically light pollution) is the Bechsteins bat (S1323) population. The SIP (p.7/11) offers

the following explanation of the nature of the identified pressure/threat:

“It is known that light pollution has an impact on both myotis species, i.e. Bechstein's and

Horseshoe bats. The investigation would seek to identify what light levels are presently and

deduce whether they are having an impact on bat movements/roosting availability in and

around the SAC areas.”


pressure/threat are concerned with further investigation of the impact of light pollution on

the resident populations of bat species.


by the Surrey WLP could result in changes to the incidence of light pollution affecting the

SAC. The Surrey WLP is concerned with the provision of a policy framework within which

development consent decisions can be made in respect of future waste management


83

facilities within the county of Surrey. The closest Surrey WLP allocated site (Policy 11a), Site

3 (Land north east of Slyfield Industrial Estate, Guildford) is located some 23.3 kilometres to

the north of the SAC, and the closest ILAS (ILAS19 – Land at Dunsfold Aerodrome, Stovolds

Hill, Cranleigh) is 8.8 kilometres to the north east. Neither Site 3 nor ILAS19 are located

sufficiently close to the SAC to be a credible source of additional light pollution within the

designated site.



would not give rise to additional light pollution within or adjoining the SAC, and would

therefore not contribute to any significant impacts arising from the disturbance of the

designated site and species. No further assessment is required in respect of the public

access / disturbance impact pathway.



nitrogen deposition) by which development at one of the ILAS (ILA19 – Land at Dunsfold

Aerodrome, Cranleigh) identified under Policy 10 of the Surrey WLP could give rise to

significant impacts on the SAC. The mechanism by which development within ILAS19 could

contribute to the deposit of nutrient nitrogen would be emissions from a thermal

treatment plant. The Surrey WLP does not specify the type or scale of waste related

development that could be accommodated on the identified ILAS.

7.49 Emissions for a small scale thermal treatment facility at ILAS19 are estimated to account for

0.28% of the site relevant critical loads for the most sensitive habitats of the Ebernoe

Common SAC (see Part B4, Appendix B). At those concentrations nutrient nitrogen

deposition within the SAC would be less than 1% of the site relevant critical loads for beech

woodlands (10kg N/ha/yr) or broadleaved deciduous woodland (10kg N/ha/yr), and

significant effects on the integrity of the SAC would be unlikely to occur. The estimated

background deposition rate for nutrient nitrogen within woodland in the area of the SAC

closest to the ILAS is 23.1 kg/N/ha/yr (which exceeds the minimum critical loads for beech

and broadleaved deciduous woodland), and the estimated emissions for a small-scale

facility would account for only 0.12% of the estimated background deposition. The PEC

(background plus process contribution) of 23.128 kg/N/ha/yr would account for 231% of

the site relevant minimum critical loads, with the change effected by the development of

thermal treatment plant accounting for 0.12% of the PEC.

7.50 On a precautionary basis it is recommended that ILAS19 (Land at Dunsfold Aerodrome,

Cranleigh) be classed as unsuitable for the development of thermal treatment facilities with

a capacity of more than 50,000 tonnes per year with reference to the Ebernoe Common

SAC. Project level Appropriate Assessment would be required to demonstrate that any

proposed facility would give rise to emissions at a concentration no greater than 1% of the

minimum site relevant critical load for nutrient nitrogen deposition for the most sensitive


84

habitat, or that if emissions would exceed the 1% threshold that there would be no

significant adverse impacts on the ecological integrity of the SAC. Implementation of Policy

14 of the Surrey WLP, which requires that all waste related planning application be

supported by sufficient information for the WPA to ascertain whether the proposed

development would result in significant adverse impacts on the natural environment,

including SPAs and SACs, will ensure that permitted development does not compromise the

ecological integrity of the SAC.

7.E Conclusions


ecological integrity of the Ebernoe Common SAC has concluded that overall there would be


11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS19 – Dunsfold

Aerodrome, Cranleigh) identified under Policy 10 of the Surrey WLP is 8.8 kilometres to the

north east. Development of a thermal treatment facility on land at ILAS19 could, in theory

result in nutrient nitrogen deposition within the SAC, and traffic arising from development

within the ILAS could also contribute to such deposition. Given the relationship of ILAS19 to





assessment).







Level

Changes in forestry and

woodland management

practices – discussed further

in section 7.C.1



WLP

Screening

Changes in off-site habitat

availability– discussed further

in section 7.C.2



WLP

Screening

Changes due to habitat

fragmentation – discussed




WLP

Screening


85


Level



in section 7.C.4



WLP

Screening

Changes in local hydrological

conditions – discussed further

in section 7.C.5



WLP

Screening




& section 7.D


Potential for adverse impacts from nutrient

nitrogen deposition arising from process emissions

(thermal treatment plant) and traffic emissions.


at ILAS19.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

Changes in the incidence of

public access / disturbance –

discussed further in section

7.C.7



WLP

Screening

7.F References


process for the Ebernoe Common SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Ebernoe Common




& designated SACs) – Ebernoe Common SAC (Joint Nature Conservation


7.53.3 European Site Conservation Objectives for Ebernoe Common Special Area of



86

7.53.4 Site Improvement Plan: Ebernoe Common SAC (Natural England, 6 March

2015).



7.53.6 Ebernoe Common SSSI Condition Survey Report (Natural England, Designated




June 2018

7.53.9 Habitat Regulations Assessment for the emerging Local Plan, URS for

Chichester District Council, May 2014






87

Chapter 8 Mole Gap to Reigate Escarpment SAC



8.1 The Mole Gap to Reigate Escarpment SAC (see map) is located in the county of Surrey and is

composed of a single SSSI, the Mole Gap to Reigate Escarpment SSSI. The SAC covers an

area of 887.68 hectares, as stated on the SAC citation, and was designated on 1 April 2005.

The SAC is situated within an area administered by Mole Valley DC, by Reigate & Banstead

BC, and by Surrey CC.

8.2 The SAC is dissected by a number of road links, including the following ‘A’ class roads.

8.2.1 The A24 (London Road) – which passes through the SAC to the south of

Leatherhead.

8.2.2 The M25 motorway – which comes within 200 metres of the SAC to the north

of Reigate.

8.2.3 The A217 – which comes within 200 metres of the SAC to the north of Reigate.

8.3 The SAC is situated within a single surface water catchment, that of the Mole (Horley to

Hersham) (GB106039017621), which lies wholly within the county of Surrey.


8.4 The Mole Gap to Reigate Escarpment SAC is located within 10 kilometres of the following

sites proposed for allocation under Policy 11a of the Surrey WLP (see Figure 8-A – a full size

version can be found in Appendix A). One of those sites (Site 4) is currently allocated for

waste related development under policy WD2 of the adopted Surrey Waste Plan (2008).

The SAC is located within 10 kilometres of the following ILAS (see below) identified under

Policy 10 of the Surrey WLP (see Figure 8-A). The Plan does not specify the type or scale of

waste related development that could be accommodated on the identified ILAS.

Site 4 (Land to the west of Leatherhead Sewage Treatment Works, Randalls Road,

Leatherhead), 2.9 kilometres to the north of the SAC.

Site 5 (Land to the west of Lambs Business Park, Terra Cotta Road, South Godstone),

8.4 kilometres to the south east of the SAC.

ILAS10 (Land near Dorking West Station, Curtis Road / Station Road, Dorking), 1.7

kilometres to the south west of the SAC.

ILAS11 (Holmethorpe Industrial Estate, Redhill), 2.5 kilometres to the west of the SAC.



88

ILAS12 (Perrywood Business Park, Honeycrock Lane, Salfords), 5.9 kilometres to the

south east of the SAC.

ILAS13 (Salfords Industrial Estate, Bonehurst Rad / Brighton Road, Salfords), 6.1

kilometres to the south of the SAC.

ILAS04 (Longmead Industrial Estate, Longmead Road, Epsom), 7.3 kilometres to the

north of the SAC.

Figure 8-A: Mole Gap to Reigate Escarpment SAC – Relationship to sites & ILAS proposed by the

Surrey WLP

8.5 The following sites proposed for minerals or waste related development in the adopted

Surrey Minerals Plan, or the Aggregates Recycling Joint DPD, are located within 5 kilometres

of the SAC.

8.5.1 The area of land identified as ‘Preferred Area P: Mercers Farm, Nutfield’ in the

Primary Aggregates DPD of the Surrey Minerals Plan lies some 4.2 kilometres

to the east of the SAC. Planning permission (TA/2013/1799) for the extraction

of soft sand was granted on 12 August 2014.

8.5.2 The area of land identified as ‘Preferred Area S: Pendell Farm, Bletchingley’ in

the Core Strategy DPD of the Surrey Minerals Plan lies some 5.0 kilometres to

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Mole Gap to Reigate Escarpment SAC

Mole Gap to Reigate

Escarpment SAC


Site 5: Lambs BP

Site 3: Slyfield IE

ILAS10

ILAS11

ILAS12

ILAS13

ILAS04

ILAS18

N

S

W E

20 km

30 km

40 km

50 km

Site 1: OakleafFarm

Site 2: Weylands TW

Site 6: Trumps Farm




ILAS07 ILAS09

ILAS17

ILAS19

ILAS20 ILAS21


89

the east of the SAC. Planning permission (TA09/1536) for the extraction of

silica sand from an area of some 20 hectares within the preferred area was

granted on 23 March 2012.

8.5.3 The area of land identified as ‘Area of Search S: Chilmead Farm, Nutfield

Marsh’ in the Core Strategy DPD of the Surrey Minerals Plan lies some 3.5

kilometres to the east of the SAC.




Site Description

Woodland, chalk grassland, chalk scrub & heathland form an interrelated mosaic at this site on the North Downs.

On the generally acidic plateau deposits of the crest of the Downs, the woodland is dominated by beech Fagus sylvatica, pedunculate oak Quercus robur, ash Fraxinus excelsior & yew Taxus baccata. On the lime-rich chalk slopes, the dominant trees are beech, ash & yew, together with field maple Acer campestre & common whitebeam Sorbus aria agg. & occasional large-leaved lime Tilia platyphyllos.

Yew woodland has been formed both by invasion of chalk grassland & from development within beech woodland following destruction of the beech over-storey. Yew occurs in extensive stands, with, in places, an understorey of box Buxus sempervirens. This site supports the only area of stable box scrub in the UK, on steep chalk slopes where the River Mole has cut into the North Downs Escarpment, creating the Mole Gap. Here natural erosion maintains the open conditions required for the survival of this habitat type.

The site supports a range of species-rich chalk grassland types on steep slopes, dominated by red fescue Festuca rubra, sheep’s-fescue F. ovina, quaking-grass Briza media &, in taller areas, upright brome Bromopsis erecta, tor-grass Brachypodium pinnatum & slender false-brome grass Brachypodium sylvaticum. Typical herbs include salad burnet Sanguisorba minor, yellow-wort Blackstonia perfoliata & field scabious Knautia arvensis. The site supports important populations of the nationally scarce musk orchid Herminium monorchis & man orchid Aceras anthropophorum, the former occurring in areas of shorter turf. A range of more widespread but local orchids are also present, including autumn lady’s-tresses Spiranthes spiralis & green-winged orchid Orchis morio, as well as commoner species, such as pyramidal orchid Anacamptis pyramidalis, fragrant orchid Gymnadenia conopsea & bee orchid Ophrys apifera.

The acidic plateau deposits on Headley Heath support acidic heathland, dominated by heather Calluna vulgaris, bell heather Erica cinerea & dwarf gorse Ulex minor, often mixed with grasses such as wavy hair-grass Deschampsia flexuosa & common bent Agrostis capillaris. Chalk heath occurs on a small area of Headley Heath where the special conditions allow both acid & lime-loving plants to grow side by side. An old chalk mine is used as a winter roost by several species of bats.


90

Qualifying Habitats


Taxus baccata woods of the British Isles. (Yew-dominated woodland) (Annex I Priority Habitat).

Asperulo-Fagetum beech forests. (Beech forests on neutral to rich soils).

European dry heaths.

Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia) (Dry grasslands & scrublands on chalk or limestone).

Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia) (important orchid sites). (Dry grasslands & scrublands on chalk or limestone, including important orchid sites) (Annex I Priority Habitat).

Stable xerothermophilous formations with Buxus sempervirens on rock slopes (Berberidion p.p.). (Natural box scrub).

Qualifying Species


Bechstein’s bat Myotis bechsteinii.

Great crested newt Triturus cristatus.



“With regard to the SAC & the natural habitats &/or species for which the site has been designated (the ‘Qualifying Features’ listed below), & subject to natural change;



The structure & function (including typical species) of qualifying natural habitats;

The structure & function of the habitats of qualifying species;

The supporting processes on which qualifying natural habitats & the habitats of qualifying species rely;

The populations of qualifying species; &,


Qualifying Features

H4030. European dry heaths.

H5110. Stable xerothermophilous formations with Buxus sempervirens on rock slopes (Berberidion p.p.); Natural box scrub.

H6210. Semi-natural dry grasslands & scrubland facies: on calcareous substrates (Festuco-Brometalia) (important orchid sites); Dry grasslands & scrublands on chalk or limestone (important orchid sites) (Annex I Priority Habitat).


91

H9130. Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils

H91J0. Taxus baccata woods of the British Isles; Yew-dominated woodland (Annex I Priority Habitat)

S1166. Triturus cristatus; Great crested newt

S1323. Myotis bechsteinii; Bechstein`s bat


report for the Mole Gap to Reigate Escarpment SSSI12 (see Table 8-A), the designated site

extends to some 985.96 hectares, of which some 51.33 % is in ‘favourable’ condition, some

48.15% is in ‘unfavourable – recovering’ condition, and some 0.52% is in ‘unfavourable – no

change’ condition. The majority of the SSSI is composed of two main habitat types,

‘broadleaved, mixed and yew woodland – lowland’ (671.10 hectares) and ‘calcareous

grassland – lowland’ (312.80 hectares), with a small area designated for its ‘earth heritage’

interest (2.06 hectares).

Table 8-A: Mole Gap to Reigate Escarpment SSSI – Condition Survey Findings

Main Habitat Type



Recovering Unfavourable – No

Change


Lowland

671.10 ha 323.77 ha

[48.2% of the habitat]

347.33 ha


0.0 ha


Calcareous Grassland –

Lowland 312.80 ha

180.27 ha


127.40 ha


5.13 ha


Earth Heritage 2.06 ha 2.06 ha


0.0 ha


0.0 ha


Totals 985.96 ha 506.10 ha

[51.33% of the SSSI] 474.73 ha

[48.15% of the SSSI] 5.13 ha

[0.52% of the SSSI]

8.9 For the 5.13 hectares of calcareous grassland habitat (SSSI unit number 37, last surveyed on

14 October 2009) classified as exhibiting ‘unfavourable – no change’ condition, the

condition survey report provides the following explanation and analysis.

Comments: Area remains with several isolated patches of species rich grassland with up to 50%

scrub, rabbit grazed, not fenced & very steep. Frequent species include salad burnet, bird’s-foot

trefoil, dwarf thistle, hairy violet, mouse-ear hawkweed & thyme. Occasional species include

rock rose, Squinancywort, rough hawkbit, & fairy flax, species occurring more rarely gentians,

carline thistle & autumn lady’s-tresses. Torgrass in excess of 10% plus scrub levels in excess of

50%, both negative indicators.”

Reasons for adverse condition: Lack of Corrective Works - Inappropriate Scrub Control”

12 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000977&ReportTitle=Mole%20Gap%20to%20Reigate%20Escarpment%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000977&ReportTitle=Mole%20Gap%20to%20Reigate%20Escarpment%20SSSI


92


8.10 The published Site Improvement Plan for the SAC (09/10/2014) for identifies the following

key pressures and threats to the site’s ecological integrity.

Changes arising from the incidence of plant disease (box blight) – discussed further in

section 8.C.1;

Changes in scrub control practices– discussed further in section 8.C.2;

Changes in land management practices – discussed further in section 8.C.3;


8.C.4;


in section 8.C.5.

8.C.1 Disease

8.11 The feature of the SAC potentially affected by the spread of plant disease (box blight) is the

natural box scrub (H5110) habitat. The SIP (p.4/12) offers the following explanation of the

nature of the identified pressure/threat:

“Box blight has been recorded on the site & has been shown to be spreading & affecting the

SAC feature 'stable box scrub on steep chalk slopes'. This is the only native site for this

feature.”


pressure/threat are concerned with assessing the extent of box blight, and investigating the

causes of yew tree deaths, starting discussions around biosecurity and potential exclusion

zones, and a possible biosecurity plan, establishing a working group to look at the future of

box, and developing a strategic overview of box in the SAC.

8.13 Screening Evaluation: It is conceivable that certain types of waste management facility

could present a risk to the SAC in terms of the spread of plant disease, where facilities are

located in close proximity to the sensitive habitats. Sites that handle green waste, and

particularly waste arising from domestic and other types of gardens, and from horticultural

businesses, could harbour a range of plant diseases, including the box blight that is a

particular concern for the SAC. None of the sites proposed for allocation under Policy 11 of

the Surrey WLP are in close enough proximity (<1.0 kilometres) to the SAC (the closest is

‘Site 4 – Land west of Leatherhead Sewage Treatment Works, Randalls Road, Leatherhead’,

some 2.9 kilometres to the north) to present a genuine risk of plant disease dispersal. None

of the areas of land identified under Policy 10 of the Surrey WLP are in close enough

proximity (<1.0 kilometres) to the SAC (the closest is ‘ILAS10 – Land near Dorking West

Station, Curtis Road / Ranmore Road, Dorking, some 1.7 kilometres to the south west) to

present a genuine risk of plant disease dispersal. The majority of the land surrounding the

SAC lies within the Metropolitan Green Belt, and it is therefore unlikely that waste related


93

development would be brought forward on non-allocated or unidentified land in closer

proximity to the SAC than the closest site allocation and identified ILAS, as strategic waste

management facilities would typically be classed as inappropriate development in a Green

Belt context.




the dispersal of plant diseases harmful to the sensitive habitats. The proposed site

allocations and identified ILAS are too distant (>1.0 kilometres) to present a credible plant

disease threat to the SAC, and the Green Belt status of the land surrounding the SAC limits

the probability of waste development being brought forward in closer proximity to the

sensitive habitats. No further assessment is required in respect of the plant disease impact

pathway.

8.C.2 Inappropriate scrub control 8.15 The feature affected by inappropriate scrub control practices is the dry grasslands and

scrublands on chalk or limestone (important orchid sites) (H6210) habitat. The SIP (p.5/12)

offers the following explanation of the nature of the identified pressure:

“Scrub is encroaching onto the chalk grassland. This can quite quickly shade out more delicate

& rare plant species found on the chalk slopes, & any associated insect species are also

therefore negatively impacted on.”


concerned with agreeing and implementing a programme of scrub clearance to reverse the

effects of encroachment on calcareous grassland, and with identifying future threats from

scrub invasion, following a condition assessment programme


by the Surrey WLP would impact upon current or future scrub control practices within the

SAC. The only points at which the scrub control regime implemented across the SAC may



time to time as a consequence of active scrub management (e.g. green waste from

clearance, etc.). The SAC and the land surrounding it lies within the Metropolitan Green

Belt, and it is therefore unlikely that waste related development would be brought forward

on non-allocated or unidentified land in closer proximity to the SAC than the closest

proposed site allocation (Site 4, 2.9 kilometres to the north) or identified ILAS (ILAS10, 1.7

kilometres south west), as strategic waste management facilities would typically be classed

as inappropriate development in a Green Belt context.


94



would not give rise to direct or indirect significant impacts on scrub control practices within

the SAC, and therefore would not affect the condition of the heathland habitats. No further

assessment is required in respect of the inappropriate scrub control impact pathway.

8.C.3 Change in land management 8.19 The feature affected by changes in land management practice is the dry grasslands and

scrublands on chalk or limestone (important orchid sites) (H6210) habitat. The SIP (p.5/12

to 6/12) offers the following explanation of the nature of the identified threat.

“To maintain a species-rich sward & its associated insects & other invertebrates, chalk

grasslands require active management - some parts of the site do not have appropriate active

management. Without it the grassland will rapidly become dominated by rank grasses, such

as Tor-grass. Together with the build up of dead plant matter, less vigorous species will be

suppressed & the diversity of the site will decrease. Eventually, the site will scrub over.

Traditionally, management is achieved by grazing. The timing will vary both between & within

sites, according to local conditions & specific species requirements.”


concerned with exploring the possibilities of a landscape-scale grazing project to target

areas as yet ungrazed, introducing appropriate landscape scale grazing on the site, and with

establishing woodland management across the landscape with objectives to meet

favourable condition in all woodland plans and subsequent funding streams.



the SAC. The only points at which the land management regime implemented across the

SAC may interface with waste management operations and practices would be in respect of



scrub clearance, disposal of fallen stock, etc.). The SAC and the land surrounding it lies

within the Metropolitan Green Belt, and it is therefore unlikely that waste related

development would be brought forward on non-allocated or unidentified land in closer

proximity to the SAC than the closest proposed site allocation (Site 4, 2.9 kilometres to the

north) or identified ILAS (ILAS10, 1.7 kilometres south west), as strategic waste


Belt context.




on the SAC. No further assessment is required in respect of the changes in land



95


8.23 The features affected by changes in public access arrangements and associated disturbance

risks are the dry grasslands and scrublands on chalk or limestone (important orchid sites)

(H6210) habitat, the population of Great crested newt (S1166), and the population of

Bechstein’s bat (S1323). The SIP (p.6/12 to 7/12) offers the following explanation of the

nature of the identified threat.

“As a beautiful place to visit, this area of Surrey is heavily populated. Increasing pressure by

increased numbers of visitors on protected sites & disturbance on the species which live here

can become damaging. Trampling of orchid-rich grasslands, repetitive disturbance to Great

crested newt breeding ponds, & spread of disease (such as box blight) are examples.”

8.24 The actions identified as the principal means of addressing the threat are concerned with:

Assessing the scale of impact on key habitats due to public access pressure across the

SAC.

Ensuring the main Bechstein's bat hibernacula are secure.

Assessing the extent of disturbance to ponds with known populations of Great crested

newts, and devising plans to prevent disturbance for at least half of the area of each of

the disturbed pond.

Plan to build five new ponds in rarely visited parts of the site, for the benefit of Great

crested newts.

Secure improvements to Bechstein's bat hibernacula, and habitat connectivity.


by the Surrey WLP could result in changes in the number of visitors to the SAC. The Surrey

WLP is concerned with the provision of a policy framework within which development

consent decisions can be made in respect of future waste management facilities within the

county of Surrey. The closest ILAS identified as potentially suitable for waste related

development and site allocated for waste development in the Surrey WLP are ILAS10 (Land

near Dorking West Station, Dorking) some 1.7 kilometres to the south west and Site 4

(Randalls Road, Leatherhead) some 2.9 kilometres to the north. Operational waste facilities

would not typically be a source of prospective visitors, compared with, for example,

residential development.



would not give rise to additional visitors to the SAC, and would therefore not contribute to

any significant impacts arising from public access to, and disturbance of, the designated

site. No further assessment is required in respect of the public access / disturbance impact

pathway.


96


8.27 The features affected by changes in the atmospheric deposition of nutrient nitrogen are the

European dry heaths (H4030) habitat, the natural box scrub (H5110) habitat, the dry

grasslands and scrublands on chalk or limestone (important orchid sites) (H6210) habitat,

the beech forests on neutral to rich soils (H9130) habitat, the yew-dominated woodland

(H91J0) habitat, and the habitats of the Bechstein`s bat (S1323). The SIP (p.8/12) offers the

following explanation of the nature of the identified threat:





concerned with undertaking further investigation of potential atmospheric nitrogen

impacts on the site (based on guidance from the Chief Scientist's Nitrogen Task & Finish

Group), and with monitoring the indicators of increased nitrogen deposition, such as

vigorous grass growth, increase in Tor-grass and other grasses, and a decrease in orchid

species through the use of fixed point quadrat surveys over 5 years.

8.29 Screening Evaluation: The Surrey WLP is likely to result in development that will give rise to

emissions of nitrogen containing compounds that could contribute to nutrient deposition

on the SAC. Of particular concern are waste management facilities that make use of

thermal treatment technologies to dispose of waste and recover energy, and the vehicle

movements associated with the construction and operation of all types of waste

management facilities.

8.30 The potential for thermal treatment development at two of the sites allocated under Policy

11a (see below) to give rise to likely significant effects has been identified on the basis of

predicted process contributions being equivalent to 1% of more of the minimum site

relevant critical load for the most sensitive habitat within the SAC (see Part B5, Appendix B).

Site 4: Land at Leatherhead STW, Randalls Road, Leatherhead.

Site 5: Land at Lambs Business Park, Terra Cotta Road, South Godstone

8.31 Five of the ILAS (see below) identified under Policy 10 are located within 10 kilometres of

the SAC. The development of thermal treatment facilities on land located within any one of

those five ILAS could, in theory, present risks of nutrient nitrogen deposition on land within

the SAC.

ILAS04 – Longmead Industrial Estate, Epsom.

ILAS10 – Land at Dorking West Station, Dorking.

ILAS11 – Holmethorpe Industrial Estate, Redhill.

ILAS12 – Perrywood Business Park, Honeycrock Lane, Salfords.


97

ILAS13 – Salfords Industrial Estate, Salfords.

8.32 In terms of the potential for diffuse emissions, a proportion of the traffic generated by

waste related development at the closest proposed site allocation (Site 4 – Leatherhead

STW) could be reasonably expected to travel along the section of the M25 that passes

within 200 metres of the SAC, or the section of the A24 that passes within 200 metres of

the SAC.



strategic road networks. None of the five ILAS that are located within 10 kilometres of the

SAC are accessed directly from roads that run through or pass within 200 metres of the

SAC. All five do, however, connect to those aspects of the road network (A24 and M25) that

do pass through or within 200 metres of the SAC, and in combination with the development

of Site 4 (Leatherhead STW, Leatherhead) could contribute to increased traffic movements

through the SAC.

8.34 Screening Conclusion: The potential for significant impacts on the SAC as a consequence of

point source emissions of nutrient nitrogen, from the development and operation of some

scale and type of thermal treatment plant at one or more allocated sites situated within 10

kilometres of the SAC, and of diffuse emissions arising from traffic generated by waste

development cannot be ruled out at the screening stage. Further assessment is required in

respect of the air pollution (emission and deposit of nitrogen) impact pathway in respect of

point source emissions from one or more of the allocated sites and identified ILAS, and in

terms of diffuse emissions from traffic generated by waste related development at those

locations.



deposition of nitrogen) by which development of two of the sites (Site 4: Leatherhead STW,

Leatherhead; and Site 5: Lambs Business Park, South Godstone) allocated under Policy 11a

and five of the ILAS identified under Policy 10 of the Surrey WLP could give rise to

significant effects on the SAC. The mechanisms by which the development of the allocated

sites and the identified ILAS could contribute to the deposit of nutrient nitrogen would be

point source pollution from thermal treatment plants, and diffuse emissions from traffic

generated by the waste facilities.

8.D.1 Emissions from thermal treatment facilities

8.36 In total seven areas of land allocated or otherwise identified under policies in the Surrey

WLP are located within 10 kilometres of the Mole Gap to Reigate Escarpment SAC.

Modelling of the potential effects of a range of scales of thermal treatment plants has been

carried out for the allocated sites (see Part B5, Appendix B, and Appendix C). For the ILAS,


98

for which detailed modelling has not been carried out, judgements (see Part B5, Appendix

B) have been made on the basis of the findings of the modelling undertaken for the

allocated sites (and sites previously proposed for allocation at the Regulation 18 stage of

the Surrey WLP). The ILAS were not considered to be suitable candidates for the siting of

large scale (>50,000 tpa) thermal treatment facilities, and the assessment therefore only

considered the impacts of small scale (<50,000 tpa) facilities at those locations. Details of

the site relevant critical loads for all the features covered by the SAC designation can be

found in Part B5 of Appendix B to this report.

8.37 For Site 4 (Leatherhead STW, Leatherhead) the modelling (see Part B5, Appendix B)

indicated that the emissions arising under each of the four scenarios considered would

account for more than 1% of the minimum site relevant critical loads across each habitat

type covered by the SAC designation. The estimated background deposition rates for

nutrient nitrogen within the area of the SAC closest to Site 4 exceed the minimum site

relevant critical loads across all the habitat types covered by the SAC designation (see Part

B5, Appendix B). The PEC (background plus process contribution) would increase by

between 0.7% to 2.2% for coniferous woodland and beech woodland, and by between 1.1%

to 3.5% for dry heaths and calcareous grassland.

8.38 For Site 5 (Lambs BP, South Godstone) the modelling (see Part B5, Appendix B) indicated

that the emissions arising under three of the four scenarios considered would account for

more than 1% of the minimum site relevant critical loads across each habitat type covered

by the SAC designation. For the fourth scenario (construction of a <50,000 tpa gasification

facility) the modelled process contributions accounted for between 0.6% and 0.2% of the

minimum site relevant critical loads for the SAC habitats. The estimated background

deposition rates for nutrient nitrogen within the area of the SAC closest to Site 5 exceed the

minimum site relevant critical loads across all the habitat types covered by the SAC

designation (see Part B5, Appendix B). The PEC (background plus process contribution)

would increase by between 0.1% to 0.4% for coniferous woodland and beech woodland,

and by between 0.2% to 0.7% for dry heaths and calcareous grassland.

8.39 For the five ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SAC it was concluded that four would be unsuitable as locations for small-

scale thermal treatment facilities (<50,000 tpa), and that one (ILAS04: Longmead Industrial

Estate, Epsom) could accommodate such a facility without giving rise to nitrogen deposition

within the SAC equivalent to more than 1% of the minimum site relevant critical loads for

all habitat classes. ILAS10 (Land at Dorking West Station, Dorking) was found to be a

unlikely to be suitable as a location for a small scale thermal treatment facility, due to its

geographical proximity and relationship to the SAC (1.7 kilometres to the south west). For

ILAS11 (Holmethorpe IE, Redhill), ILAS12 (Perrywood BP, Salfords) and ILAS13 (Salfords IE,

Salfords) it may be feasible for a small scale (<50,000 tpa) thermal treatment facility to be

accommodated in one of those locations subject to it being demonstrated at the planning

application stage that the ecological integrity of the SAC would not be adversely affected.

The scope for the development of a thermal treatment facility on land at ILAS11, ILAS12 or

ILAS13 would also be dependent on the type and scale of waste related development that


99

proceeds on the sites allocated (Site 4 and Site 5) under Policy 11a of the Surrey WLP that

lie within 10 kilometres of the SAC. If both of the allocated sites were to be brought

forward for some scale and type of thermal treatment facility the need to manage the

possibility of in-combination effects arising would reduce the suitability of ILAS11, ILAS12

and ILAS13 as potential locations for thermal treatment facilities. Implementation of Policy

14 of the Surrey WLP, which requires that all waste related planning application be

supported by sufficient information for the WPA to ascertain whether the proposed

development would result in significant adverse impacts on the natural environment,

including SPAs and SACs, will ensure that permitted development does not compromise the

ecological integrity of the SAC.

8.D.2 Emissions from traffic arising from waste management facilities

8.40 One allocated site (Site 4: Leatherhead STW, Leatherhead) and five of the ILAS (ILAS04;

ILAS10; ILAS11; ILAS12; and ILAS13) identified in the Surrey WLP are situated such that their

development could give rise to additional traffic on those sections of the A24 and M25 that

pass through or within 200 metres of the Mole Gap to Reigate Escarpment SAC. If all the

traffic that would be generated if Site 4 (Leatherhead STW) were developed as a large scale

facility (i.e. c.300,000 tpa capacity energy from waste plant), were to travel east along the

M25 or to travel south down the A243 to the A24, that could equate to an additional 838

vehicles on sections of road that pass within 200 metres of the SAC. That number of

vehicles is close to the 1,000 AADT threshold cited in the Design Manual for Roads &

Bridges (Volume 11, Section 3, May 2007), however in practice it is unlikely that 100% of

the traffic generated at Site 4 would travel east along the M25, or south along the A24, and

more likely that traffic would disperse onto the highway network in a number of different

directions.

8.41 For the five ILAS that are located within 10 kilometres of the SAC it is assumed that smaller

scale (c.50,000 tpa) waste management facilities would be constructed at all five locations,

generating an additional 200 two-way vehicle movements per day (40 movements per

facility). In practice it is unlikely that all traffic arising from the waste facilities on the ILAS

would pass through of within 200 metres of the SAC.

8.41.1 ILAS04 (Longmead Industrial Estate, Epsom) is linked to the A24 and via that

road to the M25, and could result in vehicles travelling along those sections of

those roads that pass through the SAC to the south and south east

respectively. Given the urban setting of the ILAS, and taking account of its

proximity to potential waste sources, including the Greater London

conurbation, it is unlikely that 100% of the vehicles servicing any waste facility

on ILAS04 would travel south along the A24 or south and east on the M25, and

through or within 200 metres of the SAC.

8.41.2 ILAS10 (Land at Dorking West Station, Dorking) is linked to the A24 and the

A25, and could result in vehicles travelling along those sections of the A24 that

pass through the SAC to the north. Given the setting of the ILAS within the

settlement of Dorking, and taking account of its linkage to Guildford to the


100

west and Reigate and Redhill to the east via the A25, it is unlikely that 100% of

the vehicles servicing any waste facility on ILAS10 would travel north along the

A24 and through or within 200 metres of the SAC.

8.41.3 ILAS11 (Holmethorpe Industrial Estate, Redhill), ILAS12 (Perrywood Business

Park, Salfords) and ILAS13 (Salfords Industrial Estate, Salfords) are all linked to

the A23, and it is therefore unlikely that 100% of traffic arising from any waste

facilities developed at those locations would travel along those sections of the

A24 or the M25 that pass through or within 200 metres of the SAC.

8.E Conclusions


ecological integrity of the Mole Gap to Reigate Escarpment SAC has concluded that overall

there would be no potential for ‘likely significant effects’ to arise, subject to the

observation of a number of decision rules with reference to the development of thermal

treatment facilities.

8.42.1 Two of the sites allocated under Policy 11 (Site 4: Leatherhead STW,

Leatherhead; and, Site 5: Lambs BP, South Godstone) and five of the ILAS

(ILAS04; ILAS10; ILAS11; ILAS12; and, ILAS13) identified under Policy 10 of the

Surrey WLP are located within 10 kilometres of the SAC. The construction and

operation of large scale (>50,000 tpa) thermal treatment facilities is not

recommended on either of the allocated sites, although there may be greater

scope for the development of a facility with a capacity of more than 50,000 tpa

at Site 5 (Lambs BP, South Godstone), subject to the outcome of detailed

modelling and assessment at the planning application stage. In the interests of

managing the risk of in-combination effects it is recommended that four of the

identified ILAS, ILAS10, ILAS11, ILAS12 and ILAS13, would be unsuitable

locations for small-scale (<50,000 tpa) thermal treatment plants.

8.42.2 The potential effects of emissions from traffic generated by waste

management facilities have been considered, but the relationship of the

allocated sites and identified ILAS to the road network and potential sources of

waste is such that it is unlikely that all traffic arising from new waste

management facilities, even in the event of all seven sites being brought

forward for such development, would travel along those sections of the A24

and the M25 that pass through or within 200 metres of the SAC.

8.43 The assessment considered the five impact pathways identified as key threats and





101



Level

Changes arising from the

incidence of plant disease

(box blight) – discussed




WLP

Screening

Changes in scrub control

practices– discussed further

in section 8.C.2



WLP

Screening



in section 8.C.3



WLP

Screening




8.C.4



WLP

Screening

Changes arising from air

pollution (atmospheric

nitrogen deposition) –


8.C.5

Two allocated sites (Site 4 and Site 5) and five ILAS

(ILAS04, ILAS10, ILAS11, ILAS12, ILAS13) located

within 10 km of the SAC. Potential for adverse

impacts from nutrient nitrogen deposition arising

from process emissions (thermal treatment plant)

and traffic emissions.


at Site 4, ILAS10, ILAS11, ILAS12 and ILAS13.

Small scale (<50,000 tpa) feasible at Site 5 and

ILAS04.











Assessment

of Likely

Significant

Effects

(Process

Emissions &

Traffic

Emissions)

8.F References


process for the Mole Gap to Reigate Escarpment SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Mole Gap to

Reigate Escarpment SAC (Natural England (English Nature), May 2005).


102



& designated SACs) – Mole Gap to Reigate Escarpment SAC (Joint Nature

Conservation Committee (JNCC), 25 January 2016).

8.44.3 European Site Conservation Objectives for Mole Gap to Reigate Escarpment

Special Area of Conservation (Site Code: UK0012804) (Natural England, 30 June

2014, v.2).

8.44.4 Site Improvement Plan: Mole Gap to Reigate Escarpment SAC (Natural England,

9 October 2014).



8.44.6 Mole Gap to Reigate Escarpment SSSI Condition Survey Report (Natural




June 2018

8.44.9 Surrey Waste Local Plan: Air Quality Impact Assessment, AECOM for Surrey

County Council, June 2018




103

Chapter 9 Richmond Park SAC


9.A.1 Composition & Location

9.1 The Richmond Park SAC (see map) is located in the London Borough of Richmond, and is

composed of a single SSSI, the Richmond Park SSSI. The SAC covers an area of 846.27

hectares, as stated on the SAC Standard Data Form, and was designated in December 2004.

The SAC is situated within an area administered by the London Borough of Richmond and

by the Greater London Authority.

9.2 The following ‘A’ class roads pass within 200 metres of the SAC

9.2.1 The A3 (Roehampton Vale) – which passes within 200 metres of the southern

boundary of the SAC.

9.2.2 The A308 (Kingston Vale) – which passes within 200 metres of the southern


9.2.3 The A307 (Petersham Road) – which passes within 200 metres of the western

perimeter of the SAC.

9.3 The SAC is situated across two surface water catchments, neither of which lie wholly or

partly within the county of Surrey, but one of which (the Upper Thames) is downstream of

surface water catchments (Thames (Egham to Teddington), GB106039023232) that do

include land within Surrey.

9.3.1 The Beverley Brook (Motspur Park to Thames) & Pyl Brook at West Barnes

(GB106039022850)

9.3.2 The tidal Upper Thames (GB530603911403).

9.A.2 Minerals & waste development plan proposals in Surrey within 10 kilometres of

the SAC

9.4 The Richmond Park SAC is located within 10 kilometres of the following site proposed for

allocation under Policy 11a of the Surrey WLP (see Figure 9-A – a full size version can be

found in Appendix A). That site is currently allocated for development under Policy WD2 of

the adopted Surrey Waste Plan (2008). The SAC is located within 10 kilometres of the

following ILAS (see below) identified under Policy 10 of the Surrey WLP (see Figure 9-A).





104

‘Site 2 – Land at the former Weylands Treatment Works, Molesey Road, Walton on

Thames’ is located some 7.8 kilometres to the south west of the SAC.

ILAS02 (Hersham Trading Estate, Lyon Road, Walton on Thames), which is located 8.2


ILAS03 (Molesey Industrial Estate, Central Avenue, West Molesey), which is located 6.7


ILAS04 (Longmead Industrial Estate, Longmead Road, Epsom), which is located 8.5

kilometres to the south east of the SAC.

ILAS16 (Windmill Road Industrial Area, Sunbury on Thames), which is located 9.7

kilometres to the west of the SAC.

Figure 9-A: Richmond Park SAC – Relationship to sites & ILAS proposed by the Surrey WLP

9.5 None of the preferred areas for mineral working identified in the adopted Surrey Minerals

Plan, or sites proposed for development in the Aggregates Recycling Joint DPD are situated

within 5 kilometres of the SAC. The Habitat Regulations Assessments undertaken in respect

of both of those plans concluded that the ecological integrity of the SAC would not be


<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Richmond Park SAC

Site 2: Weylands TW

Site 6: Trumps

Farm

Site 1: Oakleaf

Farm

ILAS02; ILAS03

ILAS04

ILAS16

Richmond Park SAC

N

S

W E

20 km

30 km

40 km

50 km

Site 3: Slyfield IE


Site 5: Lambs BPILAS01; ILAS15


ILAS07; ILAS08 ILAS10

ILAS14


ILAS17

ILAS18

ILAS19

ILAS20;ILAS21


105



reasons for its designation, is described as follows in the published citation

Site Description

Richmond Park has been managed as a royal deer park since the seventeenth century, producing a range of habitats of value to wildlife. In particular, Richmond Park is of importance for its diverse deadwood beetle fauna associated with the ancient trees found throughout the parkland. Many of these beetles are indicative of ancient forest areas where there has been a long continuous presence of over-mature timber. The site is at the heart of the south London centre of distribution for stag beetle Lucanus cervus.

Qualifying Species


Stag beetle Lucanus cervus



With regard to the natural habitats &/or species for which the site has been designated (“the Qualifying Features”): Avoid the deterioration of the qualifying natural habitats & the habitats of qualifying species, & the significant disturbance of those qualifying species, ensuring the integrity of the site is maintained & the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying features. Subject to natural change, to maintain or restore:


The structure & function (including typical species) of qualifying natural habitats & habitats of qualifying species;

The supporting processes on which qualifying natural habitats & habitats of qualifying species rely;

The populations of qualifying species;


Qualifying Features

S1083. Lucanus cervus; Stag beetle


106


107


report for the Richmond Park SSSI13 (see Table 9-A for a summary), the designated site

extends to some 846.43 hectares, of which some 100% is in ‘unfavourable – recovering’

condition. The majority of the SSSI is composed of two main habitat types, ‘acid grassland –

lowland’ (735.69 hectares) and ‘broadleaved, mixed & yew woodland’ (110.74 hectares).

Table 9-A: Richmond Park SSSI – Condition Survey Findings

Main Habitat Type Condition Classification

Unfavourable – Recovering


110.74 ha 110.74 hectares (13.1%)

Acid grassland - lowland 735.69 ha 735.69 hectares (86.9%)

Totals 846.43 ha 846.43 hectares (100%)


9.9 The published Site Improvement Plan (SIP) for the SAC (11 December 2014) does not

identify any pressures or threats that are currently of concern with respect to the SACs

ecological integrity.

9.10 The published Conservation Objective Supplementary Advice (COSA) report (29 February

2016) offers guidance on the actions that are required to maintain the habitat of the SAC in

a condition that supports the invertebrate species (the Stag beetle) for which it is

designated. In the absence of any identified threats or pressures for the SAC, the key

actions needed to support the ecological integrity of the habitats of the SAC invertebrate

species form the basis for the HRA.

9.10.1 Supporting habitat: structure/ function – Decaying-wood habitat: Maintain an

abundance and constant supply of ancient trees, standing dead trees, fallen

trees, stumps and roots in a state of decay. In urban areas ensure larger native

trees and man-made timber structures persist as a larval resource.

9.10.2 Supporting habitat: structure/ function – Woodland habitat structure:

Maintain a well-structured broadleaved woodland habitat, with sheltered,

sunlit glades and rides containing stumps and other suitable decaying wood

9.10.3 Supporting Processes – Natural Processes: Ensure the continuity of timber

decay and nutrient recycling processes, in particular the continued provision of

plentiful decaying stumps and roots

13 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1002388&ReportTitle=Richmond%20Park%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1002388&ReportTitle=Richmond%20Park%20SSSI


108

9.10.4 Supporting Processes – Conservation Measures: Maintain the management

measures (either within and/or outside the site boundary as appropriate)

which are necessary to maintain or restore the structure, functions &

supporting processes associated with the stag beetle feature and/or its

supporting habitats.

9.10.5 Population – Population Abundance: Maintain or restore the presence of the

stag beetle population across its full range within the SAC, whilst avoiding

deterioration from its current level as indicated by the latest mean peak count

or equivalent


by the Surrey WLP would impact upon current or future habitat management practices

within the SAC. The only points at which the habitat management regime implemented






proximity to the SAC to be of significant benefit to the ongoing management of its

woodland habitats. Wastes arising from the management of the SAC would more likely be

dealt with by facilities situated in London.



would not give rise to direct or indirect significant impacts on habitat management

practices within the SAC, and therefore would not affect the condition of those habitats. No

further assessment is required.

9.D Conclusions


ecological integrity of the Richmond Park SAC has concluded that overall there would be no

potential for ‘likely significant effects’ to arise. One of the sites allocated under Policy 11

(Site 2: Weylands TW, Walton on Thames) and four of the ILAS (ILAS02; ILAS03; ILAS04 and

ILAS16) identified under Policy 10 of the Surrey WLP are located within 10 kilometres of the

SAC. The SAC is not susceptible (according to the published SIP) to adverse impacts due to

the deposition of nutrient nitrogen, and is not close enough to the allocated site and ILAS to

be directly or indirectly affected by the more localised impacts of waste related

development (e.g. noise and light disturbance).


109

9.14 No key threats and pressures have been identified by Natural England with reference to the

conservation objectives for the SAC. The conclusions reached in respect of the likely impact

of the Surrey WLP on the SAC are based on an assessment of the extent to which

implementation of the Plan might influence or affect habitat management practices within

the SAC.

9.E References


process for the Richmond Park SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Richmond Park SAC

(Natural England (English Nature), May 2005).



& designated SACs) – Richmond Park SAC (Joint Nature Conservation


9.15.3 European Site Conservation Objectives for Richmond Park Special Area of


9.15.4 Site Improvement Plan: Richmond Park SAC, Natural England, 11 December

2014.

9.15.5 European Site Conservation Objectives: Supplementary Advice on Conserving &

Restoring Site Features – Richmond Park Special Area of Conservation (SAC),

Natural England, 29 February 2016.



9.15.7 Richmond Park SSSI Condition Survey Report (Natural England, Designated






110

Chapter 10 Shortheath Common SAC


10.A.1 Location of the SAC 10.1 The Shortheath Common SAC (see map) is located in the county of Hampshire, some 4.1

kilometres to the west of the county boundary with Surrey, and is composed solely of the

Shortheath Common SSSI. The SAC citation states that the designation covers an area of

58.94 hectares, and that the SAC was designated on 1 April 2005. The SAC is situated within

an area administered by the South Downs NPA, by East Hampshire DC, and by Hampshire

County Council. Within Surrey, the Waverley BC area is located closest to the SAC.

10.2 The SAC is not situated within 200 metres of any part of the strategic road network or of

any ‘B’ class roads. The closest ‘B’ class road is the B3006 (Selborne Road), which passes

some 480 metres to the north of the SAC at its closest point.

10.3 The SAC is situated within a single surface water catchment, of the Oakhanger Stream

(GB106039017710), which lies wholly outside the county of Surrey, and is not fed by any

upstream catchments that are situated in Surrey.

10.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC 10.4 The Shortheath Common SAC is not located within 10 kilometres of any of the sites

proposed for allocation under Policy 11a or 11b of the Surrey WLP (see Figure 10-A – a full

size version can be found in Appendix A). The closest proposed allocation is ‘Site 3 – Land to

the north east of Slyfield Industrial Estate, Moorfield Road, Guildford’, which lies some 26.9

kilometres to the north east of the SAC. The SAC is located within 10 kilometres of one of

the ILAS (ILAS20 – Coxbridge Business Park, Alton Road, Farnham) identified under Policy 10

of the Surrey WLP (see Figure 10-A), which is 9.4 kilometres to the north east of the SAC.



10.5 The Alton Road quarry at Farnham, which is allocated for development as a temporary



Permission WA/2014/0005), is located some 8.2 kilometres to the north of the SAC. The

Alton Road quarry is accessed from the north via a dedicated track that links to the A31.

The HRAs undertaken in respect of the Aggregates Recycling Joint DPD concluded that the

ecological integrity of the SAC would not be adversely affected by the plan’s

implementation.



111

10.6 None of the sites proposed for development in the adopted Surrey Waste Plan, and none of

the preferred areas for mineral working identified in the adopted Surrey Minerals Plan are

situated within 10 kilometres of the SAC. The Habitat Regulations Assessments undertaken

in respect of both of those plans concluded that the ecological integrity of the SAC would

not be adversely affected by their implementation.

Figure 10-A: Shortheath Common SAC – Relationship to sites & ILAS proposed by the Surrey WLP




Site Description

A valley mire forms the focal point of this site in the western Weald which also embraces a wide range of woodland & heathland habitats including bog-woodland. The northern strip of the mire is the most mesotrophic (moderate nutrient status) & has much grey willow Salix cinerea but also a rich ground-flora with abundant sedges Carex curta & C. rostrata, soft rush Juncus effusus, marsh cinquefoil Potentilla palustris & the bog-moss Sphagnum recurvum.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Shortheath Common SAC

ShortheathCommon

SAC

ILAS20

N

S

W E

Site 1: Oakleaf FarmSite 2: Weylands TW;


Site 6: Trumps

Farm

Site 3: Slyfield IE

Site 5: Lambs BP

ILAS07

ILAS17

ILAS21

ILAS19

ILAS10



ILAS01;ILAS09;ILAS15;ILAS22

ILAS02; ILAS03;ILAS04; ILAS14;ILAS16

20 km

30 km

40 km

50 km


112

An oligotrophic (nutrient-poor) area to the south is dominated by S. recurvum with cross-leaved heath Erica tetralix, common cottongrass Eriophorum angustifolium, purple moor-grass Molinia caerulea & round-leaved sundew Drosera rotundifolia. It is notable for its high cover of cranberry Vaccinium oxycoccos. Other bog-mosses such as Sphagnum capillifolium & S. papillosum are also present, & the whole forms a floating raft over much of the mire.

Qualifying Habitats


Bog woodland* (Priority Habitat)

European dry heaths

Transition mires & quaking bogs. (Very wet mires often identified by an unstable ‘quaking’ surface)



Avoid the deterioration of the qualifying natural habitats & the habitats of qualifying species, & the significant disturbance of those qualifying species, ensuring the integrity of the site is maintained & the site makes a full contribution to achieving Favourable Conservation Status of each of the qualifying features.

Subject to natural change, to maintain or restore:






Qualifying Features


H7140. Transition mires & quaking bogs; Very wet mires often identified by an unstable `quaking` surface

H91D0. Bog woodland* (Annex I Priority habitat)


113


report for the Shortheath Common SSSI14 (see Table 10-A), the designated site extends to

some 59.49 hectares, of which some 98.0% is in ‘unfavourable – recovering’ condition, and

some 2.0% is in ‘unfavourable – no change’ condition. The majority of the SSSI is composed

of four main habitat types, ‘lowland fen, marsh & swamp’ (17.07 hectares), ‘rivers &

streams’ (1.22 hectares), ‘lowland dwarf shrub heath’ (32.33 hectares), and ‘lowland acid

grassland’ (8.87 hectares).

Table 10-A: Shortheath Common SSSI – Condition Survey Findings

Main Habitat Type



Unfavourable – No Change

Fen, Marsh & Swamp – Lowland 17.07 ha 17.07 ha

(28.7%)

0.0 ha

(0%)

Rivers & Streams 1.22 ha 0.0 ha

(0%)

1.22 ha

(2.05%)

Dwarf Shrub Heath - Lowland 32.33 ha 32.33 ha

(54.3%)

0.0 ha

(0%)

Acid Grassland – Lowland 8.87 ha 8.87 ha

(14.9%)

0.0 ha

(0%)

Totals 59.49 ha 58.27 ha (98.0%)

1.22 ha (2.0%)

10.10 For the 1.22 hectares of rivers and streams habitat (SSSI unit number 2, last surveyed on 12

December 2013) classified as exhibiting ‘unfavourable – no change’ condition, the condition

survey report provides the following explanation and analysis.

Comment: This unit was found to be failing on assessment of the following targets: The proportion of channel in shade is in excess of targets; Lack of appropriate micro & macro scale variation; Lack of marginal vegetation; Proportion of in-channel vegetation made up of submerged/floating species lower than target. Dragonflies were seen on the day of the visit hawking over the water, but the habitat features required for the dragonfly assemblage mentioned above were not meeting targets. The pond was heavily shaded in places & did not have the desired diversity of aquatic flora.

Reasons for Adverse Condition: Freshwater - Fish Stocking, Freshwater - Inappropriate Weirs Dams and Other Structures, Game Management - Game Management - Other


10.11 The published SIP for the SAC (12 December 2014) identifies the following key pressures

and threats to the site’s ecological integrity.

14 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003329&ReportTitle=Shortheath%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003329&ReportTitle=Shortheath%20Common%20SSSI


114



10.C.2;

Changes due to direct encroachment onto the land by a third party (householder) –

discussed further in section 10.C.3;


in section 10.C.4.

10.C.1 Inappropriate scrub control

10.12 The features affected by inappropriate scrub control are the European dry heaths (H4030)

habitat, and the very wet mires often identified by an unstable ‘quaking’ surface (H7140)

habitat. The SIP (p.3/8) offers the following explanation of the nature of the identified

threat.

“There is a build up of scrub & leaf litter, alongside areas where grasses are dominant or too

tall. Active management is required to reduce this & there are several options available.

Approval from Planning Inspectorate (PINS) is being sought to allow installation of fencing &

other infrastructure, to enable grazing on the common.”


concerned with amending the Higher Level Scheme (HLS) agreement to fund additional

capital items (subject to the outcome of a Section 38 application for fencing).



SAC.

10.15 The only points at which the scrub control regime implemented across the SAC may




clearance, etc.). The provision of additional waste management capacity within the county

of Surrey would be unlikely to be situated in close enough proximity to the SAC to be of

significant benefit to the ongoing management of its habitats. Wastes arising from the

management of the SAC would more likely be dealt with by facilities situated in Hampshire.







115


10.17 The feature affected by changes in public access and associated disturbance is the

European dry heaths (H4030) habitat. The SIP (p.3/9) offers the following explanation of the

nature of the identified threat.

“This site is common land & open access, and is regularly used for recreation. Shortheath

Common is dissected by a road & there are parking facilities that enable visitors to access the

common. Integrated Site Assessment carried out in 2013 identified areas of acid grassland &

dry heath where vegetation was being lost due to recreational disturbance.”


concerned with the undertaking of education and awareness raising activities, the

undertaking of enforcement action in cases where damage has been caused, and the

enforcement of existing byelaws relevant to the SAC.





county of Surrey. The closest areas of land identified as potentially suitable for waste

related development in the Surrey WLP are located some 9.4 kilometres to the north east

(ILAS20 – Coxbridge Business Park, Farnham) and some 27.1 kilometres to the north east

(Site 3 – Land NE of Slyfield IE, Guildford) of the SAC. Operational waste facilities would not

typically be a source of prospective visitors to the SAC, compared with, for example, new







pathway.

10.C.3 Direct impact by third party (encroachment by householders)

10.21 The feature affected by third party encroachment onto the SAC is the European dry heaths

(H4030) habitat. The SIP (p.4/9) offers the following explanation of the nature of the

identified pressure/threat:

“Encroachment by householders onto the SAC dry heath mosaic is frequent on this site. Whilst

each encroachment is relatively small, cumulatively the area is significant. Attempts by the

landowners or Natural England to tackle these have not worked.”


116


concerned with the undertaking of education activities for householders, and the use of

enforcement action where necessary.


by the Surrey WLP could result in changes in the incidence of neighbouring householders

encroaching onto the SAC. The Surrey WLP is concerned with the provision of a policy

framework within which development consent decisions can be made in respect of future

waste management facilities within the county of Surrey. The SAC is located wholly within

the county of Hampshire, and is situated in an area where planning control is the

responsibility of the South Downs NPA.



would not give rise to any positive or negative impacts on the SAC with respect to the

incidence of encroachment onto the designated site by neighbouring householders. No

further assessment is required in respect of the direct impact by third parties pathway.


10.25 The features affected by the deposition of nutrient nitrogen from the atmosphere are the

European dry heaths (H4030) habitat, the very wet mires often identified by an unstable

‘quaking’ surface (H7140) habitat, and the bog woodland (H91D0) habitat. The SIP (p.4/9)


“Nitrogen deposition exceeds site relevant critical loads. It is unknown if air quality is affecting

the SAC habitats. There is a need to determine the level of Nitrogen emissions (if any) from

suspected local sources as this could be adding to the critical load.”










development at any of the six sites allocated under Policy 11 of the Surrey WLP giving rise

to nutrient nitrogen deposition within the SAC at concentrations that would exceed 1% of

the site relevant critical loads for any of the designated habitats or species (see Part B6,.

Appendix B). The closest site allocation (Site 3 – Land NE of Slyfield IE, Guildford) is 27.1

kilometres to the north east of the SAC, and beyond the distance (10 kilometres) for which


117

detailed assessment would be required by the Environment Agency as part of the

Environmental Permit consenting process. Any contribution that emissions from a facility at

the closest allocated site would make to nitrogen deposition at the SAC would be

undetectable.

10.29 One of the ILAS (ILAS20 – Coxbridge BP, Farnham) identified under Policy 10 is located

within 10 kilometres (9.4 kilometres north east) of the SAC. The development of thermal

treatment facilities on land located within ILAS20 could, in theory, present risks of nutrient

nitrogen deposition on land within the SAC.


land situated within Surrey other than the allocated sites or identified ILAS, which could

include land situated within 10 kilometres of the SAC. The Metropolitan Green Belt

planning designation does not extend across all of the land within Surrey that lies within 10

kilometres of the SAC, with areas of non-Green Belt land situated to the south and north of

Farnham. However, those areas are in close proximity to a number of SPAs (Thames Basin

Heaths SPA, Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA,

Wealden Heaths Phase 2 SPA) and another SAC (Thursley, Ash, Pirbright & Cobham SAC),

and to the Surrey Hills Area of Outstanding Natural Beauty (AONB) and the South Downs

National Park, and it is therefore unlikely that a strategic waste management facility, as a

large scale (c.150,000 tpa or greater capacity) thermal treatment plant would be classed,

would be sited on unallocated land in Surrey within 10 kilometres of the SAC.


development in Surrey would be unlikely to travel along the ‘B’ class road (B3004) that

passes within 500 metres of the SAC. For the closest site allocation (Site 3 – Land to NE of

Slyfield IE, Guildford), the Transport Study undertaken for the Surrey WLP reports that

development of a large scale (c. 300,000 tpa capacity) EfW facility would result in a 6%

increase in AADT flows on the section of the A320 (Woking Road) closest to that proposed

site (Waste Local Plan – Transport Study: Site Assessments, Table 3.1, p.20). Section 3.3

(p.21) of the Transport Study predicts that traffic generated by any waste related

development on Site 3 would disperse to the strategic road network south down the A320

to the A3. It is not predicted that any traffic would leave the A3 at Compton, to join the

A31, and would then leave the A31 at Alton in Hampshire to travel east along the B3004

passing some 480 metres to the north of the SAC.



strategic road networks. Two of the identified ILAS (ILAS20 – Coxbridge BP, Farnham;

ILAS21 – Farnham TE, Farnham) are situated such that waste related development at those

locations could contribute to additional traffic on the section of A31 that passes north of

the SAC or on the section of the A325 that passes east of the SAC. However neither the A31

nor the A325 pass within 200 metres of the SAC, and it is unlikely that traffic generated by

the presence of waste management facilities on land at ILAS20 and/or ILAS21 would travel

along the ‘B’ class road (B3004) that does pass within 200 metres of the SAC.


118


concluded that implementation of the policies and proposals set out the Plan would not

give rise to significant effects on the ecological integrity of the SAC, alone or in-

combination. The published HRA reports (AECOM, 2016, 2017 and 2018) for the Waverley

BC Local Plan concluded that implementation of the policies and proposals set out in Parts

1 and 2 of that Plan would not give rise to significant effects on the ecological integrity of

the SAC, alone or in-combination.




development). However, the potential for significant impacts as a consequence of point

source pollution from the development and operation of some scale and type of thermal

treatment plant on land at ILAS20 cannot be ruled out at the screening stage. Further

assessment is required in respect of the air pollution (emission and deposit of nitrogen)

impact pathway with reference to facility emissions from waste facility development on

land at ILAS20 (see section 10.D of this report).



nitrogen deposition) by which development at one of the ILAS (ILAS20 – Coxbridge BP,

Farnham) identified under Policy 10 of the Surrey WLP could give rise to significant impacts

on the SAC. The mechanism by which development on land within ILAS20 could contribute

to the deposit of nutrient nitrogen would be emissions from thermal treatment plants. The

Surrey WLP does not specify the type or scale of waste related development that could be


10.36 Emissions from a small scale thermal treatment facility at ILAS20 are estimated to account

for 0.56% of the site relevant critical loads for the most sensitive habitats (raised and

blanket bogs – 5 kg/N/ha/yr) of the SAC. The estimated background deposition rate for

nutrient nitrogen within the area of the SAC closest to the ILAS is 16.38 kg/N/ha/yr (which

exceeds the minimum critical loads for raised and blanket bogs ), and the estimated

emissions for a small-scale facility would account for only 0.17% of the estimated

background deposition. The PEC (background plus process contribution) of 16.41

kg/N/ha/yr would account for more than 328% of the site relevant minimum critical load

for raised and blanket bogs, with the development of a thermal treatment plant accounting

for an increase in the PEC of 0.17%.

10.37 On a precautionary basis it is recommended that ILAS20 (Coxbridge BP, Farnham) be

classed as unsuitable for the development of thermal treatment facilities with a capacity of

more than 50,000 tpa with reference to potential impacts on the Shortheath Commons

SAC. Implementation of Policy 14 of the Surrey WLP, which requires that all waste related

planning applications be supported by sufficient information for the WPA to ascertain


119

whether the proposed development would result in significant adverse impacts on the

natural environment, including SPAs and SACs, will ensure that permitted development

does not compromise the ecological integrity of the SAC.

10.E Conclusions


ecological integrity of the Shortheath Common SAC has concluded that overall there would

be no potential for ‘likely significant effects’ to arise. None of the sites allocated under

Policy 11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS20 –

Coxbridge BP, Farnham) identified under Policy 10 of the Surrey WLP is 9.4 kilometres to

the north east. Development of thermal treatment facilities on land at ILAS20 could, in

theory result in nutrient nitrogen deposition within the SAC, and traffic arising from

development within ILAS20 and the more distant ILAS21 (12.7 kilometres north east) could

also contribute to such deposition. Given the relationship of ILAS20 and ILAS21 to the wider

road network it is unlikely that any waste related development would result in vehicle

movements through the SAC. To address the risk of nutrient nitrogen deposition from

process emissions from thermal treatment of waste it is recommended that ILAS20 is

unsuitable for large scale (>50,000 tpa) thermal treatment facilities but could accommodate

a smaller plant (<50,000 tpa) (subject to the conclusions of any project level assessment).

10.39 The assessment considered the four impact pathways identified as key threats and






Level



in section 10.C.1



WLP

Screening




10.C.2



WLP

Screening

Changes due to direct

encroachment onto the land

by a third party (householder)

– discussed further in section

10.C.3



WLP

Screening


120


Level




& section 10.D





Large scale (>50,000 tpa) thermal treatment not

recommended at ILAS20 but small-scale (<50,000

tpa) facilities could be accommodated with

reference to the Shortheath Common SAC.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

10.F References


process for the Shortheath Common SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Shortheath

Common SAC (Natural England (English Nature), May 2005).



& designated SACs) – Shortheath Common SAC (Joint Nature Conservation




10.40.4 Site Improvement Plan: Shortheath Common SAC (Natural England, 12

December 2014).



10.40.6 Shortheath Common SSSI Condition Survey Report (Natural England,






121


June 2018






122

Chapter 11 South West London Waterbodies SPA & Ramsar Site


11.A.1 Location of the SPA & Ramsar Site

11.1 The South West London Waterbodies SPA (see map) and Ramsar Site (see map) are

coincident with each other, and are both distributed across north west Surrey, south west

London and the east of the Royal Borough of Windsor & Maidenhead. The South West

London Waterbodies SPA covers an area of 825.01 hectares, as stated on the SPA citation,

and was designated on 22 September 2000. The SPA and Ramsar Site are situated within an

area of land administered by the Royal Borough of Windsor & Maidenhead, Surrey County

Council, the Greater London Authority, the London Borough of Hounslow, Spelthorne BC,

Runnymede BC, and Elmbridge BC.

11.2 The SPA and the Ramsar Site are both composed of the following seven SSSIs.

Kempton Park Reservoirs SSSI, located in Surrey and Greater London, and covering

some 25.29 hectares.

Knight & Bessborough Reservoirs SSSI, located in Surrey, and covering some 63.43

hectares.

Staines Moor SSSI, located in Surrey and covering some 510.82 hectares, of which

some 371.11 hectares (units 7 and 8 of the SSSI) are covered by the SPA designation.

Thorpe Park No.1 Gravel Pits SSSI, located in Surrey, and covering some 42.53

hectares.

Wraysbury & Hythe End Gravel Pits SSSI, located in the Royal Borough of Windsor &

Maidenhead, and covering some 117.21 hectares, of which some 68.43 hectares (units

3 and 4 of the SSSI) are covered by the SPA designation.

Wraysbury No.1 Gravel Pit SSSI, located in the Royal Borough of Windsor &

Maidenhead, and covering some 57.96 hectares.

Wraysbury Reservoir SSSI, located in Surrey and covering some 205.56 hectares.

11.3 The following motorways and ‘A’ class roads pass through or lie within 200 metres of the

SPA and Ramsar Site.

11.3.1 The M25 motorway, which passes within 200 metres of the Wraysbury

Reservoir SSSI.

11.3.2 The M3 motorway, which passes within 200 metres of the Thorpe Park No.1

Gravel Pit SSSI.


http://magic.defra.gov.uk/MagicMap.aspx?startTopic=Designations&activelayer=ramIndex&query=Ref_CODE%3D%27UK11065%27


123

11.3.3 The A320 (Staines Road), which passes within 200 metres of the Thorpe Park

No.1 Gravel Pit SSSI.

11.3.4 The A30 (London Road / Staines By-Pass), which passes within 200 metres of

the Staines Moor SSSI.

11.3.5 The A3044 (Stanwell Moor Road), which passes through the Staines Moor SSSI.

11.3.6 The A3050 (Hurst Road), which pass within 200 metres of the Knight &

Bessborough Reservoirs SSSI.

11.3.7 The B376 (Staines Road / Welley Road) – which passes within 200 metres of

the Wraysbury & Hythe End Gravel Pits SSSI, and the Wraysbury No.1 Gravel

Pit SSSI.

11.4 The SPA and Ramsar Site are situated across a number of different surface water

catchments, which lie wholly or partly within the county of Surrey.

11.4.1 The Port Lane Brook (GB106039023451).

11.4.2 The Thames (Egham to Teddington) (GB106039023232).

11.4.3 The Thames (Cookham to Egham) (GB106039023231).

11.4.4 The Colne (confluence with Chess to River Thames) (GB106039023090).

11.4.5 The Surrey Ash (GB106039023480).

11.4.6 The Horton Brook (GB106039023040).

11.4.7 The Moat at Egham (GB106039017060).

11.A.2 Minerals & waste development plan proposals in Surrey relevant to the SPA &

Ramsar Site

11.5 The South West London Waterbodies SPA and Ramsar Site are located within 10 kilometres

of the following sites (see below) proposed for allocation under Policy 11a or 11b (Site 6 –

Trumps Farm, Longcross) of the Surrey WLP (see Figure 11-A – a full size version can be

found in Appendix A). The SPA and Ramsar Site are located within 10 kilometres of the

following ILAS (see below) identified under Policy 10 of the Surrey WLP (see Figure 11-A).


accommodated on the identified ILAS. Full details of the relationship of the individual SSSIs

that together form the SPA and the Ramsar Site to all the sites allocated under Policy 11

and all the ILAS identified under Policy 10 of the Surrey WLP can be found in Appendix A

(Tables A-1 to A-5) to this report.


124

Site 1 (Oakleaf Farm, Horton Road, Stanwell Moor), 0.02 kilometres to the north of

the Staines Moor SSSI component of the SPA and Ramsar Site.

Site 2 (Land at the former Weylands Treatment Works, Molesey Road, Walton on

Thames), 1.9 kilometres to the south of the Knight & Bessborough Reservoirs SSSI

component of the SPA and Ramsar Site.

Site 6 (Land at Trump’s Farm, Kitsmead Lane, Longcross), which is located some 3.1

kilometres to the south west of the Thorpe Park No.1 Gravel Pit SSSI component of

the SPA and Ramsar Site.

ILAS01 (Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park,

Weybridge; and Byfleet Industrial Estate, Byfleet Road / Oyster Lane, Woking), which

is 5.8 kilometres to the south east of the Thorpe Park No.1 Gravel Pit SSSI component

of the SPA and Ramsar Site.

ILAS02 (Hersham Trading Estate, Lyon Road, Walton on Thames), 1.9 kilometres to

the south of the Knight & Bessborough Reservoirs SSSI component of the SPA and

Ramsar Site.

ILAS03 (Molesey Industrial Estate, Central Avenue, West Molesey), 0.03 kilometres

east of the Knight & Bessborough Reservoirs SSSI component of the SPA and Ramsar

Site.

ILAS14 (Thorpe Industrial Estate, Ten Acre Lane, Thorpe), 0.7 kilometres north of the

Thorpe Park No.1 Gravel Pit SSSI component of the SPA and Ramsar Site.

ILAS15 (Byfleet Road Employment Allocation, New Haw, Byfleet), 5.5 kilometres

south east of the Thorpe Park No.1 Gravel Pit SSSI component of the SPA and Ramsar

Site.

ILAS16 (Windmill Road Industrial Area, Sunbury-on-Thames), 2.2 kilometres south

west of the Kempton Park Reservoirs SSSI component of the SPA and Ramsar Site.

11.6 The King George VI Reservoir component of the Staines Moor SSSI, which is also designated

as part of the SPA and the Ramsar Site, is identified as Preferred Area H in the adopted

Surrey Minerals Plan, and has been allocated for the extraction of sand and gravel

resources. The Habitat Regulations Assessments undertaken in respect of the Minerals Plan

concluded that the ecological integrity of the SPA and Ramsar Site would not be adversely

affected by the working of part of the complex for mineral resources.


125

Figure 11-A: South West London Waterbodies SPA – Relationship to sites & ILAS proposed by the

Surrey WLP


11.B.1 Reasons for Designation of the SPA & Ramsar Site 11.7 The ecological interest of the SPA, and the particular species that are given as reasons for


Qualifying Species

South West London Waterbodies SPA is of European importance because: (a) the site qualifies under article 4.2 of the Directive (79/409/EEC) as it is used regularly by 1% or more of the biogeographical populations of the following regularly occurring migratory species (other than those listed in Annex I), in any season:

Gadwall Anas strepera – 710 individuals wintering (5 year peak mean 1993/94 to 1997/98) (2.4% of NW Europe population);

Shoveler Anas clypeata – 853 individuals wintering (5 year peak mean 1993/94 to 1997/98) (2.1% NW/Central Europe population).

Non-qualifying species of interest:

In addition, the site supports nationally important numbers of cormorant Phalacrocorax carbo, crested grebe Podiceps cristatus, tufted duck Aythya fuligula, pochard Aythya farina, and coot Fulica atra.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

South West London Waterbodies SPA


Site 2: Weylands TW

Site 6: Trumps

Farm

Site 5: Lambs BP

Site 3: Slyfield IE

ILAS01; ILAS15

ILAS02

ILAS03

ILAS14

ILAS16

ILAS22

South West London

Waterbodies SPA

N

S

W E

20 km

30 km

40 km

Site 4: Leatherhead

STW

ILAS04

ILAS05;ILAS06

ILAS07;ILAS17

ILAS08

ILAS09 ILAS10


ILAS18

ILAS19

ILAS20;ILAS21


126

11.8 The ecological interest of the Ramsar Site, and the particular species that are given as

reasons for its designation, is described as follows in the published information sheet.

The South West London Waterbodies site comprises a series of reservoirs and former gravel pits that support internationally important numbers of wintering Anas strepera and Anas clypeata.

Qualifying Species/populations (as identified at designation):

Species with peak counts in spring/autumn:

Northern shoveler, Anas clypeata, NW & C Europe 397 individuals, representing an average of 2.6% of the GB population (5 year peak mean 1998/92002/3)

Species with peak counts in winter:

Gadwall, Anas strepera strepera, NW Europe 487 individuals, representing an average of 2.8% of the GB population (5 year peak mean 1998/92002/3)

11.B.2 Conservation Objectives for the SPA

11.9 The published conservation objectives for the SPA are given below. There are no published

conservation objectives for the Ramsar Site designation.


Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring;

The extent and distribution of the habitats of the qualifying features

The structure and function of the habitats of the qualifying features


The population of each of the qualifying features, and,


Qualifying Features

A051 Anas strepera; Gadwall (Non-breeding)

A056 Anas clypeata; Northern shoveler (Non-breeding)


reports for the seven SSSIs15 (see Table 11-A for a summary) that together form the SPA and

Ramsar Site, the SPA site extends to some 834.31 hectares, of which some 97.0% is in

‘favourable’ condition, and some 3.0% is in ‘unfavourable – recovering’ condition. The SPA

15 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000385&ReportTitle=Kempton%20Park%20Reservoirs%20SSSI;

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000383&ReportTitle=Knight%20&%20Bessborough%20Reservoirs%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001792&ReportTitle=Staines%20Moor%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000382&ReportTitle=Thorpe%20Park%20No.%201%20Gravel%20Pit%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004168&ReportTitle=Wraysbury%20&%20Hythe%20End%20Gravel%20Pits%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000381&ReportTitle=Wraysbury%20No.%201%20Gravel%20Pit%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000374&ReportTitle=Wraysbury%20Reservoir%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000385&ReportTitle=Kempton%20Park%20Reservoirs%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000383&ReportTitle=Knight%20&%20Bessborough%20Reservoirs%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001792&ReportTitle=Staines%20Moor%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000382&ReportTitle=Thorpe%20Park%20No.%201%20Gravel%20Pit%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004168&ReportTitle=Wraysbury%20&%20Hythe%20End%20Gravel%20Pits%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000381&ReportTitle=Wraysbury%20No.%201%20Gravel%20Pit%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S2000374&ReportTitle=Wraysbury%20Reservoir%20SSSI


127

and the Ramsar Site are primarily composed of one main habitat type, ‘standing open

water & canals’ (814.19 hectares), with a small area of ‘neutral grassland – lowland’ (20.12

hectares) habitat found within the Kempton Park Reservoirs SSSI component.

Table 11-A: South West London Waterbodies SPA – Condition Survey Findings

Main Habitat Type



Recovering


(97.6%)

809.02 ha

(97.0%)

5.17 ha

(0.6%)

Neutral grassland - lowland 20.12 ha

(2.4%)

0.0 ha

(0%)

20.12 ha

(2.4%)

Totals 834.31 ha 809.02 ha

(97.0%)

25.29 ha

(3.0%)


11.11 The published Site Improvement Plan (SIP) for the SPA (15 October 2014) identifies the

following key pressures and threats to the site’s ecological integrity. There is no published

site improvement plan for the Ramsar Site designation.


11.C.1;

Changes in species distribution – discussed further in section 11.C.2;

Changes due to the introduction of invasive species (Crassula helmsii)– discussed further

in section 11.C.3;

Changes arising from the natural maturation of wetland habitats– discussed further in

section 11.C.4;

Changes in fish stocking densities and practices – discussed further in section 11.C.5;

Changes in waterweed control practices – discussed further in section 11.C.6;

Changes arising from the incursion of invasive species (Egyptian geese) – discussed

further in section 11.C.7.

11.C.1 Public access/disturbance

11.12 The features affected by changes in the incidence or intensity of public access and

disturbance are the population of Gadwall (A051(NB)), and the population of Shoveler

(A056(NB)). The SIP (p.4/16 and 6/16) offers the following explanation of the nature of the


“Most of the sites have some level of formal or informal public access, including water-based

activities on some waterbodies (angling, sailing, water-skiing). People can potentially disturb

wintering Gadwall & Shoveler, & management for recreational uses may reduce the area of


128

suitable habitat. Research by Briggs (2007) & Briggs et al (2012) indicates low numbers of

Gadwall & Shoveler are associated with higher levels of disturbance.”

11.13 The actions identified as the principal means of addressing the pressure/threat are

concerned with seeking agreement with landowners, leaseholders/tenants, local

authorities and parish councils about the avoidance and management of recreational

pressures on the SPA birds, with raising awareness and understanding of the SPA amongst

recreational users, and with creating and promoting recreation opportunities away from

ecologically sensitive areas of the SPA.


by the Surrey WLP could result in changes to the opportunities for public access to the SPA

(and Ramsar Site) waterbodies. The Surrey WLP is concerned with the provision of a policy


waste management facilities within the county of Surrey. The construction of new waste

management facilities would not typically be a source of prospective recreational users of

the waterbodies, compared with, for example, new residential development (which creates

demand for recreation and leisure facilities) or new recreational development involving the

use of the SPA (and Ramsar Site) waterbodies. However, where waste facilities could be

located in particularly close proximity to the habitats of potentially sensitive species the

introduction of new sources of noise or light could give rise to disturbance.

11.15 One of the sites allocated under Policy 11a (Site 1 – Oakleaf Farm, Stanwell Moor) and two

of the ILAS identified under Policy 10 (ILAS03 – Molesey IE, West Molesey; ILAS14 – Thorpe

IE, Thorpe) are each located within 1 kilometre of SSSIs that are constituent parts of the

SPA (and Ramsar Site).

11.15.1 Site 1 (Oakleaf Farm, Stanwell Moor) is 0.02 kilometres to the north of the King

George VI Reservoir component of the Staines Moor SSSI, which forms a

constituent part of the SPA and Ramsar Site. Site 1 is separated from the SSSI

by the embanked walls of the reservoir which rise to 17 metres above the

original ground level. The reservoir is operated by Thames Water as a source of

water for public supply. The reservoir is used as a roosting and loafing site by

the over-wintering (October to March) populations of the SPA bird species. Site

1 is already occupied by a range of waste management operations, but the

principal source of noise disturbance affecting the area in which the SPA

component is located will be Heathrow Airport. Given the physical separation

of Site 1 from the SPA component by the embankment walls of the reservoir,

and taking account of background noise conditions, it is unlikely that waste

related development of Site 1 would give rise to significant disturbance

impacts on the SPA bird species within the King George VI Reservoir

component of the SPA as a consequence of noise or light emissions.

11.15.2 ILAS03 (Molesey Industrial Estate, West Molesey) is 0.03 kilometres to the east

of the Knight & Bessborough Reservoirs SSSI component of the SPA and

Ramsar Site. The reservoirs are retained by an 11 metre high continuous earth-


129

fill embankment with a clay core keyed into the underlying London Clay. The

reservoir is operated by Thames Water as a source of water for public supply.

The reservoir is used as a roosting site by the over-wintering (October to

March) populations of the SPA bird species, with algal growth around the

waters edge affording feeding opportunities for gadwall. Given the physical

separation of ILAS03 from the SPA component by the embankment walls of the

reservoir it is unlikely that waste related development within ILAS03 would

give rise to significant disturbance impacts on the SPA bird species within the

Knight & Bessborough Reservoir component of the SPA as a consequence of

noise or light emissions.

11.15.3 ILAS14 (Thorpe Industrial Estate, Thorpe) is 0.7 kilometres to the north of the

Thorpe Park No.1 Gravel Pit SSSI component of the SPA and Ramsar Site. The

SSSI is a former mineral working that has been subject to wet restoration to

create a large open waterbody that is used for a range of uses, including

watersking and fishing. The SSSI is favoured by gadwall rather than shoveler,

due to the presence of plentiful macrophytes on which the gadwall feed. Given

the physical separation of ILAS14 from the SPA, between which are areas of

land subject to residential development, agricultural land use, and past waste

management use (former landfills), it is unlikely that waste related

development within ILAS14 would give rise to significant disturbance impacts

on the SPA bird species within the Thorpe Park No.1 Gravel Pit component of

the SPA as a consequence of noise or light emissions



would not give rise to additional recreational users of the SPA waterbodies, and would

therefore not contribute to any significant impacts arising from public access to the

designated site, and disturbance of the SPA bird species. No further assessment is required

in respect of the public access / disturbance impact pathway.

11.C.2 Changes in species distribution

11.17 The features affected are the population of Gadwall (A051(NB)), and the population of

Shoveler (A056(NB)). The SIP (p.7/16 and 8/16) offers the following explanation of the

nature of the identified pressure/threat.

“Cook et al 2013 reports that Gadwall numbers have been in decline on this SPA (-51% over 10

years up to 2009/10), which is not consistent with upwards national population trend. It is not

yet confirmed that the changes in Gadwall & Shoveler numbers at the SPA is indicative of

changing species distribution or of changing population size. There is research available

(Briggs 2007 & Briggs et al 2012) as well as WeBS data to inform an assessment by Natural

England but further survey/research may be necessary. Briggs research suggests that wetland

& terrestrial habitat outside the SPA (more than 50 waterbodies according to Briggs et al

2012) is making a significant contribution to sustaining the SPA population & there are

specified non-designated sites that are unofficially recognised locally as supporting the SPA


130

population. Changes can be managed & foreseen through the planning system, e.g. there

have been new mineral restoration schemes since designation which will have most probably

affected species distribution (e.g. London Wildfowl Centre at Barnes). Natural & inevitable

maturation of gravel pits also influences the future capacity of the SPA to support the SPA

population.”

11.18 The actions identified as the principal means of addressing the pressure/threat are

concerned with collecting and collating data on the SPA and the distribution of SPA bird

species across designated and non-designated waterbodies, and with ensuring that non-

designated sites that support the SPA are recognised and reflected in local authority

decision making.

11.19 Screening Evaluation: The Surrey WLP is concerned with the provision of a policy


waste management facilities within the county of Surrey. None of the sites proposed for

allocation under Policy 11 or the ILAS identified under Policy 10 of the Surrey WLP coincide

with, or would directly impact upon, any non-designated waterbodies in the area

surrounding the designated SPA components. The new Surrey WLP will exert some

influence over the restoration of former mineral workings, as a consequence of the

emphasis placed on the recovery of value by means of the recycling and reuse of

construction, demolition and excavation wastes, and the setting of policy in respect of the

recovery of inert waste to land for the mineral site restoration. The new Surrey WLP will

not, however, exert significant influence over the end uses achieved at restored former

mineral workings, as policy in that respect is set by the adopted Surrey Minerals Plan.

11.20 Screening Conclusion: The implementation of the Surrey WLP including through the


would not give rise to any significant opportunities for the creation of new habitat tailored

to the needs of the SPA bird species, and would not result in substantial losses or changes

in the extent of existing habitats within the SPA complex or the surrounding area. No

further assessment is required in respect of the changes in species distribution impact

pathway.

11.C.3 Invasive species (Crassula helmsii)

11.21 The features affected by the spread of Crassula helmsii are the population of the Gadwall

(A051(NB)), and the population of the Shoveler (A056(NB)). The SIP (p.8/16 and 9/16) offers


“Large areas of wetland & terrestrial habitat are infested with Crassula helmsii & this is likely

to be reducing invertebrate numbers - Gadwall & Shoveler feed on invertebrates [Note – for

Gadwall invertebrates form a small part of their diet, the majority of which is composed of

vegetation]. An eradication project is tackling Crassula helmsii but it is not fully effective so

far.”


131


pressure/threat are concerned with the continued management and monitoring of Crassula

helmsii at the Kempton Park Reservoirs SSSI and the review of management elsewhere,

working with partners to secure preventative measures at other waterbodies to prevent

spread across the SPA, sharing information with the promoters of schemes that could result

in the spread of Crassula helmsii, and the provision of information to enable landowners

and recreation interest groups to identify and report Crassula helmsii.


by the Surrey WLP could act to assist in the eradication of Crassula helmsii from the SPA

complex. The only point at which the eradication project would interface with waste

management operations and practices would be in respect of a need for the removal and

appropriate management of the waste materials that will arise from the control

programme. The waste arising from the eradication project is unlikely to be of a scale that

would require the construction and operation of new green waste management capacity

within the county on land other than that already in, or allocated, for waste use.



would not give rise to direct or indirect significant impacts on the Crassula helmsii

eradication project. No further assessment is required in respect of the invasive species

impact pathway.

11.C.4 Natural changes to site conditions

11.25 The features affected by natural changes in site conditions are the population of the

Gadwall (A051(NB)), and the population of the Shoveler (A056(NB)). The SIP (p.9/16) offers


“The inevitable maturation of gravel pits is altering roosting & feeding provision in terms of

bankside vegetation, water chemistry & aquatic biodiversity. For example, research by Briggs

indicates that bankside tree growth is an obvious problem for both Gadwall & Shoveler at the

SPA. There is limited potential to manage natural processes of maturation of gravel pits but

some actions are feasible. (SPA birds may prefer non-designated sites in the short to longer

term, despite efforts to manage changing habitat at designated gravel pits).”


pressure/threat are concerned with working with partners to, carry out habitat

management across maturing gravel pits in order to maintain or enhance provision for

Gadwall and Shoveler (e.g. manage bankside willows at key locations to benefit both

species), and incorporating habitat management and habitat creation into planned

developments.


by the Surrey WLP could act to assist in the active management of the natural maturation

of the former gravel pit waterbodies that form part of the SPA complex. The only point at


132

which such management could interface with waste management operations and practices

would be in respect of a need for the removal and appropriate management of any waste

materials that may arise from active management (e.g. from the removal or thinning of

bankside vegetation). The waste arising from such management is unlikely to be of a scale

that would require the construction and operation of new green waste management

capacity within the county on land other than that already in, or allocated, for waste use.



would not give rise to direct or indirect significant impacts on the active management of

the natural maturation of the former gravel pit waterbodies of the SPA complex. No further

assessment is required in respect of the natural changes to site conditions impact pathway.

11.C.5 Fisheries (fish stocking)

11.29 The features affected by changes in fish stocking levels within the SPA complex waterbodies

are the population of the Gadwall (A051(NB)), and the population of the Shoveler

(A056(NB)). The SIP (p.10/16) offers the following explanation of the nature of the


“Research by Briggs (2007) & Briggs et al (2012) indicated that stocking of fish for recreation

angling negatively impacts upon SPA bird populations. Fish de-stocking has been carried out in

the past. Carp is particularly problematic. R K Leisure [Note: manage Wraysbury No.1 Gravel

Pit SSSI, & the northern part of the Wraysbury & Hythe End Gravel Pits SSSI], for example,

promotes waterbodies that are internationally recognised for carp fishing.”


pressure/threat are concerned with working with landowners and anglers to ensure

appropriate fish stocking levels (levels specific to the particular fish species) are achieved

and maintained.



waste management facilities within the county of Surrey. There is no mechanism by which

the forms of development covered by the Surrey WLP could act to assist in the active

management of fish stocks within the former gravel pit waterbodies that form parts of the

SPA complex.



would not give rise to direct or indirect significant impacts on fish stocks and fish stock

management practices within the former gravel pit waterbodies of the SPA complex. No

further assessment is required in respect of the fisheries impact pathway.


133

11.C.6 Inappropriate Weed Control

11.33 The features affected by inappropriate weed control practices are the population of the

Gadwall (A051(NB)), and the population of the Shoveler (A056(NB)). The SIP (p.10/16)

offers the following explanation of the nature of the identified pressure/threat:

“Control or removal of waterweed for watersports potentially impacts upon the availability of

food for Gadwall & Shoveler. Natural England can advise upon appropriate management of

waterweed through the consenting process although there is potential that some weed

clearance has been carried out in the past without consent.”


pressure/threat are concerned with reviewing the management of waterweed and

developing responses tailored to weed prevalence and summer growing conditions,

reviewing the size and location of the area that needs to be kept waterweed free, the

needs of gadwall for the particular types of waterweeds, and with producing written

guidance on waterweed control.




the forms of development covered by the Surrey WLP could act to assist in the promotion

of appropriate waterweed management practices within the former gravel pit waterbodies

that form parts of the SPA complex.



would not give rise to direct or indirect significant impacts on waterweed management

practices within the former gravel pit waterbodies of the SPA complex. No further

assessment is required in respect of the inappropriate weed control impact pathway.

11.C.7 Invasive Species (Egyptian Geese)

11.37 The features affected by the incursion of Egyptian geese are the population of the Gadwall

(A051(NB)), and the population of the Shoveler (A056(NB)). The SIP (p.11/16) offers the

following explanation of the nature of the identified pressure/threat:

“There are concerns that Egyptian geese are showing significant increases. Impacts on

Gadwall & Shoveler not yet confirmed or quantified but there is potential that geese are

competing with Gadwall & Shoveler for habitat & food.”


pressure/threat are concerned with investigating interactions between Egyptian geese, and

gadwall and shoveler, to establish whether the SPA birds experience negative direct or

indirect impacts, and with exploring the potential to reduce Egyptian geese numbers in

tandem with Canada geese controls (e.g. by the oiling of eggs).


134




the forms of development covered by the Surrey WLP could act to assist in the monitoring

or management of Egyptian geese, or in ascertaining the nature and extent of any impact

that their presence may have on the SPA bird species.



would not give rise to direct or indirect significant impacts in respect of the management or

monitoring of Egyptian geese. No further assessment is required in respect of the invasive

species impact pathway.

11.D Conclusions


ecological integrity of the South West London Waterbodies SPA and Ramsar Site has

concluded that overall there would be no potential for ‘likely significant effects’ to arise.

Three of the sites allocated under Policy 11 (Site 1 – Oakleaf Farm, Stanwell Moor; Site 2 –

Weylands TW, Walton on Thames; Site 6 – Trumps Farm, Longcross) and seven of the ILAS

(ILAS01; ILAS02; ILAS03; ILAS14; ILAS15; ILAS16; ILAS22). However, taking account of the

nature of the waterbodies that together form the SPA complex, of which those located in

closest proximity to allocated sites and ILAS comprise of established public water supply

reservoirs with engineered banks, there is little risk to the integrity of the SPA (and Ramsar

Site) from the development of land located in close proximity. In addition, the issues

identified as matters of concern for the SPA in the published SIP are mainly concerned with

the use and management of the designated waterbodies, or with the control of invasive

species, all of which are matters that would be unaffected by waste related development

on nearby land.


pressures of concern with reference to the conservation objectives for the SPA and the

Ramsar Site. The conclusions reached in respect of the likely impact of the Surrey WLP on

the SPA and the Ramsar Site via each pathway are summarised in Table 11-B.



Level




11.C.1


and Ramsar Site likely to arise from

implementation of the Surrey WLP

Screening


135


Level

Changes in species

distribution – discussed





Screening

Changes due to the

introduction of invasive

species (Crassula helmsii) –


11.C.3




Screening


natural maturation of

wetland habitats– discussed





Screening

Changes in fish stocking

densities and practices –


11.C.5




Screening

Changes in waterweed

control practices – discussed





Screening


incursion of invasive species

(Egyptian geese) – discussed





Screening

11.43 The further information provided in parts B (paragraphs 2-4, pp.8-9), H-1 (paragraphs 21-

24, pp.17-18) and H-7 (paragraphs 47-48 and 50, pp.24-25) of the appendix to the

Statement of Common Ground between Natural England and Surrey County Council, dated

8 August 2019, does not alter the conclusions reached by the HRA process in respect of the

likely impacts of the Surrey WLP on the South West London Waterbodies SPA and Ramsar

Site. That further information provides detailed descriptions of the physical relationship

between one proposed allocated site (Site 1 – Oakleaf Farm, Stanwell Moor) and two

proposed ILAS (ILAS03 – Molesey Industrial Estate, West Molesey; and, ILAS14 – Thorpe

Industrial Estate, Thorpe) and component parts of the SPA and Ramsar Site. Those

descriptions serve to reinforce the conclusions reached through the HRA process, that

waste development at the allocated site or either of the ILAS would not result in significant

impacts on the ecological integrity of the SPA and Ramsar Site.

11.E References 11.44 The following sources of information have been referred to as part of the assessment

process for the South West London Waterbodies SPA and Ramsar Site.


Protection Area (SPA) – South West London Waterbodies SPA (Natural England

(English Nature), September 2000).


136

11.44.2 NATURA 2000 – Standard Data Form: Special Protection Areas under the EC

Wild Birds Directive – South West London Waterbodies SPA (Joint Nature


11.44.3 European Site Conservation Objectives for South West London Waterbodies

SPA (Site Code: UK9012171) (Natural England, 30 June 2014, v.2).

11.44.4 Site Improvement Plan: South West London Waterbodies SPA (Natural England,

15 October 2014).

11.44.5 European Site Conservation Objectives: Supplementary Advice on Conserving &

Restoring Site Features – South West London Waterbodies Special Protection

Area (SPA), Natural England, 29 January 2018.

11.44.6 Kempton Park Reservoirs SSSI Condition Survey Report (Natural England,


11.44.7 Knight & Bessborough Reservoirs SSSI Condition Survey Report (Natural


11.44.8 Staines Moor SSSI Condition Survey Report (Natural England, Designated Sites


11.44.9 Thorpe Park No. Gravel Pit SSSI Condition Survey Report (Natural England,


11.44.10 Wraysbury & Hythe End Gravel Pits SSSI Condition Survey Report (Natural


11.44.11 Wraysbury No. Gravel Pit SSSI Condition Survey Report (Natural England,


11.44.12 Wraysbury Reservoir SSSI Condition Survey Report (Natural England,



11.44.14 Surrey Waste Local Plan: Statement of Common Ground between Natural

England & Surrey County Council. 8 August 2019. Surrey County Council,

Kingston-upon-Thames.



137

Chapter 12 Thames Basin Heaths SPA


12.A.1 Location of the SPA 12.1 The Thames Basin Heaths SPA (see map) is distributed across western Surrey, north east

Hampshire and the south east of the former county of Berkshire, and is composed of a

complex of thirteen SSSIs. The SPA covers an area of 8,274.72 hectares, as stated on the

SPA citation, and was designated on 9 March 2005. The thirteen SSSIs that together form

the SPA are situated within areas administered by Surrey County Council, Hampshire

County Council, Bracknell Forest BC, Hart DC, Rushmoor BC, Guildford BC, Woking BC,

Surrey Heath BC, Elmbridge BC, and Waverley BC.

Ash to Brookwood Heaths SSSI, located in Surrey and covering some 1,576.35 hectares.

Bourley & Long Valley SSSI, located partially in Surrey with the majority of the SSSI in

Hampshire, and covering some 823.48 hectares.

Bramshill SSSI, located in Hampshire and covering some 673.27 hectares, situated

some 6.79 kilometres to the west of the Surrey/Hampshire boundary.

Broadmoor to Bagshot Woods & Heaths SSSI, located in Surrey and Berkshire, and

covering some 1,696.33 hectares.

Castle Bottom to Yateley & Hawley Commons SSSI, located in Hampshire and covering

some 922.74 hectares, situated some 0.6 kilometres to the west of the Surrey/

Hampshire boundary.

Chobham Common SSSI, located in Surrey and covering some 655.73 hectares.

Colony Bog & Bagshot Heath SSSI, located in Surrey and covering some 1,130.51

hectares.

Eelmoor Marsh SSSI, located in Hampshire and covering some 66.34 hectares, and

situated some 3.66 kilometres to the west of the Surrey/Hampshire border.

Hazeley Heath SSSI, located in Hampshire and covering some 180.79 hectares, situated

some 9.15 kilometres to the west of the Surrey/Hampshire boundary.

Horsell Common SSSI, located in Surrey and covering some 151.99 hectares.

Ockham & Wisley Commons SSSI, located in Surrey and covering some 265.96

hectares.

Sandhurst to Owlsmoor Bogs & Heaths SSSI, located in Berkshire and covering some

85.81 hectares, situated some 2.36 kilometre to the north west of the Surrey/Bracknell

Forest boundary.

Whitmoor Common SSSI, located in Surrey and covering some 166.03 hectares.



138

12.2 The following motorways and ‘A’ class roads pass through or within 200 metres of the

component SSSIs of the SPA that are located wholly or partly in Surrey.

12.2.1 The M3 motorway, which passes through the Chobham Common SSSI, and

within 200 metres of the Colony Bog & Bagshot Heath SSSI.

12.2.2 The M25 motorway and the A3 (Portsmouth Road), which pass through the

Ockham & Wisley Commons SSSI.

12.2.3 The A3046 (Chobham Road), which passes through the Horsell Common SSSI,

and the A245 (Shores Road) and the A320 (Chertsey Road), which pass within

200 metres of the Horsell Common SSSI.

12.2.5 The A322 (Bagshot Road), which passes within 200 metres of the Whitmoor

Common SSSI, the Ash to Brookwood Heaths SSSI, the Colony Bog & Bagshot

Heath SSSI, and the Broadmoor to Bagshot Woods & Heaths SSSI.

12.2.6 The A320 (Guildford Road), which passes through the Whitmoor Common SSSI.

12.2.7 The A324 (Pirbright Road), which passes through and within 200 metres of the

Ash to Brookwood Heaths SSSI.

12.2.8 The A3095 (Rackstraw Road / Foresters Way), which passes through the

Broadmoor to Bagshot Woods & Heaths SSSI, and within 200 metres of the

Sandhurst to Owlsmoor Bogs & Heaths SSSI.

12.2.9 The A287 (Odiham Road), the A325 (Farnborough Road), and the A323 (Fleet

Road) pass through or within 200 metres of the Bourley & Long Valley SSSI.

12.3 The SPA extends across a number of different surface water catchments, many of which lie

wholly or partly within the county of Surrey.

12.3.1 Within the Wey river basin, the catchments of the, Clasford Brook & Wood

Street Brook (GB106039017850); Hoe Stream (Normandy to Pirbright)

(GB106039017870); Hoe Stream (Pirbright to River Wey confluence at Woking)

(GB106039017900); Hale/Mill Bourne (Bagshot to Addlestone Bourne

confluence near Chobham) (GB106039017930); Chertsey Bourne (Virginia

Water to Chertsey) (GB106039017070); Wey Navigation (Pyrford Reach)

(GB106039017910); Addlestone Bourne (West End to Hale/Mill Bourne

confluence at Mimbridge) (GB106039017920); Addlestone Bourne (Mill/Hale

to Chertsey Bourne) (GB106039017020); Wey (Shalford to River Thames

confluence at Weybridge) (GB106039017630).

12.3.2 Within the Lower Mole & Rythe river basin, the catchment of the Mole (Horley

to Hersham) (GB106039017621).

12.3.3 Within the Loddon river basin, the catchments of the, Blackwater (Aldershot to

Cove Brook confluence at Hawley) (GB106039017180); Fleet Brook

(GB106039017120); Cove Brook (GB106039017130); Blackwater (Hawley to

Whitewater confluence at Bramshill) (GB106039017290); Hart (Elvetham to

Hartley Wintney) (GB106039017170).


139

12.A.2 Minerals & waste development plan proposals in Surrey relevant to the SPA

12.4 The Thames Basin Heaths SPA is located within 10 kilometres of the following sites (see

below) proposed for allocation under Policy 11a (Sites 2, 3 and 4) or 11b (Site 6) of the

Surrey WLP (see Figure 12-A – a full size version can be found in Appendix A). The Plan

specifies the scale and type of waste related development that could be accommodated by

Site 6 (Trumps Farm, Longcross), which excludes any form of thermal treatment. The SPA is

located within 10 kilometres of the following ILAS (see below) identified under Policy 10 of

the Surrey WLP (see Figure 12-A). The Plan does not specify the type or scale of waste

related development that could be accommodated on the identified ILAS. Full details of the

relationship of the individual SSSIs that together form the SPA to all the sites allocated

under Policy 11 and all the ILAS identified under Policy 10 of the Surrey WLP can be found

in Appendix A (Tables A-1 to A-5) to this report.


Thames), 7.1 kilometres to the north east of the Ockham & Wisley Commons SSSI

component of the SPA.

Site 3 (Land to the north east of Slyfield Industrial Estate, Moorfield Road, Guildford),

1.2 kilometres to the south east of the Whitmoor Common SSSI component of the SPA.

Site 4 (Land to the west of Leatherhead Sewage Treatment Works, Randalls Road,

Leatherhead) 5.5 kilometres to the south east of the Ockham & Wisley Commons SSSI


Site 6 (Land at Trumps Farm, Kitsmead Lane, Longcross), 1.4 kilometres to the north

east of the Chobham Common SSSI component of the SPA.


Weybridge; & Byfleet Industrial Estate, Byfleet Road / Oyster Lane, Woking), 2.3

kilometres north west of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS02 (Hersham Trading Estate, Lyon Road, Walton on Thames), 6.9 kilometres north

east of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS03 (Molesey Industrial Estate, Central Avenue, West Molesey), 9.6 kilometres to

the north east of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS05 (Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford), 0.8

kilometres to the south east of the Whitmoor Common SSSI component of the SPA.

ILAS06 (Woodbridge Meadows Industrial Estate, Guildford), 2.2 kilometres to the

south of the Whitmoor Common SSSI component of the SPA.

ILAS07 (Land north & south of Lysons Avenue, Ash Vale), 0.4 kilometres west of the

Ash to Brookwood Heaths SSSI component of the SPA.

ILAS08 (Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old

Portsmouth Road, Peasmarsh), 6.8 kilometres south of the Whitmoor Common SSSI



140

ILAS09 (Land at Burnt Common Warehouse, London Road, Send), 3.6 kilometres east

of the Whitmoor Common SSSI component of the SPA.

ILAS14 (Thorpe Industrial Estate, Ten Acre Lane, Egham), 5.5 kilometres north east of

the Chobham Common SSSI component of the SPA.

ILAS15 (Byfleet Road, Employment Allocation, New Haw, Byfleet), 2.9 kilometres north

west of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS16 (Windmill Road Industrial Area, Sunbury-on-Thames), 9.8 kilometres north of

the Ockham & Wisley Commons SSSI component of the SPA.

ILAS17 (York Town Industrial Estate, Doman Road / Stanhope Road, Camberley), 0.6

kilometres east of the Castle Bottom to Yateley & Hawley Commons SSSI component

of the SPA.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 3.2 kilometres to the south of

the Bourley & Long Valley SSSI component of the SPA.

ILAS21 (Farnham Trading Estate (incl. land north of Water Lane), Water Lane,

Farnham), 2.1 kilometres south east of the Bourley & Long Valley SSSI component of

the SPA.

ILAS22 (Monument Way East Industrial Estate, Woking), 0.7 kilometres south of the

Horsell Common SSSI component of the SPA.

Figure 12-A: Thames Basin Heaths SPA – Relationship to sites & ILAS proposed by the Surrey WLP

N

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Thames Basin Heaths SPA

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Thames Basin Heaths SPA

Site 6: Trumps

FarmThames Basin

Heaths SPA

Site 3: Slyfield IE


Site 5: Lambs BPILAS08

ILAS05

ILAS07 ILAS09

ILAS17

ILAS05

ILAS15

Site 2: Weylands TW

Site 4:Leatherhead

STW

ILAS01


ILAS04

ILAS16

ILAS20

ILAS06

N

S

W E

20 km

30 km

40 km

ILAS22

ILAS21

ILAS10

ILAS11

ILAS12;ILAS13

ILAS18

ILAS19


141


Plan, or the sites allocated in the Aggregates Recycling Joint DPD, are situated within 5

kilometres of the SPA. The Habitat Regulations Assessments undertaken in respect of both

plans concluded that the ecological integrity of the SPA would not be adversely affected by

their implementation.




Site Description

The Thames Basin Heaths SPA is a composite site that is located across the counties of Surrey, Hampshire & Berkshire in southern England. It encompasses all or parts of Ash to Brookwood Heaths Site of Special Scientific Interest (SSSI), Bourley & Long Valley SSSI, Bramshill SSSI, Broadmoor to Bagshot Woods & Heaths SSSI, Castle Bottom to Yateley & Hawley Commons SSSI, Chobham Common SSSI, Colony Bog & Bagshot Heaths SSSI, Eelmoor Marsh SSSI, Hazeley Heath SSSI, Horsell Common SSSI, Ockham & Wisley Commons SSSI, Sandhurst to Owlsmoor Bogs & Heaths SSSI & Whitmoor Common SSSI.

The open heathland habitats overlie sand & gravel sediments which give rise to sandy or peaty acidic soils, supporting dry heathy vegetation on well-drained slopes, wet heath on low-lying shallow slopes & bogs in valleys.

The site consists of tracts of heathland, scrub & woodland, once almost continuous, but now fragmented into separate blocks by roads, urban development & farmland. Less open habitats of scrub, acidic woodland & conifer plantations dominate, within which are scattered areas of open heath & mire. The site supports important breeding populations of a number of birds of lowland heathland, especially nightjar Caprimulgus europaeus & woodlark Lullula arborea, both of which nest on the ground, often at the woodland/heathland edge, & Dartford warbler Sylvia undata, which often nests in gorse Ulex sp.

Scattered trees & scrub are used for roosting. Together with the nearby Ashdown Forest & Wealden Heaths SPAs, the Thames Basin Heaths form part of a complex of heathlands in southern England that support important breeding bird populations.

Qualifying Species

The site qualifies under article 4.1 of the Directive (79/409/EEC) as it is used regularly by 1% or more of the Great Britain populations of the following species listed in Annex I in any season:

Nightjar Caprimulgus europaeus - 264 churring males – breeding (1998/99) - 7.8% of GB population

Woodlark Lullula arborea - 149 pairs – breeding (1997) - 9.9% of GB population

Dartford warbler Sylvia undata - 445 pairs – breeding (1999) - 27.8% of GB population

Non-qualifying species of interest

Hen harrier Circus cyaneus, merlin Falco columbarius, short-eared owl Asio flammeus & kingfisher Alcedo atthis (all Annex I species) occur in non-breeding numbers of less than European importance (less than 1% of the GB population).


142


12.7 The published conservation objectives for the SPA are given below.


“With regard to the individual species &/or assemblage of species for which the site has been classified (“the Qualifying Features” listed below): Avoid the deterioration of the habitats of the qualifying features, & the significant disturbance of the qualifying features, ensuring the integrity of the site is maintained & the site makes a full contribution to achieving the aims of the Birds Directive. Subject to natural change, to maintain or restore:

The extent & distribution of the habitats of the qualifying features;

The structure & function of the habitats of the qualifying features;

The supporting processes on which the habitats of the qualifying features rely;

The populations of the qualifying features;


Qualifying Features


A246 Lullula arborea; Woodlark (Breeding)


12.B.3 Condition


reports for the complex of SSSIs16 that together form the Thames Basin Heaths SPA (see

Table 14-A for a summary), the designated sites extend to some 8,395.17 hectares, of

which some 46.8% is in ‘favourable’ condition, some 51.9% is in ‘unfavourable – recovering’

condition, some 0.4% is in ‘unfavourable – no change’ condition, and some 0.9% is in

‘unfavourable – declining’ condition. The majority of the SSSIs are composed of two main

habitat types, ‘dwarf shrub heath–lowland’ (5,933.07 hectares) and ‘coniferous woodland’

(2,144.95 hectares), with the balance made up of a mixture of acid grassland, neutral

grassland, fen, marsh and swamp, broadleaved, mixed and yew woodland, standing open

water and canals, and bracken.

16 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000009&ReportTitle=Ash%20to%20Brookwood%20Heaths%20SSSI;

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1006761&ReportTitle=Bourley%20and%20Long%20Valley%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003946&ReportTitle=Bramshill%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004223&ReportTitle=Broadmoor%20to%20Bagshot%20Woods%20and%20Heaths%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1006836&ReportTitle=Castle%20Bottom%20to%20Yateley%20and%20Hawley%20Commons%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004332&ReportTitle=Chobham%20Common%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001957&ReportTitle=Colony%20Bog%20and%20Bagshot%20Heath%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000162&ReportTitle=Eelmoor%20Marsh%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000926&ReportTitle=Hazeley%20Heath%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000870&ReportTitle=Horsell%20Common%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001052&ReportTitle=Ockham%20and%20Wisley%20Commons%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004008&ReportTitle=Sandhurst%20to%20Owlsmoor%20Bogs%20and%20Heaths%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001865&ReportTitle=Whitmoor%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000009&ReportTitle=Ash%20to%20Brookwood%20Heaths%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1006761&ReportTitle=Bourley%20and%20Long%20Valley%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003946&ReportTitle=Bramshill%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004223&ReportTitle=Broadmoor%20to%20Bagshot%20Woods%20and%20Heaths%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1006836&ReportTitle=Castle%20Bottom%20to%20Yateley%20and%20Hawley%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1006836&ReportTitle=Castle%20Bottom%20to%20Yateley%20and%20Hawley%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004332&ReportTitle=Chobham%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001957&ReportTitle=Colony%20Bog%20and%20Bagshot%20Heath%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000162&ReportTitle=Eelmoor%20Marsh%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000926&ReportTitle=Hazeley%20Heath%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000870&ReportTitle=Horsell%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001052&ReportTitle=Ockham%20and%20Wisley%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004008&ReportTitle=Sandhurst%20to%20Owlsmoor%20Bogs%20and%20Heaths%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001865&ReportTitle=Whitmoor%20Common%20SSSI


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Table 12-A: Thames Basin Heaths SPA complex of SSSIs – Condition Survey Findings

Main Habitat Type





Declining

Dwarf shrub heath – lowland

5,933.07 ha

(70.7%)

2,474.22 ha

(29.5%)

3,354.15 ha

(39.9%)

32.00 ha

(0.4%)

72.70 ha

(0.9%)

Acid grassland - lowland

29.34 ha

(0.35%)

28.92 ha

(0.3%)

0.0 ha

(0%)

0.42 ha

(<0.1%)

0.0 ha

(0%)

Coniferous Woodland

2,114.95 ha

(25.2%)

1,351.21 ha

(16.1%)

763.74 ha

(9.1%)

0.0 ha

(0%)

0.0 ha

(0%)

Standing open water & canals

19.78 ha

(0.2%)

14.87 ha

(0.2%)

2.71 ha

(<0.1%)

2.20 ha

(<0.1%)

0.0 ha

(0%)

Fen, marsh & swamp - Lowland

62.66 ha

(0.75)

44.24 ha

(0.5%)

18.42 ha

(0.2%)

0.0 ha

(0%)

0.0 ha

(0%)

Neutral grassland –

lowland

13.31 ha

(0.16%)

13.31 ha

(0.2%)

0.0 ha

(0%)

0.0 ha

(0%)

0.0 ha

(0%)

Broadleaved, mixed & yew woodland –

lowland

221.94 ha

(2.6%)

5.87 ha

(<0.1%)

216.07 ha

(2.6%)

0.0 ha

(0%)

0.0 ha

(0%)

Bracken 0.12 ha

(<0.1%)

0.0 ha

(0%)

0.0 ha

(0%)

0.12 ha

(<0.1%)

0.0 ha

(0%)

Totals 8,395.17 ha 3,932.64 ha

(46.8%)

4,355.09 ha

(51.9%)

34.74 ha

(0.4%)

72.70 ha

(0.9%)

12.9 For the 72.70 hectares of lowland dwarf shrub heath habitat classified as exhibiting

‘unfavourable – declining’ condition across the SPA, the condition survey reports for the

relevant SSSIs provide the following explanations and analyses (see below).

Colony Bog & Bagshot Heath SSSI (Surrey), Unit 3, 2.93 ha, Last surveyed 10/09/14

Comments: This unit has a small valley mire with a range of interesting species. The mire habitat is not being actively managed & is declining in nature conservation interest. There is some recent loss of wet heath & mire habitat due to unchecked growth of scrub, & spread of bracken. There is increasing cover (>20%) of pine (& some birch/willow) trees which are shading out both damp heath & mire communities. Due to the small & enclosed nature of this mire a target of zero scrub & bracken is appropriate. There is some rhododendron which needs removing. Bracken is present at higher levels than desirable. The cover of dwarf ericaceous shrubs is within targets but the cover of dense Molinia exceeds the recommended 50% in places & its litter is generally well above 50% cover & increasing. Common & cross-leaved heather are present as tall mature plants, bog myrtle is frequent. A number of species of Sphagnum are present in the mire & wet heath land fringes, but the shade & litter resulting from the Molinia & scrub is limiting the cover of Sphagnum (much less than target) & low-growing plants. Some of the positive indicators are still fairly frequent on the mire. Black bog rush is of greatest interest, & this remains widespread & locally frequent. Tormentil, cotton grass & bog asphodel are all occasional.


144

There are a few small pools of open water in the mire but there is very little bare/ exposed ground – less than the 1% minimum target level. The upper end of the mire has some growth of reedmace (Typha) which is indicative of possible enrichment of water supplies to the mire & a concern for the habitat. The unit also has a very small area of dry heath which has been managed to control scrub, gorse & bracken. This area has a good cover (70%) of common heather, & small amounts of birch & bracken. Gorse is regenerating quickly. The dry heath is in favourable condition but is a lesser priority in this unit than the mire

Reasons for adverse condition: Lack of corrective works - inappropriate scrub control

Colony Bog & Bagshot Heath SSSI (Surrey), Unit 18, 4.60 ha, Last surveyed 27/10/17

Comments: This unit is covered with mature secondary woodland with a more or less continuous canopy of silver birch, oak & chestnut with some beech & pine. The understorey & field layers include some gorse, bramble & bracken, with gorse, heather, fine grasses & honeysuckle. Previous habitat maps & aerial photos show significant areas of open heath land & dry grassland habitat within a smaller area of dry woodland. These glades & clearings of open habitat are now much reduced in size & quality, or have been lost beneath tree cover. The small parts of the site where there are tree canopy gaps do still retain some heather & tall leggy gorse, as well as fine grasses, but these are of negligible value to specialist heathland fauna, & are at risk of declining further due to the shade & leaf litter from the trees.


Castle Bottom to Yateley & Hawley Commons SSSI (Hampshire), Unit 7, 26.06 ha, Last surveyed 25/09/13

Comments: The following targets are currently not being met: Cover of trees & scrub species, cover of negative herbaceous species, extent of feature, frequency of positive indicator species, presence of all Heather growth phases, frequency of all heath grass, sedge & rush species, cover of negative indicator species (specific species), frequency of wildflowers. There has been a loss of extent of the lowland dry heath feature due to scrub & gorse encroachment. There is a lack of sufficient age structure of heather. There has been much public access & dog walking therefore the potential for disturbance at this site in particular to Annexe 1 heathland bird species is high. Dartford warbler numbers not at target across SSSI as a whole.


Hazeley Heath SSSI (Hampshire), Unit 13, 7.02 ha, Last surveyed 25/09/13

Comments: The unit is a mosaic of habitats, with a variety of wetter communities present. Historically it supported an area of wet mire which appears to have disappeared under wet Willow & Alder woodland. In drier areas the secondary woodland is dominated by Oak & Birch. The only sign of management is scrub clearance in a wayleave & here there is a wet grassland/fen community. Some wildflowers present such as Marsh Thistle, Wood Sedge, Honeysuckle, Gypsywort, Marsh Bedstraw, Greater Bird’s foot Trefoil, Lesser Spearwort, Marsh Pennywort, & Water Pepper. Himalayan Balsam & Bamboo sighted.

In the far south-west area, conditions are drier overall & the area has more potential to support lowland dry heath. The area would benefit from removal of bracken, trees & nettles. In many areas the community was observed to be very rank & dominated by grasses, sedges or rushes, with fewer wildflowers.

Reasons for adverse condition: Lack of corrective works - inappropriate scrub control, & inappropriate weed control


145

Bourley & Long Valley SSSI (Hampshire / Surrey), Unit 4, 32.09 ha, Last surveyed 26/06/13

Comments: There are large areas of the site where vegetation has been lost leaving bare, soft sand, not suitable for invertebrates due to disturbance. These areas appear to be expanding. Much of the grassland & heather has been mown very short, this may lead to loss of more vegetation. In particular, the heather which is not part of the few remaining large blocks, is tending to thin. Areas suitable for woodlark & nightjar have declined in recent years although a few birds do still succeed in fledging young. An area to the east of the site which was cleared of all heather & gorse in 2012 is showing scant signs of heather regeneration. The sections which were not scraped too deeply have some pioneer Calluna but most of the area is either bare or becoming dominated by weedy species & European gorse.

Reasons for adverse condition: Agriculture - inappropriate cutting/mowing; Lack of corrective works - inappropriate scrub control


‘unfavourable – no change’ condition across the SPA, the condition survey reports for the

relevant SSSIs provide the following explanations and analyses (see below).


Comments: The site fails the condition assessment due to the high cover of bracken, high cover of trees & shrubs, & an absence of positive floral & other indicators for heathland. Whilst the character of the area as a whole is still mostly that of secondary woodland, dwarf shrubs do occur throughout, in areas where the environment is more open. Heather, Bell heather, Cross-leaved Heath, Dwarf Gorse & Bog Myrtle were seen, with pioneer heather /regeneration occurring close to tracks & rides. These are all encouraging signs that the remnant heath could regenerate further if more areas are cleared. Otherwise, the area is dominated by dense & tall bracken stands & trees & shrubs of varying ages including Birch, Oak, Holly, Rowan & Conifers. Records of the three Annexe 1 birds have been assessed across the site as a whole – although recent count data seems to suggest that this site is not supporting these species directly.

Reasons for adverse condition: Agriculture – undergrazing; Lack of corrective works - inappropriate scrub control & inappropriate weed control


Comments: This area has been assessed for its potential to support Annexe 1 heathland bird species. The unit fails due to the dominance of conifer plantation. The supporting habitat surfaces for the invertebrate assemblages are also noted to be absent.


Ash to Brookwood Heaths SSSI (Surrey), Unit 12, 15.31 ha, Last surveyed 15/05/17

Comments: The unit is considered to be in unfavourable condition, as it provides a very limited area of rather poor quality ‘open’ habitat for heath land flora & fauna. The unit has the potential to be enhanced for heathland species, including the bird assemblage. At present there is no suitable nesting habitat for specialist heathland birds. Most of the unit has stands of closed canopy Scot’s pine plantation as the dominant vegetation: much of this is fairly mature, but there is an area with younger thicket stage pine saplings (3-4m), which have grown up on the site of a former clearing (from aerial photos). There are occasional broad-leaved trees, mainly English oak, silver birch & rowan, with some holly. Parts of the woodland floor are bare/ covered with pine litter, but there are frequent patches of bilberry (some quite large), & bracken is also widespread.


146

A stand of ling is present at the location of the pine saplings, but is now being shaded out. A wayleave passes along one of the unit boundaries, & forms an open corridor linking to adjacent parts of the SSSI/SPA where there are larger clearings of value to nesting heathland birds. The wayleave has a bare sandy track, with heathland vegetation along the verges including ling & cross-leaved heath, bilberry, purple moor-grass, gorse, & occasional fine grasses including bristle bent. The unit provides a little supporting habitat for SPA birds, with some of the woodland edge habitats suitable for foraging by nightjar. There is significant amount of recreational visitor pressure, mainly dog walkers along the wayleave.

Reasons for adverse condition: Lack of corrective works - inappropriate scrub control & inappropriate weed control

Broadmoor to Bagshot Woods & Heath SSSI (Surrey), Unit 1, 9.29 ha, Last surveyed 07/09/17

Comments: This SSSI unit includes 2 small areas either side of a road. The western area has about 1 ha of dry heath, with some secondary woodland. That area is fragmented from the remainder of the SSSI, being surrounded by roads & residential housing. The eastern area has a larger area of open habitat with a little over 4 ha of dry & wet heath, & mire, as well as mature coniferous woodland on the higher ground at the northern end of the unit. This area is continuous with the much larger areas of heathland to the east. The overall extent of heathland has been more or less maintained, with a slight reduction on the western block, & slight increase on the eastern side. The dry heath has some useful areas of dwarf shrubs, dominated by ling with bell heather & dwarf gorse being locally frequent. There is a generally low frequency & diversity of grasses & forbs on the dry heath – occasional Cladonia lichens, tormentil, cat’s-ear & wavy hair grass). There is quite good diversity in heather structure with scattered small & larger patches of pioneer growth (10-25%), as well as more extensive areas of building & mature heather (70-100%). There is excessively high cover (locally 20-50+%) of tall & dense invasive trees & scrub, & across the unit this scrub needs to be significantly reduced to meet SSSI targets. Common gorse is present as mature stands of value to birds – the cover of gorse is currently meeting targets. There is quite good representation of bare ground with a sunny aspect of high value to specialist insects. The mire is dominated by tall dense purple moor-grass (exceeding SSSI targets with 50-60+% cover across much of the mire) which is growing unchecked to shade & smother other vegetation, & is also accumulating potentially damaging amounts of litter – this is a threat to the habitat condition & a reason for this habitat not meeting the SSSI objectives for this habitat. The mire has reasonable cover (locally 10+%) of bog mosses Sphagnum spp. but this is difficult to accurately assess as it is ‘hidden’ beneath the tall canopy cover of purple moor-grass, & as such at risk of being shaded out or smothered by grass litter. Bog myrtle, cross-leaved heath, creeping willow, bog asphodel, green-ribbed sedge, tormentil & cotton grass are all present & locally frequent or occasional. Parts of the mire have a locally high density of young birch saplings which pose another threat to habitat condition if they are allowed to grow unchecked. The area has potential as a breeding habitat for the SPA Birds, & all 3 species have been previously recorded in low numbers from on or very close to the eastern area, although the unit has not been closely monitored in recent years & no accurate data is available.


12.11 For the 2.20 hectares of standing open water and canals habitat (Whitmoor Common SSSI

unit number 11, last surveyed on 16/08/06) classified as exhibiting ‘unfavourable – no


analysis.

Comments: All the aquatic plants which are the interest features of this site are no longer found here. The pond requires a full scale lake restoration to restore habitats for these features.

Reasons for adverse condition: Freshwater – siltation


147

12.12 For the 0.42 hectares of lowland acid grassland habitat (Bramshill SSSI unit number 4, last

surveyed on 30/08/12) classified as exhibiting ‘unfavourable – no change’ condition, the


Comments: Small fleabane was once present in some shallow ditches, however none was found on this visit. The shallow ditches are covered in vegetation such as grasses, rushes & some common fleabane, & there is little bare ground present. The field is also mown to help keep the sward short but grazing is not heavy enough.

Reasons for adverse condition: Agriculture – Undergrazing

12.13 For the 0.12 hectares of bracken habitat (Castle Bottom to Yateley & Hawley Commons SSSI

unit number 9, last surveyed on 19/09/13) classified as exhibiting ‘unfavourable – no


analysis.

Comments: The area was surveyed on the condition of its habitat supporting the three heathland bird species; Nightjar, Woodlark & Dartford Warbler. As this small area is mostly dominated by Bracken & Rhododendron, it is considered to be unsuitable. Remnant lowland heath was not found on the visit. Aggregations of birds features were assessed over the SSSI as a whole, but count data suggests that this site is not supporting these species directly.



12.14 The published Site Improvement Plan (SIP) for the SPA (03 November 2014) identifies the



12.C.1;

Changes in grazing practices – discussed further in section 12.C.2;


12.C.3


Changes in the incidence of wildfire / arson – discussed further in section 12.C.5;


in section 12.C.6;

Changes in the condition, location and extent of the features of qualifying interest –


Changes in the use of the land for military activities – discussed further in section 12.C.8;

Changes due to habitat fragmentation – discussed further in section 12.C.9.


148

12.C.1 Public Access / Disturbance

12.15 The features affected by changes in public access and disturbance are the populations of

the European nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford Warbler

(A302(B)). The SIP (pp.5/20 and 6/20) offers the following explanation of the nature of the


“Parts of Thames Basin Heaths (& Thursley, Hankley & Frensham Commons SPA) are subject to

high levels of recreational use & dog walkers make up a large proportion of visitors. This is

likely to be affecting the distribution & overall numbers of ground-nesting Annex 1 birds (&

breeding success). An 'avoidance strategy' is in place to help manage this pressure, including

the provision of Suitable Accessible Natural Green Space (SANGS). However, recreational

pressure may be hampering the potential for the sites to achieve their full contribution to

sustainable national populations. Further work is desirable to determine the scale of impact

from recreational disturbance. There is also concern at the growing use of parts of the

complex by commercial dog walkers & desire to control this. Improved habitat management

to increase suitability for Annex 1 birds & better coordination of habitat provision across the

complex is also needed to better offset the effects of disturbance.”


pressure/threat are concerned with producing an over-arching habitat management

strategy to help offset/ decrease the effects of recreational disturbance on Annex 1 birds,

with producing coherent and consistent access management strategies for all sites, and

with implementing a wardening strategy to reduce impacts of recreational disturbance on

Annex 1 birds.


by the Surrey WLP could result in changes in the number of visitors to the SPA. The Surrey



county of Surrey. The construction of new waste facilities, even on land located in close

proximity to components of the SPA, would not typically be a source of prospective visitors,

compared with, for example, new residential development.






pathway.

12.C.2 Undergrazing

12.19 The features affected by under-grazing are the habitats of the populations of the European

nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford Warbler (A302(B)). The SIP

(pp.6/20 to 8/20) offers the following explanation of the nature of the identified pressure:


149

“Parts of the complex are undermanaged. Limitations are such that traditional stock cannot

be used (because they are live firing ranges), or resistance to the fencing of common land. The

excessive cost of disposal of arisings from cutting management is a significant factor making it

impractical for large scale use. Controlled burning is not considered a practical alternative in

this complex. Lack of grazing over a long period has resulted in poor habitat quality &

restoration will take a long time. Grazing may actually be having negative impacts in some

cases & improved management is required in these instances. There is scope to improve

efficiency in use of resources through improved coordination, sharing of equipment &

improved partnership working.”


concerned with:

Implementing appropriate alternative management where grazing is not practical;

Investigating possible economic uses of material arising from habitat management,

such as biomass to bioenergy;

Developing a heathland management partnership which seeks to share resources,

expertise and equipment in order to increase efficiencies in management delivery;

Producing agreed management plans for key sites which identify priority actions to

improve condition of Natura 2000 features;

Improving long-term management of power line wayleaves with power suppliers to

avoid damaging impacts and improve habitat condition and connectivity.


by the Surrey WLP would impact upon current or future grazing practices within the SPA.

The only points at which the grazing regime implemented across the SPA may interface

with waste management operations and practices would be in respect of a need for the

removal and appropriate management of the waste materials that will arise from time to

time as a consequence of active grazing of the heathland (e.g. fallen stock, etc.). It is

unlikely that any increase in grazing of the SPA would result in a significant rise in demand

for fallen stock management services, to an extent that demand would exceed the capacity

of existing service providers.



would not give rise to direct or indirect significant impacts on grazing practices within the

SPA, and therefore would not affect the condition of the heathland habitats. No further

assessment is required in respect of the undergrazing impact pathway.

12.C.3 Forestry & Woodland Management

12.23 The features affected by changes in forestry and woodland management are the habitats of

the populations of the European nightjar (A224(B)), the Woodlark (A246(B)), and the

Dartford Warbler (A302(B)). The SIP (p.8/20) offers the following explanation of the nature



150

“Large parts of Thames Basin Heaths are occupied by commercial forestry plantations where

the maintenance of suitable conditions for Annex 1 birds is dependent upon rotational felling.

However, there is no coordination or overall management plan & felling is dependent upon

market forces. Climate change is also causing change in thinking amongst managers with

introduction of broadleaves being considered & change from rotational to continuous cover

management.”


concerned with undertaking a review of long-term forestry management policy in the

complex to ensure suitable habitat conditions for Annex 1 birds are consistently

maintained.



management practices within the SPA. The only points at which the forestry and woodland

management regime implemented across the SPA may interface with waste management

operations and practices would be in respect of a need for the removal and appropriate

management of the waste materials that will arise from time to time as a consequence of

active woodland management (e.g. green waste from thinning, coppicing, etc.). It is unlikely

that any increase in active woodland and forestry management within the SPA would result

in a significant rise in demand for green waste management services, to an extent that

demand would exceed the capacity of existing service providers.




management practices within the SPA, and therefore would not affect the condition of

those habitats. No further assessment is required in respect of the changes in woodland or

forestry management impact pathway.

12.C.4 Inappropriate Scrub Control

12.27 The features affected by inappropriate scrub control practices are the habitats of the

populations of the European nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford

Warbler (A302(B)). The SIP (p.10/20) offers the following explanation of the nature of the

identified pressure:

“Ineffective or lack of scrub control affects some areas of dry & wet heath, especially at Colony

Bog, & at Bourley & Long Valley. The absence of scrub management plans at most sites is of

concern as it is often viewed as a negative aspect with little consideration given for its value to

Annex 1 birds. There is also concern that scrub management is a constant, significant drain on

resources – there is a need for investigation of options which give an economic return on scrub

management.”


concerned with implementing a programme of scrub clearance to reverse effects of


151

encroachment of heathland to follow on from investigation of the potential for sustainable

use of the waste arising.



SPA. The only points at which the scrub control regime implemented across the SPA may



time to time as a consequence of active management (e.g. green waste from scrub

clearance, etc.). It is unlikely that any increase in active scrub control within the SPA would

result in a significant rise in demand for green waste management services, to an extent

that demand would exceed the capacity of existing service providers.



would not give rise to direct or indirect significant impacts on scrub management practices

within the SPA, and therefore would not affect the condition of those habitats. No further


12.C.5 Wildfire / Arson

12.31 The features affected by changes in the risk or incidence of wildfire or arson are the

populations of European nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford

Warbler (A302(B)) and the habitats on which they depend. The SIP (p.11/20 and 12/20)

offers the following explanation of the nature of the identified pressure:

“Uncontrolled fires are very damaging as they can have profound impacts on reptile

populations, invertebrates & plant diversity & can result in significant habitat loss for Annex 1

birds. They can affect forestry areas as well as open heath. Damaging impacts can last for

many years for example by the wholesale removal of all gorse from a site. Strategies are in

place in parts of the complex to reduce risk but more attention is needed to properly address

this issue. Increasing threat of extensive fires is of great concern to the fire services & there is

a desire for greater link up between efforts to protect property & roads from fire, & habitat

management.”


concerned with completing and implementing fire strategies and risk management plans

for all sites, with undertaking a public fire awareness campaign, and with embedding

wildfire mitigation and adaptation into local authority Local Development Plan policies.



the SPA. It is conceivable that certain types of waste management facility could present a

fire risk to designated sites, where those facilities were located in close proximity to the

sensitive habitats. There have been incidences of significant fires at waste recycling and

storage facilities that handle household, industrial and commercial wastes, and there have


152

been cases of spontaneous combustion occurring at green waste composting facilities due

to inappropriate stockpiling and management of the waste materials. None of the sites

proposed for allocation under Policy 11 or the ILAS identified under Policy 10 in the Surrey

WLP are in close enough proximity (within 400 metres) to the SPA to present a genuine fire

risk.




within the SPA, and although waste related development could, in theory, present a fire risk

to the SPA, the sites allocated under Policy 11 and the ILAS identified under Policy 10 are

too distant (>400 metres) to present a credible threat. No further assessment is required in

respect of the wildfire and arson impact pathway.


habitats of the populations of the European nightjar (A224(B)), the Woodlark (A246(B)),

and the Dartford Warbler (A302(B)). The SIP (p.12/20) offers the following explanation of

the nature of the identified pressure/threat:



sedge dominated systems rather than Sphagnum dominated; spread of Molinia into wet & dry

heath also appears to be promoted by high nitrate levels. This is most likely to be a current

issue at Chobham Common but may represent a chronic adverse impact over the complex as a

whole.”


pressure/threat are concerned with controlling and reducing nitrogen emissions and

deposition, and with ameliorating the impacts of that deposition.



on the SPA. Of particular concern are waste management facilities that make use of




12.38 The potential for thermal treatment development at the sites allocated under Policy 11a

(see below) to give rise to likely significant effects has been identified on the basis of

predicted process contributions being equivalent to 1% or more of the minimum site

relevant critical load for the most sensitive habitat within the SPA (see Part B7, Appendix B).

Site 2: Weylands TW, Lyon Road, Walton on Thames.

Site 3: Land north east of Slyfield Industrial Estate, Guildford.


153

Site 4: Land at Leatherhead STW, Randalls Road, Leatherhead.

12.39 Fifteen of the ILAS (see below) identified under Policy 10 of the Surrey WLP are located

within 10 kilometres of at least one component part of the SPA. The development of

thermal treatment facilities on land located within any one of those fifteen ILAS could, in

theory, present risks of nutrient nitrogen deposition on land within the SPA.



kilometres north west of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS02 (Hersham Trading Estate, Lyon Road, Walton on Thames), 6.9 kilometres north

east of the Ockham & Wisley Commons SSSI component of the SPA.


the north east of the Ockham & Wisley Commons SSSI component of the SPA.


kilometres to the south east of the Whitmoor Common SSSI component of the SPA.


south of the Whitmoor Common SSSI component of the SPA.


Ash to Brookwood Heaths SSSI component of the SPA.


Portsmouth Road, Peasmarsh), 6.8 kilometres south of the Whitmoor Common SSSI



of the Whitmoor Common SSSI component of the SPA.

ILAS14 (Thorpe Industrial Estate, Ten Acre Lane, Egham), 5.5 kilometres north east of

the Chobham Common SSSI component of the SPA.

ILAS15 (Byfleet Road, Employment Allocation, New Haw, Byfleet), 2.9 kilometres north

west of the Ockham & Wisley Commons SSSI component of the SPA.

ILAS16 (Windmill Road Industrial Area, Sunbury-on-Thames), 9.8 kilometres north of

the Ockham & Wisley Commons SSSI component of the SPA.


kilometres east of the Castle Bottom to Yateley & Hawley Commons SSSI component

of the SPA.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 3.2 kilometres to the south of

the Bourley & Long Valley SSSI component of the SPA.


Farnham), 2.1 kilometres south east of the Bourley & Long Valley SSSI component of

the SPA.

ILAS22 (Monument Way East Industrial Estate, Woking), 0.7 kilometres south of the

Horsell Common SSSI component of the SPA.


154

12.40 In terms of the potential for diffuse emissions, a proportion of the traffic generated by

waste related development at the closest proposed site allocation to components of the

SPA (Site 3 – Land NE of Slyfield IE, Guildford) could be reasonably expected to travel along

roads that pass through a part of the SPA (Whitmoor Common SSSI). The traffic generated

by the development of a large scale facility (i.e. c.300,000 tpa capacity energy from waste

plant), could equate to an additional 838 vehicles on sections of road that pass through the

SPA. That number of vehicles is close to the 1,000 AADT threshold cited in the Design

Manual for Roads & Bridges (Volume 11, Section 3, May 2007).

12.41 For Site 3 (Land NE of Slyfield IE, Guildford) the preferred vehicle route described in the

Transport Study for the Surrey WLP (section 3.3, p.22) is to the south to the A3 via the

A320, and it is not anticipated that traffic would travel north along the section of the A320

that passes through Whitmoor Common SSSI. On that basis it is concluded that significant

impacts from traffic emissions associated with the development of a waste facility at Site 3

are unlikely to affect the SPA. The HRA for the Guilford BC Local Plan concluded that

implementation of that plan would not give rise to significant impacts on the SPA as a

consequence of traffic emissions, alone or in-combination with other plans and projects.

12.42 For Site 6 (Land at Trumps Farm, Longcross), allocated under Policy 11b of the Surrey WLP

for development as a small to medium scale dry mixed recyclables processing facility, there

is little risk of the majority of the traffic generated by the facility passing through the SPA.

The closest SPA component to Site 6 is the Chobham Common SSSI, located some 1.4

kilometres to the south west. Access to Site 6 would be achieved from the south via

Longcross Road (B386) and Kitsmead Lane which links to the A320 to the east. The HRA for

the Runnymede BC Local Plan concluded that implementation of that plan would not give

rise to significant impacts on the SPA as a consequence of traffic emissions, alone or in-

combination with other plans and projects.



strategic road networks. Three of the identified ILAS (ILAS05 – Slyfield IE, Guildford; ILAS17

– York Town IE, Camberley; and ILAS22 – Monument Way East IE, Woking ) are situated

such that waste related development at those locations could contribute to additional

traffic on the sections of ‘A’ roads (A320, A30 and A320 and A245 respectively) that pass

through or within component parts of the SPA. For ILAS05, as for Site 3, it is anticipated

that the majority of traffic would travel south along the A320 to the A3, and would not pass

north through Whitmoor Common SSSI. For ILAS17 it is unlikely that traffic servicing any

waste management facility would travel exclusively on the A30 (east-west) when the ILAS is

also accessible from the A331 (north-south). For ILAS22 it is likely that a proportion of the

traffic arising from any waste management facility would travel along sections of the A320

and A245 that pass through or within 200 metres of the Horsell Common SSSI, however

given the status of the ILAS as an established industrial estate it is likely that any waste

facility would be small in scale (<50,000 tpa) and would generate limited additional traffic.


155

12.44 Screening Conclusion: The implementation of the Surrey WLP would not give rise to

significant impacts on nutrient nitrogen deposition within the SPA, as a consequence of

emissions from traffic sources. The potential for significant impacts as a consequence of

emissions from thermal treatment plant at one or more of the allocated sites or identified

ILAS situated within 10 kilometres of the SPA cannot be ruled out at the screening stage.

Further assessment is required in respect of the air pollution (emission and deposit of

nitrogen) impact pathway in respect of point source emissions from one or more of the

allocated sites or identified ILAS.

12.C.7 Monitoring of Feature Condition, Location & Extent

12.45 The features affected are the populations of the European nightjar (A224(B)), the Woodlark

(A246(B)), and the Dartford Warbler (A302(B)). The SIP (p.13/20) offers the following

explanation of the nature of the identified threat:

“There are significant gaps in the knowledge of key aspects such as where woodlarks are

overwintering & whether these sites are in need of protection, & coverage of the complex in

terms of monitoring of Annex 1 birds is not comprehensive so recorded bird numbers are not

representative of total numbers. Also, current monitoring does not provide information on

breeding success, only territory numbers.”


concerned with establishing a sustainable long-term bird monitoring strategy which

provides adequate coverage of all parts of the SPA, and with commissioning research to

determine the critical factors in the breeding success of woodlark in this complex,

particularly focussing on possible effects of climate change and changing weather patterns.

12.47 Screening Evaluation: The implementation of the Surrey WLP could make a limited

contribution to the availability of information about the ways in which the SPA bird species

make use of the designated site and other suitable habitats in the surrounding area. The

Surrey WLP is concerned with the provision of additional waste management capacity over

the 15 year plan period, to meet identified current and future gaps in capacity, and would

present limited opportunities for the collection of ecological data associated with the

proposed development of specific sites. A number of the sites allocated under Policy 11 and

the ILAS identified under Policy 10 of the Surrey WLP are located in close proximity to the

SPA, and ecological survey work associated with any applications that may come forward in

respect of those sites could contribute to the wider body of knowledge available about the

SPA bird species use of designated and un-designated habitats.



would not give rise to significant impacts on the SPA with reference to the monitoring and

ongoing evaluation of the behaviours of the SPA bird species. No further assessment is

required in respect of the feature of interest monitoring impact pathway.


156

12.C.8 Military Uses

12.49 The features affected by changes in military use of the designated land are the populations

of the European nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford Warbler

(A302(B)). The SIP (p.13/20) offers the following explanation of the nature of the identified

threat:

“None of the military training areas in the complex currently have integrated management

plans which seek to integrate management of the estate for military training with nature

conservation management. There is a need for improved communication between partners

over common objectives.”


concerned with completing integrated management plans for all military training sites in

the complex.



manages those areas of land that it owns within the SPA designation. The Surrey WLP is






would not give rise to direct or indirect significant impacts on the SPA with reference to the

use of land within the SPA designation for military purposes. No further assessment is

required in respect of the military uses impact pathway.

12.C.9 Habitat Fragmentation

12.53 The features affected by further fragmentation of the supporting habitats are the

populations of the European nightjar (A224(B)), the Woodlark (A246(B)), and the Dartford

Warbler (A302(B)). The SIP (p.14/20) offers the following explanation of the nature of the


“Fragmentation of the complex means that recovery after devastating impacts such as fires &

severe winters is restricted or prevented altogether. This has implications for the ability of

species such as Dartford warbler, smooth snake, marsh clubmoss, specialist invertebrates to

recolonise parts of the complex. There is currently high risk of local extinctions in parts of the

complex because of this.”


concerned with commissioning a study to identify priorities for habitat management that is

able to ameliorate the effects of habitat fragmentation.


157

12.55 Screening Evaluation: None of the sites proposed for allocation or the ILAS identified in the

Surrey WLP are in close enough proximity to the SPA to contribute directly to the further

fragmentation of the habitats of the designated site, with the closest located some 0.54

kilometres to the east. Much of the land surrounding the SPA components that are situated

in Surrey lies within the Metropolitan Green Belt, and it is therefore unlikely that waste

related development would be brought forward on non-allocated land in closer proximity

to the SPA than the closest proposed site allocation or identified ILAS, as strategic waste


Belt context.



would not give rise to direct or indirect significant impacts on the SPA with reference to

habitat fragmentation. No further assessment is required in respect of the habitat

fragmentation impact pathway.



deposition of nitrogen) by which development at three of the sites allocated under Policy

11a of the Surrey WLP (Site 2 – Weylands TW, Walton on Thames, Site 3 – Land NE of

Slyfield IE, Guildford, and Site 4 – Leatherhead STW, Leatherhead) and fifteen of the ILAS

identified under Policy 10 could give rise to significant effects on the SPA. The mechanism

by which the development of the proposed sites and identified ILAS could contribute to the

deposit of nutrient nitrogen would be point source pollution from thermal treatment

plants.

12.58 In total twenty areas of land allocated or otherwise identified under policies in the Surrey

WLP are located within 10 kilometres of the Thames Basin Heaths SPA. Modelling of the

potential effects of a range of scales of thermal treatment plants has been carried out for

the allocated sites (see Part B7, Appendix B, and Appendix C). For the ILAS, for which

detailed modelling has not been carried out, judgements (see Part B7, Appendix B) have

been made on the basis of the findings of the modelling undertaken for the allocated sites

(and sites previously proposed for allocation at the Regulation 18 stage of the Surrey WLP).

The ILAS were not considered to be suitable candidates for the siting of large scale (>50,000

tpa) thermal treatment facilities, and the assessment therefore only considered the impacts

of small scale (<50,000 tpa) facilities at those locations. Details of the site relevant critical

loads for all the features covered by the SPA designation can be found in Part B7 of

Appendix B to this report.

12.59 For Site 2 (Weylands TW, Walton on Thames) the modelling (see Part B7, Appendix B)



type required to support the SPA bird species. The estimated background deposition rates

for nutrient nitrogen within the area of the SPA closest to Site 2 exceed the minimum site


158

relevant critical loads across both the habitat types of the SPA bird species (see Part B7,

Appendix B). The PEC (background plus process contribution) would increase by between

0.6% to 2.5% for coniferous woodland, and by between 0.9% to 4.0% for heathlands.

12.60 For Site 3 (Land NE Slyfield IE, Guildford) the modelling (see Part B7, Appendix B) indicated

that the emissions arising under each of the four scenarios considered would account for

more than 1% of the minimum site relevant critical loads across each habitat type required

to support the SPA bird species. The estimated background deposition rates for nutrient

nitrogen within the area of the SPA closest to Site 3 exceed the minimum site relevant

critical loads across both the habitat types of the SPA bird species (see Part B7, Appendix B).

The PEC (background plus process contribution) would increase by between 2.2% to 5.7%

for coniferous woodland, and by between 3.6% to 9.2% for heathlands.

12.61 For Site 4 (Leatherhead STW, Leatherhead) the modelling (see Part B7, Appendix B)



type required to support the SPA bird species. The estimated background deposition rates

for nutrient nitrogen within the area of the SPA closest to Site 4 exceed the minimum site

relevant critical loads across both the habitat types of the SPA bird species (see Part B7,

Appendix B). The PEC (background plus process contribution) would increase by between

0.4% to 2.0% for coniferous woodland, and by between 0.7% to 3.2% for heathlands.

12.62 For the fifteen ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SPA it was concluded that the majority would be less suited to the

development of small-scale thermal treatment facilities (<50,000 tpa). In four cases the

conclusion was that the ILAS would be unsuited to the development of any scale of thermal

treatment facility.

12.62.1 ILAS05 (Slyfield IE, Guildford), ILAS07 (Lysons Avenue, Ash Vale), ILAS17 (York

Town IE, Camberley), and ILAS22 (Monument Way East IE, Woking) were found

to be unsuitable as locations for small scale thermal treatment facilities, due to

their geographical proximity and relationship to components of the SPA (all

within 1.0 kilometres of a constituent SSSI).

12.62.2 For ILAS01 (Brooklands IE et al, Byfleet), ILAS02 (Hersham TE, Walton on

Thames), ILAS03 (Molesey IE, West Molesey), ILAS06 (Woodbridge Meadows

IE, Guildford), ILAS08 (Riverwey IE et al, Peasmarsh), ILAS09 (Burntcommon

Warehouse, Send), ILAS14 (Thorpe IE, Thorpe), ILAS15 (Byfleet Road

Employment Allocation), ILAS16 (Windmill Road Industrial Area, Sunbury on

Thames), ILAS20 (Coxbridge BP, Farnham), and ILAS21 (Farnham TE, Farnham)

it may be feasible for a small scale (<50,000 tpa) thermal treatment facilities to

be accommodated in one or more of those locations subject to it being

demonstrated at the planning application stage that the ecological integrity of

the SPA would not be adversely affected.


159

12.63 The scope for the development of thermal treatment facilities on land at any of the ILAS

(excepting ILAS05, ILAS07, ILAS17 and ILAS22) would also be dependent on the type and

scale of waste related development that proceeds on the sites allocated under Policy 11a

(Site 2, Site 3 and Site 4) of the Surrey WLP that lie within 10 kilometres of the SPA. If all

three of the allocated sites were to be brought forward for some scale and type of thermal

treatment facility the need to manage the possibility of in-combination effects arising from

those developments would reduce the suitability of those ILAS also located within 10

kilometres of the same SPA components as potential locations for thermal treatment

facilities. Implementation of Policy 14 of the Surrey WLP, which requires that all waste

related planning application be supported by sufficient information for the WPA to


on the natural environment, including SPAs and SACs, will ensure that permitted

development does not compromise the ecological integrity of the SPA.

12.E Conclusions 12.64 The assessment of the implications of the implementation of the Surrey WLP for the

ecological integrity of the Thames Basin Heaths SPA has concluded that overall there would

be no potential for ‘likely significant effects’ to arise, subject to the observation of a

number of decision rules with reference to the development of thermal treatment facilities.

12.64.1 One of the sites allocated under Policy 11a (Site 3: Land north east of Slyfield

IE, Guildford) and four of the ILAS (ILAS05; ILAS07; ILAS17; and, ILAS22)

identified under Policy 10 of the Surrey WLP are located in sufficiently close

proximity to components of the SPA to render them unsuitable as locations for

different scales of thermal treatment facility. The construction and operation

of large scale (>50,000 tpa) thermal treatment facilities is not recommended

on Site 3, although there may scope for the development of a facility with a

capacity of less than 50,000 tpa, subject to the outcome of detailed modelling

and assessment at the planning application stage. In the interests of managing

the risk of in-combination effects it is recommended that four of the identified

ILAS, ILAS05, ILAS07, ILAS17 and ILAS22, would be unsuitable locations for all

scales of thermal treatment plants.





management facilities would travel along those parts of the road network that

pass through the thirteen SSSIs that together form the SPA.

12.65 The assessment considered the nine impact pathways identified as key threats and


conclusions reached in respect of the likely impact of the Surrey WLP on the SPA via each



160



Level




12.C.1



WLP

Screening

Changes in grazing practices –


12.C.2



WLP

Screening


woodland management


in section 12.C.3



WLP

Screening



in section 12.C.4



WLP

Screening


wildfire / arson – discussed




WLP

Screening





12.C.6 & section 12.D

Three allocated sites (Site 2, Site 3 and Site4) and

seventeen ILAS (ILAS01, ILAS02, ILAS03, ILAS05,

ILAS06, ILAS07, ILAS08, ILAS09, ILAS14, ILAS15,

ILAS16, ILAS17, ILAS20, ILAS21, ILAS22) located

within 10 km of the SPA. Potential for adverse





recommended on Site 3.


at ILAS05, ILAS07, ILAS17 and ILAS22.

For all other allocated sites and ILAS thermal

treatment may be feasible, subject to project level

assessment.





on the SPA, subject to implementation of the






Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)


161


Level

Changes in the condition,

location and extent of the

features of qualifying interest


12.C.7



WLP

Screening

Changes in the use of the

land for military activities –


12.C.8



WLP Screening






WLP Screening

12.66 The further information provided in parts C (paragraphs 5-7, p.10), E (paragraphs 11-15,

pp.12-13), H-3 (paragraphs 28-32, pp.19-20), H-4 (paragraphs 33-38, pp.20-22), H-8

(paragraphs 51 and 53-55, pp.25-26) and H-10 (paragraphs 59 and 61-62, pp.27-28) of the

appendix to the Statement of Common Ground between Natural England and Surrey

County Council, dated 8 August 2019, does not alter the conclusions reached by the HRA

process in respect of the likely impacts of the Surrey WLP on the Thames Basin Heaths SPA.

That further information provides detailed descriptions of the physical relationship

between two proposed allocated sites (Site 3 – Land north east of Slyfield Industrial Estate,

Guildford; and, Site 6 – Trumps Farm, Longcross) and four proposed ILAS (ILAS05 – Slyfield

Industrial Estate, Guildford; ILAS07 – Land north and south of Lysons Avenue, Ash Vale;

ILAS17 – York Town Industrial Estate, Camberley; and, ILAS22 – Monument Way East

Industrial Estate, Woking) and component parts of the SPA. Those descriptions serve to

reinforce the conclusions reached through the HRA process, that waste development at

either of the allocated sites or any of the ILAS would not result in significant impacts on the

ecological integrity of the SPA.

12.F References 12.67 The following sources of information have been referred to as part of the assessment

process for the Thames Basin Heaths SPA.


Protection Area (SPA) – Thames Basin Heaths SPA (Natural England (English

Nature), February 2005).


Wild Birds Directive – Thames Basin Heaths SPA (Joint Nature Conservation


12.67.3 European Site Conservation Objectives for Thames Basin Heaths Special

Protection Area (Site Code: UK9012141) (Natural England, 30 June 2014, v.2).


162

12.67.4 Site Improvement Plan: Thames Basin (covering the Thames Basin Heaths SPA,

the Thursley, Ash, Pirbright & Chobham SAC, & the Thursley, Hankley &

Frensham Commons (Wealden Heaths Phase 1) SPA) (Natural England, 3

November 2014).



12.67.6 Ash to Brookwood Heaths SSSI Condition Survey Report (Natural England,


12.67.7 Bourley & Long Valley SSSI Condition Survey Report (Natural England,


12.67.8 Bramshill SSSI Condition Survey Report (Natural England, Designated Sites


12.67.9 Broadmoor to Bagshot Woods & Heaths SSSI Condition Survey Report (Natural


12.67.10 Castle Bottom to Yateley & Hawley Commons SSSI Condition Survey Report


12.67.11 Chobham Common SSSI Condition Survey Report (Natural England, Designated


12.67.12 Colony Bog & Bagshot Heath SSSI Condition Survey Report (Natural England,


12.67.13 Eelmoor Marsh SSSI Condition Survey Report (Natural England, Designated


12.67.14 Hazeley Heath SSSI Condition Survey Report (Natural England, Designated Sites


12.67.15 Horsell Common SSSI Condition Survey Report (Natural England, Designated


12.67.16 Ockham & Wisley Commons SSSI Condition Survey Report (Natural England,


12.67.17 Sandhurst to Owlsmoor Bogs & Heaths SSSI Condition Survey Report (Natural


12.67.18 Whitmoor Common SSSI Condition Survey Report (Natural England,




June 2018.




163

12.67.21 Habitats Regulations Assessment Screening of Woking Borough Council's Draft

Core Strategy Policies with Potential for Impacts on Natura 2000 & Ramsar

Sites, Mayer Brown for Woking Borough Council, December 2011.

12.67.22 Habitats Regulations Assessment for Guildford Borough Proposed Submission

Local Plan: Strategy & Sites, 2017 Update, AECOM for Guildford Borough

Council, April 2017.

12.67.23 Appropriate Assessment Report Pursuant to the Conservation of Habitats and

Species Regulations 2017 on the Likely Significant Effects and Adverse Effects

on Integrity of Runnymede Borough Council’s Local Plan: HRA Screening and

Appropriate Assessment Report, AECOM for Runnymede Borough Council, April

2018.





164

Chapter 13 Thursley, Ash, Pirbright & Chobham SAC


13.A.1 Location of the SAC 13.1 The Thursley, Ash, Pirbright & Chobham SAC (see map) is located in the county of Surrey

covers an area of 5,138.00 hectares, as stated on the SAC citation, and was designated on 1

April 2005. The SAC is situated within an area administered by Surrey County Council,

Guildford Borough Council, Surrey Heath Borough Council, Waverley Borough Council. The

SAC is composed of the following four SSSIs:

Ash to Brookwood Heaths SSSI, located in Surrey and covering some 1,576.35 hectares.

Chobham Common SSSI, located in Surrey and covering some 655.73 hectares.

Colony Bog & Bagshot Heath SSSI, located in Surrey and covering some 1,130.51

hectares.

Thursley, Hankley & Frensham Commons SSSI, located in Surrey and covering some

1,876.41 hectares.

13.2 The following ‘A’ class roads pass through, or within 200 metres of the four SSSIs that

together form the SAC.

13.2.1 The A3 (Portsmouth Road), the A287 (Farnham Road), the A286 (Haslemere

Road) and the A3100 (Portsmouth Road) all pass through the Thursley, Hankley

& Frensham Commons SSSI.

13.2.2 The M3 motorway, which passes through the Chobham Common SSSI, and

within 200 metres of the Colony Bog & Bagshot Heath SSSI.

13.2.3 The A322 (Bagshot Road), which passes within 200 metres of the Ash to

Brookwood Heaths SSSI, and the Colony Bog & Bagshot Heath SSSI.

13.2.4 The A324 (Pirbright Road), which passes through and within 200 metres of the

Ash to Brookwood Heaths SSSI.

13.3 The SAC extends across a number of different surface water catchments, many of which lie

wholly or partly within the county of Surrey.

13.3.1 Within the Wey river basin, the catchments of the, Clasford Brook & Wood

Street Brook (GB106039017850); Hoe Stream (Normandy to Pirbright)

(GB106039017870); Hoe Stream (Pirbright to River Wey confluence at Woking)

(GB106039017900); Hale / Mill Bourne (Bagshot to Addlestone Bourne

confluence near Chobham) (GB106039017930); Chertsey Bourne (Virginia

Water to Chertsey) (GB106039017070); Wey Navigation (Pyrford Reach)

(GB106039017910); Addlestone Bourne (West End to Hale / Mill Bourne

confluence at Mimbridge) (GB106039017920); Royal Brook



165

(GB106039017760); the Truxford Brook (GB106039017770); the Wey (Tilford

to Shalford) (GB106039017820); the South Wey (River Slea confluence to

Tilford) (GB106039017780); and the Ock (GB106039017790).

13.3.2 Within the Loddon river basin, the catchments of the, Blackwater (Aldershot to

Cove Brook confluence at Hawley) (GB106039017180).


13.4 The Thursley, Ash, Pirbright & Chobham SAC is located within 10 kilometres of the following

sites (See below) proposed for allocation under Policy 11a (Site 3) or 11b (Site 6) of the

Surrey WLP (see Figure 13-A – a full size version can be found in Appendix A). The Plan

specifies the scale and type of waste related development that could be accommodated by

Site 6 (Trumps Farm, Longcross), which excludes any form of thermal treatment. The SAC is

located within 10 kilometres of the following ILAS (see below) identified under Policy 10 of

the Surrey WLP (see Figure 13-A). The Plan does not specify the type or scale of waste

related development that could be accommodated on the identified ILAS. Full details of the

relationship of the individual SSSIs that together form the SAC to all the sites allocated

under Policy 11 and all the ILAS identified under Policy 10 of the Surrey WLP can be found

in Appendix A (Tables A-1 to A-5) to this report.

‘Site 3 – Land to the north east of Slyfield Industrial Estate, Moorfield Road, Guildford’,

4.7 kilometres to the south east of the Ash to Brookwood Heaths SSSI component of

the SAC.

‘Site 6 – Land to the south of the M3 motorway & north of the former Trumps Farm

landfill, Kitsmead Lane, Longcross, Chertsey’, 1.4 kilometres to the north east of the

Chobham Common SSSI component of the SAC.



kilometres south east of the Chobham Common SSSI component of the SAC.


kilometres to the south east of the Ash to Brookwood Heaths SSSI component of the

SAC.


south east of the Ash to Brookwood Heaths SSSI component of the SAC.


Ash to Brookwood Heaths SSSI component of the SAC.


Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the Thursley, Hankley &

Frensham Commons SSSI component of the SAC.


of the Ash to Brookwood Heaths SSSI component of the SAC.


166


kilometres east of the Colony Bog & Bagshot Heath SSSI component of the SAC.

ILAS19 (Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh), 8.8 kilometres south

east of the Thursley, Hankley & Frensham Commons SSSI component of the SAC.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 4.8 kilometres to the north

west of the Thursley, Hankley & Frensham Commons SSSI component of the SAC.


Farnham), 5.0 kilometres north of the Thursley, Hankley & Frensham Commons SSSI

component of the SAC.

ILAS22 (Monument Way East Industrial Estate, Woking), 4.1kilometres south east of

the Chobham Common SSSI component of the SAC.

Figure 13-A: Thursley, Ash, Pirbright & Chobham SAC – Relationship to sites & ILAS proposed by the

Surrey WLP



kilometres of the SAC. The Habitat Regulations Assessments undertaken in respect of both

plans concluded that the ecological integrity of the SAC would not be adversely affected by


<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Thursley, Ash Pirbright & Chobham SAC

Site 6: Trumps FarmThursley,

Ash Pirbright & Chobham

SAC

Site 3:Slyfield IE

Site 2: WeylandsTW

Site 5: Lambs BP

ILAS01;ILAS15

ILAS07

ILAS09ILAS17

ILAS20

ILAS15

ILAS19

N

S

W E

ILAS21

20 km

30 km

40 km

Site 1: OakleafFarm

Site 4: Leatherhead

STW

ILAS08;ILAS14

ILAS02;ILAS03

ILAS04ILAS05

ILAS06;ILAS22

ILAS10

ILAS11

ILAS12; ILAS13

ILAS16

ILAS18


167


13.B.1 Reasons for Designation 13.6 The ecological interest of the SAC, and the particular habitats and species that are cited as


Site Description

The heathland is a series of large fragments of previously more continuous areas & is principally dominated by heather – dwarf gorse (Calluna vulgaris – Ulex minor) dry heathland. There are transitions to wet heath & valley mire, scrub, woodland & acid grassland, including types rich in annual plants. This habitat supports an important assemblage of animal species, including numerous rare & local invertebrate species, including the nationally rare white-faced darter Leuccorhinia dubia, as well as sand lizard Lacerta agilis & smooth snake Coronella austriaca.

This site supports the sole area of lowland northern Atlantic wet heath in south-east England. The wet heath at Thursley is mainly cross-leaved heath – bog-moss (Erica tetralix – Sphagnum compactum) & contains several rare plants, including great sundew Drosera anglica, bog hair-grass Deschampsia setacea, bog orchid Hammarbya paludosa & brown beak-sedge Rhynchospora fusca.

Depressions on peat substrates are widespread, both in bog pools, mires & in flushes where they occur as part of a mosaic associated with valley bog & wet heath. They show extensive representation of brown-beak sedge & are also important for great sundew and bog orchid Hammarbya paludosa.

Qualifying Habitats


Depressions on peat substrates of the Rhynchosporion

European dry heaths









168



Qualifying Features



H7150. Depressions on peat substrates of the Rhynchosporion


reports for the SSSIs17 (see Table 15-A for a summary) that together form the SAC, the area

covered by the SSSIs extends to some 5,241.07 hectares, of which some 70.6% is in

‘favourable’ condition, some 28.9% is in ‘unfavourable – recovering’ condition, some 0.3%

is in ‘unfavourable – no change’ condition, and some 0.1% is in ‘unfavourable – declining’

condition. The majority of the four SSSIs are composed of ‘dwarf, shrub heath –lowland’

habitat (4,955.81 hectares), with the remainder composed of a mixture of broadleaved,

mixed and yew woodland, standing open water and canals, fen, marsh and swamp, acid

grassland, and neutral grassland

Table 13-A: Thursley, Ash, Pirbright & Chobham SAC – Condition Survey Findings

Main Habitat Type





Declining

Dwarf shrub heath - lowland

4,955.81 ha

(94.56%)

3,462.87 ha

(66.07%)

1,470.10 ha

(28.05%)

15.31 ha

(0.29%)

7.53 ha

(0.14%)

Broadleaved, mixed & yew woodland –

lowland

142.23 ha

(2.21%)

122.15 ha

(2.33%)

20.08 ha

(0.38%)

0.0 ha

(0.0%)

0.0 ha

(0.0%)

Standing open water & canals

48.89 ha

(0.93%)

33.43 ha

(0.64%)

15.46 ha

(0.29%)

0.0 ha

(0.0%)

0.0 ha

(0.0%)

Fen, marsh & swamp - lowland

44.24 ha

(0.84%)

44.24 ha

(0.84%)

0.0 ha

(0.0%)

0.0 ha

(0.0%)

0.0 ha

(0.0%)

Acid grassland – lowland

27.64 ha

(0.53%)

23.57 ha

(0.45%)

4.07 ha

(0.13%)

2.05 ha

(0.04%)

0.0 ha

(0.0%)

Neutral grassland –

lowland

20.21 ha

(0.39%)

13.31 ha

(0.25%)

6.90 ha

(0.13%)

0.0 ha

(0.0%)

0.0 ha

(0.0%)

Totals 5,241.07 ha 3,699.57 ha

(70.58%) 1,516.61 ha

(28.94%) 17.36 ha (0.33%)

7.53 ha (0.14%)

17 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000009&ReportTitle=Ash%20to%20Brookwood%20Heaths%20SSSI;

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004332&ReportTitle=Chobham%20Common%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001957&ReportTitle=Colony%20Bog%20and%20Bagshot%20Heath%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004371&ReportTitle=Thursley,%20Hankley%20&%20Frensham%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000009&ReportTitle=Ash%20to%20Brookwood%20Heaths%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004332&ReportTitle=Chobham%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1001957&ReportTitle=Colony%20Bog%20and%20Bagshot%20Heath%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004371&ReportTitle=Thursley,%20Hankley%20&%20Frensham%20Commons%20SSSI


169


‘unfavourable – declining’ condition across the SPA, the condition survey reports for the

Colony Bog & Bagshot Heath SSSI (units 3 & 18) provide the following explanations and

analyses (see below).

Colony Bog & Bagshot Heath SSSI, Unit 3, 2.93 ha, Last surveyed 10/09/14

Comments: This unit has a small valley mire with a range of interesting species. The mire habitat is not being actively managed & is declining in nature conservation interest. There is some recent loss of wet heath & mire habitat due to unchecked growth of scrub, & spread of bracken. There is increasing cover (>20%) of pine (& some birch/willow) trees which are shading out both damp heath & mire communities. Due to the small & enclosed nature of this mire a target of zero scrub & bracken is appropriate. There is some rhododendron which needs removing. Bracken is present at higher levels than desirable. The cover of dwarf ericaceous shrubs is within targets but the cover of dense Molinia exceeds the recommended 50% in places & its litter is generally well above 50% cover & increasing. Common & cross-leaved heather are present as tall mature plants, bog myrtle is frequent. A number of species of Sphagnum are present in the mire & wet heath land fringes, but the shade & litter resulting from the Molinia & scrub is limiting the cover of Sphagnum (much less than target) & low-growing plants. Some of the positive indicators are still fairly frequent on the mire. Black bog rush is of greatest interest, & this remains widespread & locally frequent. Tormentil, cotton grass & bog asphodel are all occasional. There are a few small pools of open water in the mire but there is very little bare/ exposed ground – less than the 1% minimum target level. The upper end of the mire has some growth of reedmace (Typha) which is indicative of possible enrichment of water supplies to the mire & a concern for the habitat. The unit also has a very small area of dry heath which has been managed to control scrub, gorse & bracken. This area has a good cover (70%) of common heather, & small amounts of birch & bracken. Gorse is regenerating quickly. The dry heath is in favourable condition but is a lesser priority in this unit than the mire


Colony Bog & Bagshot Heath SSSI, Unit 18, 4.60 ha, Last surveyed 27/10/17

Comments: This unit is covered with mature secondary woodland with a more or less continuous canopy of silver birch, oak & chestnut with some beech & pine. The understorey & field layers include some gorse, bramble & bracken, with gorse, heather, fine grasses & honeysuckle. Previous habitat maps & aerial photos show significant areas of open heath land & dry grassland habitat within a smaller area of dry woodland. These glades & clearings of open habitat are now much reduced in size & quality, or have been lost beneath tree cover. The small parts of the site where there are tree canopy gaps do still retain some heather & tall leggy gorse, as well as fine grasses, but these are of negligible value to specialist heathland fauna, & are at risk of declining further due to the shade & leaf litter from the trees.


13.10 For the 15.31 hectares of lowland dwarf shrub heath habitat (Ash to Brookwood Heaths

SSSI unit number 12, last surveyed on 15 May 2017) classified as exhibiting ‘unfavourable –

no change’ condition, the condition survey report provides the following explanation and

analysis.

Comments: The unit is considered to be in unfavourable condition, as it provides a very limited area of rather poor quality ‘open’ habitat for heath land flora & fauna. The unit has the potential to be enhanced for heathland species, including the bird assemblage. At present there is no suitable nesting habitat for specialist heathland birds.


170

Most of the unit has stands of closed canopy Scot’s pine plantation as the dominant vegetation: much of this is fairly mature, but there is an area with younger thicket stage pine saplings (3-4m), which have grown up on the site of a former clearing (from aerial photos). There are occasional broad-leaved trees, mainly English oak, silver birch & rowan, with some holly. Parts of the woodland floor are bare/ covered with pine litter, but there are frequent patches of bilberry (some quite large), & bracken is also widespread. A stand of ling is present at the location of the pine saplings, but is now being shaded out. A wayleave passes along one of the unit boundaries, & forms an open corridor linking to adjacent parts of the SSSI/SPA where there are larger clearings of value to nesting heathland birds. The wayleave has a bare sandy track, with heathland vegetation along the verges including ling & cross-leaved heath, bilberry, purple moor-grass, gorse, & occasional fine grasses including bristle bent. The unit provides a little supporting habitat for SPA birds, with some of the woodland edge habitats suitable for foraging by nightjar. There is significant amount of recreational visitor pressure, mainly dog walkers along the wayleave.

Reasons for adverse condition: Lack of corrective works - inappropriate scrub control & inappropriate weed control

13.11 For the 2.05 hectares of lowland acid grassland habitat (Thursley, Hankley & Frensham

Commons SSSI unit number 19, last surveyed on 17 July 2008) classified as exhibiting

‘unfavourable – no change’ condition, the condition survey report provides the following

explanation and analysis.

Comments: This is a small unit in private ownership on the edge of Thursley Common, the owner is unknown. Assessment is the same as in 2002, the site is 20% bracken & the remainder species poor acid grassland dominated by ragwort. Does include birds-foot trefoil, common centaury, hard rush & marsh thistle. There are no signs of any management having been carried out, the unit does not contain any of the interest features or buffer the rest of the site.

Reasons for adverse condition: Agriculture - undergrazing


13.12 The published Site Improvement Plan for the SAC (03/11/2014) identifies the following key

pressures and threats to the site’s ecological integrity.



13.C.2;

Changes in local hydrological conditions – discussed further in section 13.C.3;


Changes due to the introduction of invasive species – discussed further in section 13.C.5;



in section 13.C.7;




171

13.C.1 Undergrazing

13.13 The features affected by deficiencies in the grazing regime are the wet heathland with

cross-leaved heath (H4010) habitat, the European dry heaths (H4030) habitat, and the

depressions on peat substrates (H7150) habitat. The SIP (pp.6/20 to 8/20) offers the


“Parts of the complex are undermanaged. Limitations are such that traditional stock cannot

be used (because they are live firing ranges), or resistance to the fencing of common land. The

excessive cost of disposal of arisings from cutting management is a significant factor making it

impractical for large scale use. Controlled burning is not considered a practical alternative in

this complex. Lack of grazing over a long period has resulted in poor habitat quality &

restoration will take a long time. Grazing may actually be having negative impacts in some

cases & improved management is required in these instances. There is scope to improve

efficiency in use of resources through improved coordination, sharing of equipment &

improved partnership working.”


concerned with:

Implementing appropriate alternative management where grazing is not practical;

Investigating possible economic uses of material arising from habitat management,


Developing a heathland management partnership which seeks to share resources,


Producing agreed management plans for key sites which identify priority actions to


Improving long-term management of power line wayleaves with power suppliers to



by the Surrey WLP would impact upon current or future grazing practices within the SAC.

The only points at which the grazing regime implemented across the SAC may interface




unlikely that any increase in grazing of the SAC would result in a significant rise in demand







172

SAC, and therefore would not affect the condition of the heathland habitats. No further


13.C.2 Forestry & Woodland Management

13.17 The features affected by changes in forestry and woodland management practices are the

wet heathland with cross-leaved heath (H4010) habitat, and the European dry heaths

(H4030) habitat. The SIP (p.8/20) offers the following explanation of the nature of the


“Large parts …are occupied by commercial forestry plantations where the maintenance of

suitable conditions … is dependent upon rotational felling. However, there is no coordination

or overall management plan & felling is dependent upon market forces. Climate change is also

causing change in thinking amongst managers with introduction of broadleaves being

considered & change from rotational to continuous cover management.”


concerned with undertaking a review of long-term forestry management policy in the

complex to ensure suitable habitat conditions for Annex 1 birds are consistently

maintained.



management practices within the SAC. The only points at which the forestry and woodland

management regime implemented across the SAC may interface with waste management



active woodland management (e.g. green waste from thinning, coppicing, etc.). The

volumes of waste arising from active woodland management on the SAC would be unlikely

to be of a scale that would require the provision of additional green waste management

capacity on unallocated land in Surrey.







13.C.3 Hydrological Changes

13.21 The features affected by changes in hydrology are the wet heathland with cross-leaved

heath (H4010) habitat, and the depressions on peat substrates (H7150) habitat. The SIP



173

“Part of Thursley, Ash Pirbright & Chobham SAC (Elstead Common) has evidence of damaging

impacts due to drainage. Drains are also present on Thursley & Ockley Commons but it is not

clear whether these are having adverse impacts - more research is needed here. This is

becoming more urgent in the face of changing weather patterns and prolonged droughts but

it is not clear at present what intervention, if any, should be put in place.”


concerned with commissioning hydrological studies of Elstead, Ockley and Thursley

Commons to determine whether drainage is having adverse impacts, and of the mires on

Ash Ranges (including Whitepatch Bog), to ascertain the effects of past drainage and

evaluate the potential for habitat restoration, and with commissioning and implementing

mire restoration plans to bring these into favourable condition.


by the Surrey WLP would impact upon the hydrology of the habitats within the SAC. None

of the sites allocated under Policy 11 or the ILAS identified under Policy 10 of the Surrey

WLP are situated within the catchments for those areas of the SAC that have been

identified as particularly susceptible to adverse impacts as a consequence of changes in

hydrology associated with the past and ongoing drainage of mires.



would not give rise to direct or indirect significant impacts on the hydrology of those parts

of the SAC that are particularly susceptible to changes in hydrology. No further assessment

is required in respect of the changes in hydrology impact pathway.

13.C.4 Inappropriate Scrub Control

13.25 The features affected by a lack of appropriate scrub control are the wet heathland with

cross-leaved heath (H4010) habitat, and the European dry heaths (H4030) habitat. The SIP


“Ineffective or lack of scrub control affects some areas of dry & wet heath, especially at Colony

Bog, & at Bourley & Long Valley. The absence of scrub management plans at most sites is of

concern as it is often viewed as a negative aspect with little consideration given for its value to

Annex 1 birds. There is also concern that scrub management is a constant, significant drain on

resources – there is a need for investigation of options which give an economic return on scrub

management.”


concerned with implementing a programme of scrub clearance to reverse effects of

encroachment of heathland to follow on from investigation of the potential for sustainable

use of the waste arising.




174

SAC. The only points at which the scrub control regime implemented across the SAC may




clearance, etc.). The volumes of waste arising from active scrub management on the SAC

would be unlikely to be of a scale that would require the provision of additional green

waste management capacity on unallocated land in Surrey.






13.C.5 Invasive Species 13.29 The features affected by the incursion of invasive plant species are the wet heathland with

cross-leaved heath (H4010) habitat, and the European dry heaths (H4030) habitat. The SIP


“Rhododendron & Gaultheria control is on-going in parts but difficult to control where access

for management is constrained. It is unclear what the scale of threat is posed by piri-pri bur to

open heathland but monitoring of its spread is desirable. Possibly more of a threat to dry

heath than wet.”


concerned with the preparation and implementation of invasive species control plans for all

sites where these remain a problem or pose a significant threat.


by the Surrey WLP could act to introduce invasive plant species into the SAC. None of the

sites allocated under Policy 11 or ILAS identified under Policy 10 of the Surrey WLP are

situated in close enough proximity to the SAC to act as a source of invasive plant species

(e.g. from green waste from domestic gardens and horticultural businesses). The only point

at which measures to control the spread of invasive plant species across the SAC may


for the removal and appropriate management of the waste materials from the eradication

of the invasive plants (e.g. green waste from clearance, etc.). The volumes of waste arising

from the active management of invasive plants on the SAC would be unlikely to be of a

scale that would require the provision of additional green waste management capacity on

unallocated land in Surrey.



would not give rise to direct or indirect significant impacts on the SAC in respect of the


175

spread or control of invasive plant species. No further assessment is required in respect of

the invasive plant species impact pathway.

13.C.6 Wildfire / Arson 13.33 The features affected by changes in the risk or incidence of wildfires or arson are the wet

heathland with cross-leaved heath (H4010) habitat, the European dry heaths (H4030)

habitat, and the depressions on peat substrates (H7150) habitat. The SIP (p.11/20 and

12/20) offers the following explanation of the nature of the identified pressure:

“Uncontrolled fires are very damaging as they can have profound impacts on reptile

populations, invertebrates & plant diversity & can result in significant habitat loss for Annex 1

birds. They can affect forestry areas as well as open heath. Damaging impacts can last for

many years for example by the wholesale removal of all gorse from a site. Strategies are in

place in parts of the complex to reduce risk but more attention is needed to properly address

this issue. Increasing threat of extensive fires is of great concern to the fire services & there is

a desire for greater link up between efforts to protect property & roads from fire, & habitat

management.”


concerned with completing and implementing fire strategies and risk management plans

for all sites, with undertaking a public fire awareness campaign, and with embedding

wildfire mitigation and adaptation into local authority Local Development Plan policies.



the SAC. It is conceivable that certain types of waste management facility could present a

fire risk to designated sites, where those facilities were located in close proximity to the

sensitive habitats. There have been incidences of significant fires at waste recycling and

storage facilities that handle household, industrial and commercial wastes, and there have

been cases of spontaneous combustion occurring at green waste composting facilities due

to inappropriate stockpiling and management of the waste materials. None of the sites

proposed for allocation or ILAS identified in the emerging Surrey WLP are in close enough

proximity to the SAC to present a genuine fire risk.




within the SAC, and although waste related development could, in theory, present a fire

risk to the SAC, the site allocations proposed are too distant to present a credible threat. No

further assessment is required in respect of the wildfire and arson impact pathway.

13.C.7 Air pollution: impact of atmospheric nitrogen deposition 13.37 The features affected by changes in the amounts of nutrient nitrogen deposited from the

atmosphere are the wet heathland with cross-leaved heath (H4010) habitat, the European

dry heaths (H4030) habitat, and the depressions on peat substrates (H7150) habitat. The


176

SIP (p.12/20) offers the following explanation of the nature of the identified

pressure/threat:



sedge dominated systems rather than Sphagnum dominated; spread of Molinia into wet & dry

heath also appears to be promoted by high nitrate levels. This is most likely to be a current

issue at Chobham Common but may represent a chronic adverse impact over the complex as a

whole.”


pressure/threat are concerned with controlling and reducing nitrogen emissions and

deposition, and with ameliorating the impacts of that deposition.







13.40 The potential for thermal treatment development at one of the sites (Site 3: Land north

east of Slyfield IE, Guildford) allocated under Policy 11a to give rise to likely significant

effects has been identified on the basis of predicted process contributions being equivalent

to 1% or more of the minimum site relevant critical load for the most sensitive habitat

within the SAC (see Part B8, Appendix B).

13.41 Eleven of the ILAS (see below) identified under Policy 10 of the Surrey WLP are located

within 10 kilometres of at least one component part of the SAC. The development of

thermal treatment facilities on land located within any one of those ten ILAS could, in

theory, present risks of nutrient nitrogen deposition on land within the SAC.



kilometres south east of the Chobham Common SSSI component of the SAC.


kilometres to the south east of the Ash to Brookwood Heaths SSSI component of the

SAC.


south east of the Ash to Brookwood Heaths SSSI component of the SAC.


Ash to Brookwood Heaths SSSI component of the SAC.


Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the Thursley, Hankley &

Frensham Commons SSSI component of the SAC.


177


of the Ash to Brookwood Heaths SSSI component of the SAC.


kilometres west of the Colony Bog & Bagshot Heath SSSI component of the SAC.

ILAS19 (Dunsfold Aerodrome, Stovolds Hill, Cranleigh), 8.7 kilometres south east of the

Thursley, Hankley & Frensham Commons SSSI component of the SAC.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 4.8 kilometres to the north

west of the Thursley, Hankley & Frensham Commons SSSI component of the SAC.


Farnham), 5.0 kilometres north of the Thursley, Hankley & Frensham Commons SSSI

component of the SAC.

ILAS22 (Monument Way East Industrial Estate, Woking), 4.1 kilometres south east of

the Chobham Common SSSI component of the SAC.


development at the closest proposed site allocation (Site 3 – Land to the north east of

Slyfield IE, Guildford) could travel along the section of the A3 that passes through the SAC

to the south west of Guildford. For that proposed site allocation, the Transport Study

undertaken for the Surrey WLP reports that development of a large scale (c. 300,000 tpa

capacity) EfW facility would result in a 6% (838 additional vehicles) increase in AADT on the

section of the A320 (Woking Road) closest to that proposed site (Waste Local Plan –

Transport Study: Site Assessments, Table 3.1, p.20). Section 3.3 (p.21) of the Transport

Study predicts that traffic generated by any waste related development on Site 3 would

disperse to the strategic road network south down the A320 to the A3. For the section of

the A3 that passes through the SAC to the south west of Guildford the reported AADT for

2017 (Department for Transport Count Point 81525, A3 – Hindhead Tunnel to A283), is

48,176 vehicles. If all traffic from the proposed site allocation were to travel along the

section of the A3 to the south west of Guildford that would equate to an additional 838

vehicles (a 1.7% change in AADT) on the section of that road that passes through the SAC,

which is close to the 1,000 AADT threshold cited in the Design Manual for Roads & Bridges

(Volume 11, Section 3, May 2007).

13.43 For Site 6 (Land at Trumps Farm, Longcross), allocated under Policy 11b of the Surrey WLP

for development as a small to medium scale dry mixed recyclables processing facility, there

is little risk of the majority of the traffic generated by the facility passing through the SAC.

The closest SAC component to Site 6 is the Chobham Common SSSI, located some 1.4

kilometres to the south west. Access to Site 6 would be achieved from the south via

Longcross Road (B386) and Kitsmead Lane which links to the A320 to the east. The HRA for

the Runnymede BC Local Plan concluded that implementation of that plan would not give

rise to significant impacts on the SAC as a consequence of traffic emissions, alone or in-

combination with other plans and projects.


178




– Woodbridge Meadows IE, Guildford; ILAS08 – Riverwey IE, Astolat BP & Weyvern Park,

Peasmarsh) are situated such that waste related development at those locations could

contribute to additional traffic on the A3. Should waste related development of any scale

proceed at one or more of ILAS05, ILAS06 or ILAS08, the traffic generated could act in-


Guildford (Site 3). A further two ILAS (ILAS20 – Coxbridge BP, Farnham; and ILAS21 –

Farnham TE, Farnham) could contribute to traffic on the A287, which dissects the western

part of the Thursley, Hankley & Frensham Commons SSSI component of the SAC.

13.45 Screening Conclusion: The implementation of the Surrey WLP could give rise to impacts in

terms of nutrient nitrogen deposition within parts of the SAC, as a consequence of

emissions from traffic sources. The potential for impacts as a consequence of point source

pollution, from the development and operation of some scale and type of thermal

treatment plant at one or more of the allocated sites situated within 10 kilometres of the

SAC cannot be ruled out at the screening stage. Further assessment is required in respect of

the air pollution (emission and deposit of nitrogen) impact pathway with reference to

emissions from thermal treatment facilities, and from waste related traffic.

13.C.8 Military Uses 13.46 The features affected by changes in the military uses made of land within the SAC are the

wet heathland with cross-leaved heath (H4010) habitat, the European dry heaths (H4030)

habitat, and the depressions on peat substrates (H7150) habitat. The SIP (p.13/20) offers

the following explanation of the nature of the identified threat:

“None of the military training areas in the complex currently have integrated management

plans which seek to integrate management of the estate for military training with nature

conservation management. There is a need for improved communication between partners

over common objectives.”



the complex.



manages those areas of land that it owns within the SAC designation. The Surrey WLP is







179


use of land within the SAC designation for military purposes. No further assessment is

required in respect of the military uses impact pathway.

13.C.9 Habitat Fragmentation 13.50 The features affected by habitat fragmentation are the wet heathland with cross-leaved

heath (H4010) habitat, the European dry heaths (H4030) habitat, and the depressions on

peat substrates (H7150) habitat. The SIP (p.14/20) offers the following explanation of the

nature of the identified pressure:

“Fragmentation of the complex means that recovery after devastating impacts such as fires &

severe winters is restricted or prevented altogether. This has implications for the ability of

species such as Dartford warbler, smooth snake, marsh clubmoss, specialist invertebrates to

recolonise parts of the complex. There is currently high risk of local extinctions in parts of the

complex because of this.”


concerned with commissioning a study to identify priorities for habitat management that is

able to ameliorate the effects of habitat fragmentation.

13.52 Screening Evaluation: None of the sites allocated under Policy 11 or ILAS identified under

Policy 10 of the Surrey WLP are in close enough proximity to the SAC to contribute directly

to the further fragmentation of the habitats of the designated site, with the closest located

some 0.4 kilometres to the west (ILAS07 – Land north and south of Lysons Avenue, Ash

Vale). Much of the land surrounding the SAC components lies within the Metropolitan

Green Belt, and it is therefore unlikely that waste related development would be brought

forward on non-allocated or unidentified land in closer proximity to the SAC than the

closest identified ILAS and closest site allocation, as strategic waste management facilities

would typically be classed as inappropriate development in a Green Belt context.








deposition of nitrogen) by which development at one of the sites allocated under Policy 11a

of the Surrey WLP (Site 3 – Land NE of Slyfield IE, Guildford) and eleven of the ILAS

identified under Policy 10 could give rise to significant effects on the SAC. The mechanisms

by which the development of the proposed sites and ILAS could contribute to the deposit of


180

nutrient nitrogen would be emissions from thermal treatment plants and from waste

related traffic.


13.55 In total twelve areas of land allocated or otherwise identified under policies in the Surrey

WLP are located within 10 kilometres of the Thursley, Ash, Pirbright & Chobham SAC.

Modelling of the potential effects of a range of scales of thermal treatment plants has been

carried out for the allocated site (see Part B8, Appendix B, and Appendix C). For the ILAS,

for which detailed modelling has not been carried out, judgements (see Part B8, Appendix

B) have been made on the basis of the findings of the modelling undertaken for the

allocated sites (and sites previously proposed for allocation at the Regulation 18 stage of

the Surrey WLP). The ILAS were not considered to be suitable candidates for the siting of

large scale (>50,000 tpa) thermal treatment facilities, and the assessment therefore only

considered the impacts of small scale (<50,000 tpa) facilities at those locations. Details of

the site relevant critical loads for all the features covered by the SAC designation can be

found in Part B8 of Appendix B to this report.

13.56 For Site 3 (Land NE Slyfield IE, Guildford) the modelling (see Part B8, Appendix B) indicated

that the emissions arising under each of the four scenarios considered would account for

more than 1% of the minimum site relevant critical loads across each of the SAC habitats.

The estimated background deposition rates for nutrient nitrogen within the area of the SAC

closest to Site 3 exceed the minimum site relevant critical loads across all three SAC habitat

types (see Part B8, Appendix B). The PEC (background plus process contribution) would

increase by between 1.4% to 5.1% for call the SAC habitat types.

13.57 For the eleven ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SAC it was concluded that the majority could be suited to the

development of small-scale thermal treatment facilities (<50,000 tpa). In one case the

conclusion was that the ILAS would be unsuited to the development of any scale of thermal

treatment facility.

13.57.1 ILAS07 (Lysons Avenue, Ash Vale) was found to be unsuitable as a location for

small scale thermal treatment facilities, due to its geographical proximity and

relationship to a component of the SAC (within 1.0 kilometre of a constituent

SSSI).

13.57.2 For ILAS01 (Brooklands IE et al, Byfleet), ILAS05 (Slyfield IE, Guildford), ILAS06

(Woodbridge Meadows IE, Guildford), ILAS08 (Riverwey IE et al, Peasmarsh),

ILAS09 (Burntcommon Warehouse, Send), ILAS17 (York Town IE, Camberley),

ILAS19 (Dunsfold Aerodrome, Cranleigh), ILAS20 (Coxbridge BP, Farnham),

ILAS21 (Farnham TE, Farnham), and ILAS22 (Monument Way East IE, Woking) it

may be feasible for a small scale (<50,000 tpa) thermal treatment facilities to

be accommodated in one or more of those locations subject to it being

demonstrated at the planning application stage that the ecological integrity of

the SAC would not be adversely affected.


181

13.58 The scope for the development of thermal treatment facilities on land at any of the ILAS

(excepting ILAS07) would also be dependent on the type and scale of waste related

development that proceeds on the site allocated under Policy 11a (Site 3) of the Surrey

WLP that lies within 10 kilometres of the SAC. If that allocated site were to be brought

forward for some scale and type of thermal treatment facility the need to manage the

possibility of in-combination effects would reduce the suitability of those ILAS also located

within 10 kilometres of the same SAC components as potential locations for thermal

treatment facilities. Implementation of Policy 14 of the Surrey WLP, which requires that all

waste related planning application be supported by sufficient information for the WPA to



development does not compromise the ecological integrity of the SAC.

13.D.2 Vehicle emissions

13.59 The worst case scenario for the development of the closest site allocation (Site 3 – Land NE

of Slyfield IE, Guildford) to the SAC is for a c.300,000 tpa capacity EfW plant, generating an

additional 838 vehicles per day, which for the purposes of screening it has been assumed

would all travel to and from the facility on the section of the A3 that passes through the

SAC. In combination with the development of Site 3, it is assumed that smaller scale (50,000

tpa) waste management facilities would be constructed at three ILAS (ILAS05; ILAS06 and

ILAS08) in or close to Guildford that could generate an additional 120 two-way vehicle

movements per day (40 movements per facility), with all that additional traffic travelling

along the section of the A3 that passes through the SAC. Separately, the two ILAS in

Farnham (ILAS20 and ILAS21) could generate additional traffic on the section of the A287

that passes through part of the SAC.

13.60 In practice, development of Site 3 would not involve the construction and operation of a

large scale EfW facility with a c.300,000 tpa capacity. Site 3 lies within a priority area for

redevelopment identified in the emerging Guildford BC Local Plan. Under the Slyfield Area

Regeneration Programme, Site 3 would accommodate a replacement sewage treatment

works for Guildford, the current site of which would then be redeveloped as housing, and a

replacement CRC and WTS, the current site of which would then be redeveloped for

industrial and commercial use. The Surrey WLP site allocation would also encompass an

area of land safeguarded as the potential route of a new link road that would connect the

Slyfield area to Clay Lane to the north. There would be limited space left on Site 3 to

accommodate any additional waste management capacity.

13.61 The use of Site 3 to accommodate facilities that would replace existing waste development

currently situated in the Slyfield area, displaced by housing, industrial and commercial

development as part of the Slyfield Area Regeneration Programme, would not substantially

alter the volumes of operational traffic generated by those facilities. Consequently there

would be no discernible change in the contribution that waste related development


182

situated on the Slyfield Industrial estate makes to traffic volumes on the section of the A3

that passes through the SAC as a consequence of the development of Site 3.

13.62 In practice it is unlikely that new waste management facilities would be developed on all

three of the ILAS (ILAS05, ILAS06 and ILAS08) located in or close to Guildford that could

contribute to additional traffic on the A3, or that traffic from any facilities built would travel

exclusively on the section of the A3 that passes through the SAC. For the two ILAS in

Farnham that could contribute to traffic on the A287, both are accessed from the A31, and

it is therefore more likely that the majority of traffic to and from those locations, in the

event of either or both being developed for waste uses, would travel on the A31 in the first

instance.

13.63 The published Habitat Regulations Assessment reports (AECOM, 2016, 2017 and 2018) for

the Waverley BC Local Plan concluded that implementation of the policies and proposals

set out in Parts 1 and 2 of that Plan would not give rise to significant effects on the

ecological integrity of the SAC, alone or in-combination. The HRA for the Guilford BC Local

Plan concluded that implementation of that plan would not give rise to significant impacts

on the SAC as a consequence of traffic emissions.

13.E Conclusions


ecological integrity of the Thursley, Ash, Pirbright & Chobham SAC has concluded that

overall there would be no potential for ‘likely significant effects’ to arise, subject to the



13.64.1 One of the ILAS (ILAS07) identified under Policy 10 of the Surrey WLP is located

in sufficiently close proximity to a component of the SAC to render it

unsuitable as a location for all scales of thermal treatment plants.






pass through the four SSSIs that together form the SAC.






183



Level



13.C.1



WLP

Screening


woodland management


in section 13.C.2



WLP

Screening



in section 13.C.3



WLP

Screening



in section 13.C.4



WLP

Screening

Changes due to the


species – discussed further in

section 13.C.5



WLP

Screening






WLP

Screening





13.C.7 & section 13.7

One allocated site (Site 3) and eleven ILAS (ILAS01,


ILAS19, ILAS20, ILAS21, ILAS22) located within 10

km of the SAC. Potential for adverse impacts from



emissions.


at ILAS07.



assessment.











Assessment

of Likely

Significant

Effects

(Process

Emissions &

Traffic

Emissions)


184


Level




13.C.8



WLP Screening






WLP Screening

13.66 The further information provided in parts E (paragraphs 11-15, pp.12-13) and H-4

(paragraphs 33-38, pp.20-22) of the appendix to the Statement of Common Ground

between Natural England and Surrey County Council, dated 8 August 2019, does not alter

the conclusions reached by the HRA process in respect of the likely impacts of the Surrey

WLP on the Thursley, Ash, Pirbright & Chobham SAC. That further information provides

detailed descriptions of the physical relationship between one proposed allocated site (Site

6 – Trumps Farm, Longcross) and one proposed ILAS (ILAS07 – Land north & south of Lysons

Avenue, Ash Vale) and component parts of the SAC. Those descriptions serve to reinforce

the conclusions reached through the HRA process, that waste development at the allocated

site or the ILAS would not result in significant impacts on the ecological integrity of the SAC.

13.F References


process for the Thursley, Ash, Pirbright & Chobham SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Thursley, Ash,

Pirbright & Chobham SAC (Natural England (English Nature), May 2005).



& designated SACs) – Thursley, Ash, Pirbright & Chobham SAC (Joint Nature


13.67.3 European Site Conservation Objectives for Thursley, Ash, Pirbright & Chobham

Special Area of Conservation (Site Code: UK0030080) (Natural England, 30 June

2014, v.2).

13.67.4 Site Improvement Plan: Thursley, Ash, Pirbright & Chobham SAC (Natural

England, 24 November 2014).





185

13.67.6 Condition Survey Report for the Ash to Brookwood Heaths SSSI (Natural


13.67.7 Condition Survey Report for the Chobham Common SSSI (Natural England,


13.67.8 Condition Survey Report for the Colony Bog & Bagshot Heath SSSI (Natural


13.67.9 Condition Survey Report for the Thursley, Hankley & Frensham Commons SSSI




June 2018





13.67.14 Habitats Regulations Assessment for Guildford Borough Proposed Submission

Local Plan: Strategy & Sites, 2017 Update, AECOM for Guildford Borough

Council, April 2017.



2007.






186

Chapter 14 Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA & Thursley & Ockley Bog Ramsar Site


14.A.1 Location of the SPA & Ramsar Site 14.1 The Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA (see map) is

located in Surrey, and is composed of a single SSSI, the Thursley, Hankley & Frensham

Commons SSSI. The SPA covers an area of 1,879.93 hectares, as stated on the SPA standard

data form, and was designated in February 1994.

14.2 Part of the area, some 256.2 hectares, covered by both the SSSI and SPA designations is

also designated as a Ramsar Site (see map), under the 1971 Ramsar Convention on

wetlands of international importance. That area is known as the Thursley & Ockley Bogs

Ramsar Site, and was designated under Ramsar criterion 2 for the community of rare

wetland invertebrate species including notable numbers of breeding dragonflies, and under

Ramsar criterion 3 for the presence of all six reptile species native to the UK, and for the

nationally important breeding populations of European nightjar and woodlark. The SPA and

the Ramsar Site are both situated within an area administered by Waverley BC and by

Surrey County Council.

14.3 The Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA is dissected by

a number of road links, including the following ‘A’ class roads.

143.1 The A3 (Portsmouth Road) – which passes through the SPA.

14.3.2 The A287 (Farnham Road) – which passes through the SPA.

14.3.3 The A286 (Haslemere Road) – which passes through the SPA.

14.3.4 A3100 (Portsmouth Road) – which passes through the SPA.

14.4 The Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA is situated

across a number of different surface water catchments, all of which lie wholly or partly

within the county of Surrey.

14.4.1 The Royal Brook (GB106039017760).

14.4.2 The Truxford Brook (GB106039017770).

14.4.3 The Wey (Tilford to Shalford) (GB106039017820).

14.4.4 The South Wey (River Slea confluence to Tilford) (GB106039017780).

14.4.5 The Ock (GB106039017790).




187

14.A.2 Minerals & waste development plan proposals in Surrey relevant to the SPA &

Ramsar Site

14.5 The Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA is not located

within 10 kilometres of any of the sites proposed for allocation under Policy 11 of the

Surrey WLP (see Figure 14-A – a full size version can be found in Appendix A). The closest

proposed allocation is ‘Site 3 – Land to the north east of Slyfield Industrial Estate, Moorfield

Road, Guildford’, which lies some 12.3 kilometres to the north east of the SPA. The SPA is

located within 10 kilometres a number of ILAS (see below) identified under Policy 10 of the

Surrey WLP (see Figure 14-A). The Plan does not specify the type or scale of waste related

development that could be accommodated on the identified ILAS.

ILAS06 (Woodbridge Meadows Industrial Estate, Guildford), 9.7 kilometres to the north

east of the SPA.

ILAS07 (Land north & south of Lysons Avenue, Ash Vale), 9.7 kilometres to the north of

the SPA.


Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the SPA.

ILAS19 (Land at Dunsfold Aerodrome, Stovolds Hill, Cranleigh) 8.7 kilometres to the

south east of the SPA.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 4.8 kilometres to the north west

of the SPA.


Farnham), 4.8 kilometres to the north of the SPA.

14.6 Alton Road quarry at Farnham, which is allocated for development as a temporary



Permission WA/2014/0005), is located some 4.1 kilometres to the north west of the SPA.

The Alton Road quarry is accessed from the north via a dedicated track that links to the

A31. The Habitat Regulations Assessments undertaken in respect of the Aggregates

Recycling Joint DPD concluded that the ecological integrity of the SPA would not be

adversely affected by the plan’s implementation.


Plan are situated within 5 kilometres of the SPA. The Habitat Regulations Assessments

undertaken in respect of both of those plans concluded that the ecological integrity of the

SPA would not be adversely affected by their implementation.


188

Figure 14-A: Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA –

Relationship to sites & ILAS proposed by the Surrey WLP




Site Description

Thursley, Hankley & Frensham Commons together incorporate a heath & valley mire complex. Broadleaved & coniferous woodland covers large parts of the site with scattered scrub & trees present over much of the heath, & several areas of permanent grassland. Areas of open water ranging from acidic boggy pool & ditches to large ponds also contribute significantly to the overall diversity of the site.

Thursley, Hankley & Frensham Commons qualify under Article 4.1 of the EC Birds Directive as a site of international importance by regularly supporting in the summer the following populations of birds listed under Annex I:

About 20 pairs of nightjars Caprimulgus europeaus, (1% of the British breeding population);

Up to 27 pairs of woodlark Lullula arborea, (12% of the British breeding population); and,

In excess of 20 pairs of Dartford warblers Sylvia undata, (4% of the British breeding population in 1984).0

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA

THFC (Wealden

Heaths Phase 1)

SPA

ILAS21

ILAS20

ILAS19

ILAS08

ILAS06

ILAS07

ILAS17

N

S

W E

20 km

30 km

40 km

50 km

Site 6: Trumps Farm

Site 5: Lambs BP

Site 1:Oakleaf Farm

Site 2: Weylands TW

Site 3: Slyfield IE


ILAS18


ILAS17 ILAS01;ILAS15

ILAS10

ILAS14

ILAS16




189

The numbers of these species fluctuate considerably from year to year; the figures given above relate to peak numbers recorded over the last 10-15 years. This site makes a substantial contribution to the maintenance of the traditional breeding ranges of these species within Britain, where habitat has become greatly fragmented & degraded in recent decades, & in the EC.

Notable also are regular breeding kingfishers Alcedo atthis, & wintering hen harriers Circus cyaneus, species also listed under Annex I of the EC Birds Directive.


14.9 The published conservation objectives for the SPA are given below


“With regard to the individual species &/or assemblage of species for which the site has been

classified (“the Qualifying Features” listed below): Avoid the deterioration of the habitats of the

qualifying features, & the significant disturbance of the qualifying features, ensuring the integrity of

the site is maintained & the site makes a full contribution to achieving the aims of the Birds

Directive. Subject to natural change, to maintain or restore:

The extent & distribution of the habitats of the qualifying features;

The structure & function of the habitats of the qualifying features;

The supporting processes on which the habitats of the qualifying features rely;

The populations of the qualifying features;


Qualifying Features




14.B.3 Condition


reports for the SSSI18 that is coincident with the SPA designation, the designated site

extends to some 1,876.41 hectares, of which some 81.8 % is in ‘favourable’ condition, some

18.1% is in ‘unfavourable – recovering’ condition, and some 0.1% is in ‘unfavourable – no

change’ condition. The majority of the SSSI is composed of five main habitat types, ‘dwarf

shrub heath–lowland’ (1,656.88 hectares), ‘broadleaved, mixed & yew woodland – lowland’

(136.36 hectares), ‘standing open water & canals’ (48.64 hectares), ‘acid grassland –

lowland’ (29.69 hectares), and ‘neutral grassland – lowland’ (6.90 hectares).

18 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004371&ReportTitle=Thursley,%20Hankley%20&%20Frensham%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004371&ReportTitle=Thursley,%20Hankley%20&%20Frensham%20Commons%20SSSI


190

Table 14-A: Thursley, Hankley & Frensham Commons SSSI – Condition Survey Findings

Main Habitat Type



Recovering Unfavourable – No

Change


Lowland

136.36 ha (7.3%)

116.28 ha (6.2%)

20.08 ha (1.1%)

0.00 ha (0%)

Dwarf Shrub Heath – Lowland

1,656.88 ha (88.3%)

1,362.91 ha (72.6%)

293.97 ha (15.7%)

0.00 ha (0%)

Acid Grassland – Lowland

29.69 ha (1.6%)

23.57 ha (1.3%)

4.07 ha (0.2%)

2.05 ha (0.1%)

Neutral Grassland - Lowland

6.90 ha (0.4%)

0.00 ha (0%)

6.90 ha (0.4%)

0.00 ha (0%)

Standing Open Water & Canals

48.64 ha (2.6%)

33.43 ha (1.8%)

15.21 ha (0.8%)

0.00 ha (0%)

Totals 1,876.41 ha 1,536.18 ha (81.8%)

340.22 ha (18.1%)

2.05 ha (0.1%)

14.11 For the 2.05 hectares of acid grassland habitat (SSSI unit number 19, last surveyed on 17

July 2008) classified as exhibiting ‘unfavourable – no change’ condition, the condition

survey report provides the following explanation and analysis.

Comments: This is a small unit in private ownership on the edge of Thursley Common, the owner is unknown. Assessment is the same as in 2002, the site is 20% bracken & the remainder species poor acid grassland dominated by ragwort. Does include birds-foot trefoil, common centaury, hard rush & marsh thistle. There are no signs of any management having been carried out, the unit does not contain any of the interest features or buffer the rest of the site.

Reasons for adverse condition: Agriculture - Undergrazing


14.12 The published Site Improvement Plan (SIP) for the SPA (3 November 2014) identifies the



14.C.1;





in section 14.C.5;


191

Changes in the condition, location and extent of the features of qualifying interest –





14.13 The features affected by changes in the incidence of public access and associated

disturbance are the populations of the European nightjar A224(B), the Woodlark A246(B),

and the Dartford Warbler A302(B). The SIP (p.5/20) offers the following explanation of the

nature of the identified pressure/threat.

“Parts of … Thursley, Hankley & Frensham Commons SPA…are subject to high levels of recreational use & dog walkers make up a large proportion of visitors. This is likely to be affecting the distribution & overall numbers of ground-nesting Annex 1 birds (& breeding success). An 'avoidance strategy' is in place to help manage this pressure, including the provision of Suitable Accessible Natural Green Space (SANGS). However, recreational pressure may be hampering the potential for the sites to achieve their full contribution to sustainable national populations. Further work is desirable to determine the scale of impact from recreational disturbance. There is also concern at the growing use of parts of the complex by commercial dog walkers & desire to control this. Improved habitat management to increase suitability for Annex 1 birds & better coordination of habitat provision across the complex is also needed to better offset the effects of disturbance.”

14.14 The actions that have been identified as the principal means of addressing the pressure/

threat are concerned with the production of an over-arching habitat management strategy

to help offset/decrease the effects of recreational disturbance on the Annex 1 birds, with

the production of coherent and consistent access management strategy for the designated

site, and with implementing a wardening strategy to reduce the impacts of recreational

disturbance on the Annex 1 birds.





county of Surrey. The closest site allocated (Site 3 – land north east of Slyfield IE, Guildford)

under Policy 11 of the Surrey WLP is located some 12.3 kilometres to the north east of the

SPA, and is too distant to be a source of visitor pressure for the SPA. The closest ILAS

(ILAS20 – Coxbridge BP, Farnham) identified under Policy 10 of the Surrey WLP is located

some 4.8 kilometres to the north west, and is too distant to be a source of visitor pressure

for the SPA. The SPA and the land surrounding it lies within the Metropolitan Green Belt,

and it is therefore unlikely that waste related development would be brought forward on

non-allocated land in closer proximity to the SPA than the closest proposed site allocation

or ILAS, as strategic waste management facilities would typically be classed as

inappropriate development in a Green Belt context. Operational waste facilities would not

typically be a source of prospective visitors to the SPA, compared with, for example, new



192




any significant impacts arising from public access to, and disturbance of, the designated site

and species. No further assessment is required in respect of the public access / disturbance

impact pathway.

14.C.2 Undergrazing

14.17 The features affected by undergrazing of the SPA habitats are populations of the European

nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). The SIP


“Parts of the complex are undermanaged. Limitations are such that traditional stock cannot be used (because they are live firing ranges), or resistance to the fencing of common land. The excessive cost of disposal of arisings from cutting management is a significant factor making it impractical for large scale use. Controlled burning is not considered a practical alternative in this complex. Lack of grazing over a long period has resulted in poor habitat quality & restoration will take a long time. Grazing may actually be having negative impacts in some cases & improved management is required in these instances. There is scope to improve efficiency in use of resources through improved coordination, sharing of equipment & improved partnership working.”


concerned with:

Implementation of appropriate alternative management where grazing is not practical;

Investigation of possible economic uses of material arising from habitat management


Development of a heathland management partnership which seeks to share resources,


Production of agreed management plans for key sites which identify priority actions to


Improve long-term management of power line wayleaves with power suppliers to



by the Surrey WLP would impact upon current or future grazing practices of the habitats

situated within the SPA.

14.20 The only points at which the grazing regime implemented across the SPA may interface




unlikely that any increase in grazing of the SPA would result in a significant rise in demand


193






SPA, and therefore would not affect the condition of the heathland habitats. No further


14.C.3 Inappropriate scrub control

14.22 The features affected by a lack of appropriate scrub control measures are the populations

of the European nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler

A302(B). The SIP (p.10/20) offers the following explanation of the nature of the identified

pressure:

“Ineffective or lack of scrub control affects some areas of dry and wet heath, …. The absence of scrub management plans … is of concern as it is often viewed as a negative aspect with little consideration given for its value to Annex 1 birds. There is also concern that scrub management is a constant, significant drain on resources - there is a need for investigation of options which give an economic return on scrub management.”


concerned with implementing a programme of scrub clearance to reverse the effects of the

encroachment of the heathland, following on from investigation of the options for use of

the material arising from clearance.


by the Surrey WLP would impact upon current or future scrub control practices of the

habitats situated within the SPA.

14.25 The only points at which the scrub control regime implemented across the SPA may




clearance, etc.). The SPA and the land surrounding it lies within the Metropolitan Green

Belt, and it is therefore unlikely that waste related development would be brought forward

on non-allocated land in closer proximity to the SPA than the closest proposed site

allocation, as strategic waste management facilities would typically be classed as

inappropriate development in a Green Belt context.




the SPA, and therefore would not affect the condition of the heathland habitats. No further



194

14.C.4 Wildfire / arson

14.27 The features affected by wildfire or fire arising from arson are the populations of the

European nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). The

SIP (p.11/20 to 12/20) offers the following explanation of the nature of the identified

threat:

“Uncontrolled fires are very damaging as they can have profound impacts on reptile populations, invertebrates & plant diversity & can result in significant habitat loss for Annex 1 birds. They can affect forestry areas as well as open heath. Damaging impacts can last for many years for example by the wholesale removal of all gorse from a site. Strategies are in place in parts of the complex to reduce risk but more attention is needed to properly address this issue. Increasing threat of extensive fires is of great concern to the fire services & there is a desire for greater link up between efforts to protect property & roads from fire, & habitat management.“


concerned with completing and agreeing the implementation of a fire strategy and risk

management plan for the SPA in order to reduce fire risk, with undertaking public fire

awareness campaigns, and with embedding wildfire mitigation and adaptation into local

authority Local Development Plan policies.



the SPA.







allocated under Policy 11 of Surrey WLP are in close enough proximity to the SPA to present

a genuine fire risk, the closest being some 12.3 kilometres to the north east (Site 3 – land

north east of Slyfield IE, Guildford). None of the ILAS identified under Policy 10 of the

Surrey WLP are in close enough proximity to present a genuine fire risk, the closest being

some 4.8 kilometres to the north west (ILAS20 – Coxbridge BP, Farnham). The land

surrounding the SPA lies within the Metropolitan Green Belt. It is therefore unlikely that

waste related development would be brought forward on non-allocated land in closer

proximity to the SPA than the closest proposed site allocation or identified ILAS, as strategic

waste management facilities would typically be classed as inappropriate development in a

Green Belt context.





195


to the SPA, the site allocations proposed are too distant to present a credible threat and

the Green Belt status of the land surrounding the SPA limits the probability of waste

development being brought forward in close proximity to the sensitive habitats. No further

assessment is required in respect of the wildfire and arson impact pathway.


14.32 The features affected by changes in nutrient nitrogen deposition from the atmosphere are

the habitats of the populations of the European nightjar A224(B), the Woodlark A246(B),

and the Dartford Warbler A302(B). The SIP (p.12/20) offers the following explanation of the

nature of the identified pressure/threat:

“Nitrogen deposition exceeds the site-relevant critical load for ecosystem protection. The aerial pollution may be promoting changes in species composition of mires towards Molinia & sedge dominated systems rather than Sphagnum dominated; spread of Molinia into wet & dry heath also appears to be promoted by high nitrate levels. This…may represent a chronic adverse impact over the complex as a whole.”






on the SPA. Of particular concern are waste management facilities that make use of





there is no risk of development at any of the six sites allocated under Policy 11 of the Surrey

WLP giving rise to nutrient nitrogen deposition within the SPA at concentrations that would

exceed 1% of the site relevant minimum critical loads for the habitats of the SPA bird

species. The closest site allocation (Site 3 – Land NE of Slyfield IE, Guildford) is 12.3

kilometres to the north east of the SPA, beyond the distance (10 kilometres) for which

detailed assessment would be required by the Environment Agency as part of the

Environmental Permit consenting process. Any contribution that emissions from a thermal

treatment facility at Site 3 would make to nitrogen deposition on the SPA would be

undetectable.

14.36 Six of the ILAS (see below) identified under Policy 10 of the Surrey WLP are located within

10 kilometres of the SPA. The development of thermal treatment facilities on land located

within any one of those six ILAS could, in theory, present risks of nutrient nitrogen

deposition on land within the SPA.


196

ILAS06 (Woodbridge Meadows Industrial Estate, Guildford), 9.7 kilometres north east

of the SPA.

ILAS07 (Land north & south of Lysons Avenue, Ash Vale), 9.7 kilometres north of the

SPA


Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the SPA.

ILAS19 (Dunsfold Aerodrome, Stovolds Hill, Cranleigh), 8.7 kilometres south east of the

SPA.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 4.8 kilometres north west of

the SPA.


Farnham), 5.0 kilometres north of the SPA.


development at the closest proposed site allocation (Site 3 – Land NE of Slyfield IE,

Guildford) could travel along the section of the A3 that passes through the SPA to the south

west of Guildford. For Site 3 the Transport Study undertaken for the Surrey WLP reports

that development of a large scale (c. 300,000 tpa capacity) EfW facility would result in a 6%

(838 additional vehicles) increase in AADT on the section of the A320 (Woking Road) closest

to the site (Waste Local Plan – Transport Study: Site Assessments, Table 3.1, p.20). Section

3.3 (p.21) of the Transport Study predicts that traffic generated by any waste related

development at Site 3 would disperse to the strategic road network south down the A320

to the A3. For the section of the A3 that passes through the SPA to the south west of

Guildford the reported AADT for 2017 (Department for Transport Count Point 81525, A3 –

Hindhead Tunnel to A283), is 48,176 vehicles. If all traffic from Site 3 were to travel along

the section of the A3 to the south west of Guildford that would equate to an additional 838

vehicles (a 1.7% change in AADT) on the section of that road that passes through the SPA,

which is close to the 1,000 AADT threshold cited in the Design Manual for Roads & Bridges

(Volume 11, Section 3, May 2007).




– Woodbridge Meadows IE, Guildford; ILAS08 – Riverwey IE, Astolat BP & Weyvern Park,

Peasmarsh) are situated such that waste related development at those locations could

contribute to additional traffic on the A3. Should waste related development of any scale

proceed at one or more of ILAS05, ILAS06 or ILAS08, the traffic generated could act in-


Guildford (Site 3). A further two ILAS (ILAS20 – Coxbridge BP, Farnham; and ILAS21 –

Farnham TE, Farnham) could contribute to traffic on the A287, which dissects the western

part of the SPA.


197

14.39 Screening Conclusion: The implementation of the Surrey WLP could give rise to impacts in

terms of nutrient nitrogen deposition within parts of the SPA, as a consequence of

emissions from traffic sources. The potential for impacts as a consequence of point source

pollution, from the development and operation of some scale and type of thermal

treatment plant at one or more of the allocated sites situated within 10 kilometres of the

SPA cannot be ruled out at the screening stage. Further assessment is required in respect of

the air pollution (emission and deposit of nitrogen) impact pathway with reference to

emissions from thermal treatment facilities, and from waste related traffic.

14.C.6 Monitoring of feature condition, location & extent

14.40 The features affected by gaps in knowledge and understanding of the way in which the SPA

species use the site and the surrounding area are the populations of the European nightjar

A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). The SIP (p.13/20) offers

the following explanation of the nature of the identified threat:

“There are significant gaps in the knowledge of key aspects such as where woodlarks are overwintering & whether these sites are in need of protection, & coverage of the complex in terms of monitoring of Annex 1 birds is not comprehensive so recorded bird numbers are not representative of total numbers. Also, current monitoring does not provide information on breeding success, only territory numbers.”


concerned with establishing a long-term bird monitoring strategy that covers of all parts of

the SPA, and commissioning research to determine critical factors in the breeding success

of woodlark in this complex, particularly focussing on possible effects of climate change and

changing weather patterns


either negatively or positively, on the availability of information about the ways in which

the SPA bird species make use of the designated site and other suitable habitats in the

surrounding area. The Surrey WLP is concerned with the provision of additional waste

management capacity over the 15 year plan period, to meet identified current and future

gaps in capacity, and would present limited opportunities for the collection of ecological

data associated with the proposed development of specific sites. None of the sites

allocated under Policy 11 or the ILAS identified under Policy 10 of the Surrey WLP are

located in, or in close proximity to, the SPA.




monitoring and ongoing evaluation of the behaviours of the SPA bird species. No further

assessment is required in respect of the feature of interest monitoring impact pathway.


198

14.C.7 Military activities / uses

14.44 The features affected by changes in the military use of the designated site are the

populations of the European nightjar A224(B), the Woodlark A246(B), and the Dartford

Warbler A302(B). The SIP (p.13/20) offers the following explanation of the nature of the

identified threat:

“None of the military training areas in the complex currently have integrated management plans which seek to integrate management of the estate for military training with nature conservation management. There is a need for improved communication between partners over common objectives.”



the complex.






influence the land use or land management practices employed by the military on MoD

land.





required in respect of the military activities and uses impact pathway.

14.C.8 Habitat fragmentation

14.48 The features affected by habitat fragmentation are the populations of the European

nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). The SIP


“Fragmentation of the complex means that recovery after devastating impacts such as fires & severe winters is restricted or prevented altogether. This has implications for the ability of species such as Dartford warbler, smooth snake, marsh clubmoss, specialist invertebrates to recolonise parts of the complex. There is currently high risk of local extinctions in parts of the complex because of this.”


concerned with commissioning a study to identify priorities for habitat management which

reduce the adverse impacts of habitat fragmentation


199

14.50 Screening Evaluation: None of the sites allocated under Policy 11 or ILAS identified under

Policy 10 of the Surrey WLP are in close enough proximity to the SPA to contribute directly

to the further fragmentation of the habitats of the designated site. The closest allocated

site (Site 3 – land north east of Slyfield IE, Guildford) is some 12.3 kilometres to the north

east, and the closest ILAS (ILAS20 – Coxbridge BP, Farnham) is 4.8 kilometres to the north

west. The land surrounding the SPA lies within the Metropolitan Green Belt, and it is

therefore unlikely that waste related development would be brought forward on non-

allocated land in closer proximity to the SPA than the closest site allocation or identified

ILAS, as strategic waste management facilities would typically be classed as inappropriate

development in a Green Belt context.



would not give rise to direct or indirect significant impacts on the SPA with reference to





14.52 In total six areas of land identified under Policy 10 of the Surrey WLP are located within 10

kilometres of the SPA. For the ILAS, for which detailed modelling has not been carried out,

judgements (see Part B9, Appendix B) have been made on the basis of the findings of the

modelling undertaken for the allocated sites (and sites previously proposed for allocation at

the Regulation 18 stage of the Surrey WLP). The ILAS were not considered to be suitable

candidates for the siting of large scale (>50,000 tpa) thermal treatment facilities, and the

assessment therefore only considered the impacts of small scale (<50,000 tpa) facilities at

those locations. Details of the site relevant critical loads for all the features covered by the

SPA designation can be found in Part B9 of Appendix B to this report.

14.53 Emissions for a small scale thermal treatment facility at the six ILAS are estimated to

account for between 1.12% and 2.52% of the site relevant critical loads for the most

sensitive habitats (coniferous woodland) of the SPA bird species (see Part B9, Appendix B).

The estimated background deposition rate for nutrient nitrogen within woodland in those

areas of the SPA closest to the ILAS range from 20.86 kg/N/ha/yr to 22.82 kg/N/ha/yr

(which exceeds the minimum critical loads for coniferous woodland), and the estimated

emissions for small-scale facilities would account for between 0.25% and 0.55% of the

estimated background deposition. The predicted environmental concentration (PEC)

(background plus process contribution) for coniferous woodland ranges from 20.92

kg/N/ha/yr to 22.95 kg/N/ha/yr, and would account for between 418% and 459% of the site

relevant minimum critical loads, with the development of thermal treatment plant at each

ILAS accounting for between 0.25% and 0.55% of the PEC.


200

14.54 For the six ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SPA it was concluded that all could be suited to the development of small-

scale thermal treatment facilities (<50,000 tpa), subject to it being demonstrated at the

planning application stage that the ecological integrity of the SPA would not be adversely

affected. Implementation of Policy 14 of the Surrey WLP, which requires that all waste

related planning application be supported by sufficient information for the WPA to



development does not compromise the ecological integrity of the SPA.

14.D.2 Vehicle emissions

14.55 The worst case scenario for the development of the closest site allocation (Site 3 – Land NE

of Slyfield IE, Guildford) to the SPA is for a c.300,000 tpa capacity EfW plant, generating an

additional 838 vehicles per day, which for the purposes of screening it has been assumed

would all travel to and from the facility on the section of the A3 that passes through the

SPA. In combination with the development of Site 3, it is assumed that smaller scale (50,000

tpa) waste management facilities would be constructed at three ILAS (ILAS05; ILAS06 and

ILAS08) in or close to Guildford that could generate an additional 120 two-way vehicle

movements per day (40 movements per facility), with all that additional traffic travelling

along the section of the A3 that passes through the SPA. Separately, the two ILAS in

Farnham (ILAS20 and ILAS21) could generate additional traffic on the section of the A287

that passes through part of the SPA.

14.56 In practice, development of Site 3 would not involve the construction and operation of a

large scale EfW facility with a c.300,000 tpa capacity. Site 3 lies within a priority area for

redevelopment identified in the emerging Guildford BC Local Plan. Under the Slyfield Area

Regeneration Programme, Site 3 would accommodate a replacement sewage treatment

works for Guildford, the current site of which would then be redeveloped as housing, and a

replacement CRC and WTS, the current site of which would then be redeveloped for

industrial and commercial use. The Surrey WLP site allocation would also encompass an

area of land safeguarded as the potential route of a new link road that would connect the

Slyfield area to Clay Lane to the north. There would be limited space left on Site 3 to

accommodate any additional waste management capacity.

14.57 The use of Site 3 to accommodate facilities that would replace existing waste development

currently situated in the Slyfield area, displaced by housing, industrial and commercial

development as part of the Slyfield Area Regeneration Programme, would not substantially

alter the volumes of operational traffic generated by those facilities. Consequently there

would be no discernible change in the contribution that waste related development

situated on the Slyfield Industrial estate makes to traffic volumes on the section of the A3

that passes through the SPA as a consequence of the development of Site 3.


201

14.58 In practice it is unlikely that new waste management facilities would be developed on all

three of the ILAS (ILAS05, ILAS06 and ILAS08) located in or close to Guildford that could

contribute to additional traffic on the A3, or that traffic from any facilities built would travel

exclusively on the section of the A3 that passes through the SPA. For the two ILAS in

Farnham that could contribute to traffic on the A287, both are accessed from the A31, and

it is therefore more likely that the majority of traffic to and from those locations, in the

event of either or both being developed for waste uses, would travel on the A31 in the first

instance.

14.59 The published Habitat Regulations Assessment reports (AECOM, 2016, 2017 and 2018) for

the Waverley BC Local Plan concluded that implementation of the policies and proposals

set out in Parts 1 and 2 of that Plan would not give rise to significant effects on the

ecological integrity of the SPA, alone or in-combination. The HRA for the Guilford BC Local

Plan concluded that implementation of that plan would not give rise to significant impacts

on the SPA as a consequence of traffic emissions.

14.E Thursley & Ockley Bog Ramsar Site

14.60 The Thursley & Ockley Bog Ramsar Site (see map) covers an area of some 256.2 hectares,

covered by both the Thursley, Hankley & Frensham Commons SSSI and the Thursley,

Hankley & Frensham Commons (Wealden Heaths Phase 1). The Ramsar Site was designated

under Ramsar criterion 2 for the community of rare wetland invertebrate species including

notable numbers of breeding dragonflies, and under Ramsar criterion 3 for the presence of

all six reptile species native to the UK, and for the nationally important breeding

populations of European nightjar and woodlark.

14.61 The Ramsar Site designation covers only 256.2 hectares of the SSSI, with that area made up

of the following six SSSI units.

Units in ‘Favourable’ Condition



Unit 37 3.47 ha Lowland broadleaved mixed and yew woodland habitat


Units in ‘Unfavourable – recovering’ Condition



14.62 The implementation of the policies set out, and development of the sites and areas of

search identified, in the Surrey WLP is not expected to give rise to significant adverse

impacts on the ecological integrity of the Thursley, Hankley & Frensham Common (Wealden

Heaths Phase 1) SPA, or of the Thursley, Ash, Pirbright & Chobham SAC (see Chapter 13).



202

Only one of the areas of land identified in the Surrey WLP (ILAS08 – Riverwey IE et al,

Peasmarsh) lies within 10 kilometres of the Thursley & Ockley Bogs Ramsar Site, and that is

some 8.3 kilometres to the north east. Given the conclusions reached in respect of the SPA

and SAC designations that are coincident with the Ramsar Site designation, and taking

account of the distance that separates the latter from the closest area of land identified in

the Surrey WLP, it is concluded that the ecological integrity of the Ramsar Site would be

unaffected by the implementation of the Plan.

14.F Conclusions


ecological integrity of the Thursley, Hankley & Frensham Commons (Wealden Heaths Phase

1) SPA has concluded that overall there would be no potential for ‘likely significant effects’

to arise.

14.63.1 None of the ILAS identified under Policy 10 of the Surrey WLP are located in

sufficiently close proximity to the SPA to render them unsuitable as potential

locations for small scale thermal treatment plants in isolation.






pass through the SPA.

14.64 The assessment considered the eight impact pathways identified as key threats and






Level


public access / disturbance–


14.C.1



WLP

Screening



14.C.2



WLP

Screening



in section 14.C.3



WLP

Screening


203


Level






WLP

Screening






Six ILAS (ILAS06, ILAS07, ILAS08, ILAS19, ILAS20,

ILAS21) located within 10 km of the SPA. Potential

for adverse impacts from nutrient nitrogen



For all ILAS thermal treatment may be feasible,

subject to project level assessment.


additional deposition within the SPA – likely to









Assessment

of Likely

Significant

Effects

(Process

Emissions &

Traffic

Emissions)


location & extent of the



14.C.6



WLP

Screening




14.C.7



WLP Screening






WLP Screening

14.G References


process for the Thursley, Hankley & Frensham Common (Wealden Heaths Phase 1) SPA.

14.65.1 EC Directive 79/409 [92/43] on the Conservation of Wild Birds: Citation for

Special Protection Area (SAC) – Wealden Heaths Phase 1 (Thursley, Hankley &

Frensham Commons) (Natural England (English Nature), January 1996).


Birds Directive (includes proposed SPAs, Sites of Community Importance &


204

designated SPAs) – Thursley, Hankley & Frensham Commons (Wealden Heaths

Phase 1) (Joint Nature Conservation Committee (JNCC), 25 January 2016).

14.65.3 European Site Conservation Objectives for Thursley, Hankley & Frensham

Commons (Wealden Heaths Phase 1) Special Protection Area (Site Code:

UK9012131) (Natural England, 30 June 2014, v.2).

14.65.4 Site Improvement Plan: Thames Basin Heaths SPA, Thursley, Ash, Pirbright &

Chobham SAC, & Thursley, Hankley & Frensham Commons (Wealden Heaths

Phase 1) SPA (Natural England, 3 November 2014).



14.65.6 Thursley, Hankley & Frensham Commons SSSI Condition Survey Report




June 2018







2007.




205

Chapter 15 Wealden Heaths Phase 2 SPA


15.A.1 Location of the SPA

15.1 The Wealden Heaths Phase 2 SPA (see map) is located in Surrey, Hampshire and West

Sussex, and is composed of four SSSIs. The SPA citation states that the designation covers

an area of 2,053.83 hectares, and was designated on 16 March 1998. The SPA extends

across the areas administered by the following local authorities, Surrey CC and Waverley

BC, Hampshire CC and East Hampshire DC, Chichester DC and West Sussex CC, and the

South Downs NPA.

Bramshott & Ludshott Commons SSSI, located in Hampshire and covering some 374.44

hectares. The SSSI adjoins the Surrey/Hampshire county boundary along 150 metres of

the SSSI boundary.

Broxhead & Kingsley Commons SSSI, located in Hampshire and covering some 105.13

hectares. The SSSI lies some 1.1 kilometres to the south west of the Surrey/Hampshire

county boundary.

Devil’s Punch Bowl SSSI, located in Surrey and covering some 282.22 hectares.

Woolmer Forest SSSI, located in Hampshire and West Sussex and covering some

1,298.52 hectares. The SSSI lies some 3.7 kilometres to the south west of the

Surrey/West Sussex county boundary.

15.2 The SPA is dissected by a number of road links, including the following ‘A’ class roads.

15.2.1 The A3 (Portsmouth Road / London Road) – which passes through the

Woolmer Forest SSSI, and within 200 metres of the Bramshott & Ludshottt

Commons SSSI, and of the Devil’s Punch Bowl SSSI.

15.2.2 The A325 (Petersfield Road / Farnham Road) – which passes through the

Woolmer Forest SSSI, and through the Broxhead & Kingsley Common SSSI.

15.3 The SPA is situated across a number of different surface water catchments, a number of

which lie wholly or partly within the county of Surrey.

15.3.1 The South Wey (Bordon to River Slea confluence) (GB106039017720).

15.3.2 The South Wey (Haslemere to Bordon) (GB106039017700).

15.3.3 The Slea (Kingsley to Sleaford) (GB106039017750).

15.3.4 The Truxford Brook (GB106039017770).

15.3.5 The Hollywater & Deadwater at Bordon (GB106039017690).



206

15.A.2 Minerals & waste development plan proposals in Surrey relevant to the SPA

15.4 The Wealden Heaths Phase 2 SPA is not located within 10 kilometres of any of the sites

proposed for allocation under Policy 11 of the Surrey WLP (see Figure 15-A – a full size

version can be found in Appendix A). The closest proposed allocation is Site 3 (Land to the

north east of Slyfield Industrial Estate, Moorfield Road, Guildford), which lies some 17.6

kilometres to the north east of the closest component of the SPA (the Devil’s Punch Bowl

SSSI). Two component parts of the SPA (the Devil’s Punch Bowl SSSI and the Broxhead &

Kingsley Commons SSSI) are located within 10 kilometres a number of ILAS (see below)

identified under Policy 10 of the Surrey Waste Local Plan (see Figure 15-A). The Plan does

not specify the type or scale of waste related development that could be accommodated on

the identified ILAS. Full details of the relationship of the individual SSSIs that together form

the SPA to all the sites allocated under Policy 11 and all the ILAS identified under Policy 10

of the Surrey WLP can be found in Appendix A (Tables A-1 to A-5) to this report.

ILAS20 (Coxbridge Business Park, Alton Road, Farnham), 7.3 kilometres to the north east

of the Broxhead & Kingsley Commons SSSI.


Farnham), 9.7 kilometres to the north west of the Devil’s Punch Bowl SSSI.

Figure 15-A: Wealden Heaths Phase 2 SPA – Relationship to sites & ILAS proposed by the Surrey

WLP

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Wealden Heaths Phase 2 SPA

Wealden Heaths Phase 2

SPA

N

S

W E

ILAS21

20 km

30 km

40 km

50 km

Site 6:Trumps Farm

Site 1:Oakleaf Farm

Site 2: Weylands TWSite 4: Leatherhead STW

Site 3:Slyfield IE

Site 5:Lambs BP

ILAS20

ILAS19

ILAS01; ILAS09; ILAS10; ILAS22



ILAS07

ILAS11

ILAS12; ILAS13

ILAS14; ILAS16

ILAS15ILAS17

ILAS18


207



kilometres of the SPA. The Habitat Regulations Assessments undertaken in respect of both

plans concluded that the ecological integrity of the SPA would not be adversely affected by



15.B.1 Reasons for Designation 15.6 A description of the ecological interest of the SPA, and the particular habitats and species

that are given as reasons for its designation, is described as follows in the published

citation.

Qualifying Features

Wealden Heaths Phase 2 SPA is of European importance because it is used regularly by at least 1% of the GB population of threes species listed in Annex 1 of the Birds Directive (79/409/EEC):

Dartford warbler Sylvia undata – 16 pairs (1.7% GB) 5 year peak mean for 1989-1993;

Nightjar Caprimulgus europeaus – 43 pairs (1.4% GB) 5 year peak mean for 1989-1993;

Woodlark Lullula arborea – 15 pairs (4.3% GB) 5 year peak mean for 1989-1993.

15.B.2 Conservation Objectives 15.7 The published conservation objectives for the SPA are given below.


Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring;

The extent and distribution of the habitats of the qualifying features

The structure and function of the habitats of the qualifying features


The population of each of the qualifying features, and,


Qualifying Features





208


reports for the four SSSIs19 (see Table 15-A for a summary) that together comprise the SPA,

the designated site extends to some 2,060.31 hectares, of which some 41.6 % is in

‘favourable’ condition, and some 58.4% is in ‘unfavourable – recovering’ condition. The SAC

is composed of four main habitat types, ‘dwarf shrub heath - lowland’ (1,568.57 hectares),

‘coniferous woodland’ (313.23 hectares), ‘broadleaved, mixed & yew woodland’ (175.70

hectares) and ‘standing open water & canals’ (2.80 hectares).

Table 15-A: Wealden Heaths Phase 2 SPA – Condition Survey Findings

Main Habitat Type



Recovering


175.70 ha

(8.5%)

137.97 ha

(6.7%)

37.73 ha

(1.8%)

Dwarf shrub heath – lowland 1,568.57 ha

(76.1%)

540.99 ha

(26.3%)

1,027.58 ha

(49.9%)


(15.2%)

176.25 ha

(8.6%)

136.98 ha

(6.6%)


(0.1%)

2.80 ha

(0.1%)

0 ha

(0.0%)

Totals 2,060.31 ha 858.01 ha

(41.6%)

1,202.29 ha

(58.4%)


15.9 The published Site Improvement Plan (SIP) for the SPA (23 October 2014) identifies the


Changes in land management – discussed further in section 15.C.1;

Changes in the condition, location or extent of the qualifying features – discussed

further in section 15.C.2;


15.C.3;


Changes in the incidence of wildfire / arson – discussed further in section 15.C.5.

19 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003749&ReportTitle=Bramshott%20and%20Ludshott%20Commons%20SSSI;

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1002611&ReportTitle=Broxhead%20and%20Kingsley%20Commons%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000109&ReportTitle=Devil's%20Punch%20Bowl%20SSSI; https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004188&ReportTitle=Woolmer%20Forest%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1003749&ReportTitle=Bramshott%20and%20Ludshott%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1002611&ReportTitle=Broxhead%20and%20Kingsley%20Commons%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1000109&ReportTitle=Devil's%20Punch%20Bowl%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004188&ReportTitle=Woolmer%20Forest%20SSSI


209


15.10 The features affected by changes in land management practices are the populations of the


SIP (p.4/15 to 5/15) offers the following explanation of the nature of the identified threat:

“Parts of the complex have suffered from management neglect in the past & there are

ongoing management issues. Common issues are lack of structural diversity, bracken

encroachment & scrub development. Grazing is not practical in parts of the complex but viable

alternative means of management to meet objectives are not yet in place. Grazing may also

be constrained in parts because of resistance to fencing of common land.”


concerned with:

Implementing habitat management which delivers effective heather management,

scrub control and bracken control.

Establishing site-based partnerships to improve communication over management

priorities and to advise and agree on annual work programmes.

Making changes to existing Higher Level Stewardship agreements in order to fit with

impending changes in use of military training areas.

Investigating possible biomass to bioenergy use of material produced as a result of

annual vegetation cutting and clearance.



the SPA. The only points at which the land management regime implemented across the

SPA may interface with waste management operations and practices would be in respect of



scrub clearance, disposal of fallen stock, etc.). The provision of additional waste

management capacity within the county of Surrey would be unlikely to be provided in close

enough proximity to the majority of the SPA to be of significant benefit to the ongoing

management of its habitats.




on the SPA. No further assessment is required in respect of the changes in land



210

15.C.2 Monitoring of feature condition, location & extent

15.14 The features affected by a lack of monitoring and evidence are the populations of the


SIP (pp.6/15 and 7/15) offers the following explanation of the nature of the identified

threat and pressure:

“There is only partial coverage of the SPA for monitoring of Annex 1 birds & those areas are

reliant on volunteer recorders; there is a need for a more strategic, long-term approach to

monitoring.”

“Work is needed by Natural England to clarify the conservation objectives for designated

features at Woolmer Forest, to improve the evidence base on the interest features, to identify

where these occur, & to provide greater linkage between objectives & military training use.”

15.15 The actions that have been identified as the principal means of addressing the threat and

the pressure are concerned with:

Establishing a structured long-term monitoring strategy for Annex 1 birds across the

complex, similar to Thames Basin Heaths SPA model;

Developing and implementing a coordinated access strategy for the complex which

provides a basis for effective management of recreational use;

In respect of Woolmer Forest, commissioning a study to identify core areas utilised by

Annex 1 birds for breeding and feeding, and to identify priorities for habitat

enhancement.

In respect of Woolmer Forest, providing clear advice on nature conservation objectives

and habitat management priorities.


either negatively or positively, on monitoring practices or on the availability of information

about the ways in which the SPA bird species make use of the designated site and other

suitable habitats in the surrounding area. The Surrey WLP is concerned with the provision

of additional waste management capacity over the 15 year plan period, to meet identified

current and future gaps in capacity, and would present limited opportunities for the

collection of ecological data associated with the proposed development of specific sites.

None of the sites allocated under Policy 11 or the ILAS identified under Policy 10 of the

Surrey WLP are located in, or in close proximity to, the SPA.




monitoring and ongoing evaluation of the behaviours of the SPA bird species. No further

assessment is required in respect of the monitoring of the feature of interest impact

pathway.


211


15.18 The features affected by changes in the frequency or extent of visitor access to the SPA are

the populations of the European nightjar A224(B), the Woodlark A246(B), and the Dartford

Warbler A302(B). The SIP (p.7/15) offers the following explanation of the nature of the

identified threat:

“Visitor access provision is not currently coordinated between sites or managed so as to

reduce impacts on ground-nesting birds.”


concerned with the development and implementation of a coordinated access strategy for

the complex which provides a basis for effective management of recreational use





county of Surrey. The closest ILAS (ILAS20 – Coxbridge BP, Farnham) identified as

potentially suitable for waste related development under Policy 10 of the Surrey WLP is

located some 7.3 kilometres to the north east of the SPA and is an established business and

commercial site. Operational waste facilities would not typically be a source of prospective

visitors to the SPA, compared with, for example, new residential development.






pathway.

15.C.4 Military activities / uses

15.22 The features affected by changes in the nature and extent of military activities on the SPA

are the populations of the European nightjar A224(B), the Woodlark A246(B), and the

Dartford Warbler A302(B). The SIP (p.8/15) offers the following explanation of the nature of

the identified pressure:

“There is currently poor coordination between management for military training purposes &

nature conservation management at Woolmer Forest & scope for significant gains with closer

working between partners. The production of an integrated management plan is needed.”


concerned with completing integrated management plans for all military training areas.


212






influence the land use or land management practices employed by the military on MoD

land.





required in respect of the military activities and uses impact pathway.

15.C.5 Wildfire / arson

15.26 The features affected by changes in the incidence or wildfire or arson are the populations

of the European nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler

A302(B). The SIP (p.8/15 to 9/15) offers the following explanation of the nature of the

identified threat:

“Wildfire is a natural hazard identified in the National Risk Assessment / Register &

Community Risk Registers. Wildfires in the south of England are likely to increase as identified

in the Climate Change Risk Assessment (CCRA). Wildfires can be a serious risk to human life,

residential & commercial property & critical national infrastructures, as well as being a high

risk threat to reptile populations, invertebrates & plant diversity resulting in significant habitat

loss for Annex 1 birds. Open heath is the predominant risk (dry & wet heath, peat habitats) as

well as young coniferous woodland. Impacts can last for many years for example by the

wholesale removal of all gorse & heather seedbank.“


concerned with completing wildfire risk assessments for all sites and preparing and

implementing wildfire management plans, and with embedding wildfire mitigation and

adaptation into local authority Local Development Plan policies and community risk

registers.



the SPA.








213

proposed for allocation or ILAS identified as potentially suitable for waste related

development in the Surrey WLP are in close enough proximity to the SPA to present a

genuine fire risk, and the land surrounding the component of the SPA that is situated in

Surrey (the Devil’s Punch Bowl SSSI) lies within the Metropolitan Green Belt. It is therefore

unlikely that waste related development would be brought forward on non-allocated or

unidentified land in closer proximity to the SPA than the closest identified ILAS (7.3

kilometres to the north east), as strategic waste management facilities would typically be

classed as inappropriate development in a Green Belt context.





to the SPA, the site allocations proposed and ILAS identified are too distant to present a

credible threat and the Green Belt status of the land surrounding the SPA limits the

probability of waste development being brought forward in close proximity to the sensitive

habitats of the SPA bird species. No further assessment is required in respect of the wildfire

and arson impact pathway.

15.D Conclusions


ecological integrity of the Wealden Heaths Phase 2 SPA has concluded that overall there


under Policy 11 are located within 10 kilometres of the SPA, but two of the ILAS (ILAS20 –

Coxbridge BP, Farnham; and ILAS21 – Farnham TE, Farnham) identified under Policy 10 of

the Surrey WLP are 7.3 kilometres to the north east and 9.7 kilometres to the north west.

The deposit of nutrient nitrogen is not identified in the published SIP as a threat or pressure

for the SPA, and therefore the question of the Surrey WLP influence on air quality through

process emissions or traffic emissions did not form part of the assessment.







Level





WLP

Screening


214


Level


location or extent of the

qualifying features –


15.C.2



WLP

Screening




15.C.3



WLP

Screening




15.C.4



WLP

Screening






WLP

Screening

15.E References


process for the Wealden Heaths Phase 2 SPA.

15.33.1 EC Directive 79/409/EC on the Conservation of Wild Birds: Citation for Special

Protection Area (SPA) – Wealden Heaths Phase 2 SPA (Natural England (English

Nature), March 1998).


Wild Birds Directive – Wealden Heaths Phase 2 SPA (Joint Nature Conservation


15.33.3 European Site Conservation Objectives for Wealden Heaths Phase 2 Special

Protection Area (Site Code: UK9012132) (Natural England, 30 June 2014, v.2).

15.33.4 Site Improvement Plan: Wealden Heaths Phase 2 SPA & Woolmer Forest SAC

(Natural England, 23 October 2014).

15.33.5 Bramshott & Ludshott Commons SSSI Condition Survey Report (Natural


15.33.6 Broxhead & Kingsley Commons SSSI Condition Survey Report (Natural England,


15.33.7 Devils Punch Bowl SSSI Condition Survey Report (Natural England, Designated



215

15.33.8 Woolmer Forest SSSI Condition Survey Report (Natural England, Designated





216

Chapter 16 Wimbledon Common SAC


16.A.1 Composition & Location 16.1 The Wimbledon Common SAC (see map) is located in Greater London and is composed of a

single SSSI, the Wimbledon Common SSSI (351.38 hectares). The Wimbledon Common SAC

covers an area of 348.31 hectares, as stated on the SAC citation, and was designated on 1

April 2005. The SAC is situated within an area administered by Merton Council and the

Greater London Authority.

16.2 The following ‘A’ class roads pass within 200 metres of the SAC.

16.2.1 The A3 (Roehampton Vale) – which passes within 200 metres of the northern


16.2.2 The A219 (Parkside) – which passes within 200 metres of the eastern boundary

of the SAC.

16.2.3 The A3 (Robin Hood Way) – which passes within 200 metres of the western


16.3 The SAC is situated within a single surface water catchment, which lies partly within the

county of Surrey, but is not fed by any upstream catchments situated in Surrey. The

catchment of the Beverley Brook (Motspur Park to Thames) & Pyl Brook at West Barnes

(GB106039022850).

16.A.2 Minerals & waste development plan proposals in Surrey within 10 kilometres of the SAC

16.4 The Wimbledon Common SAC is located within 10 kilometres of the following sites

proposed for allocation under Policy 11, and the following ILAS identified under Policy 10 of

the Surrey WLP (see Figure 16-A – a full size version can be found in Appendix A). The Plan

does not specify the type or scale of waste related development that could be



Thames), 9.9 kilometres to the south west of the SAC. The site is also allocated for

waste related development under policy WD2 of the adopted Surrey Waste Plan

(2008), and is in existing waste use.


the south west of the SAC.

ILAS04 (Longmead Industrial Estate, Longmead Road, Epsom), 8.6 kilometres to the

south of the SAC. The ILAS already accommodates an established community recycling

centre and waste transfer station.



217

Figure 16-A: Wimbledon Common SAC – Relationship to sites & ILAS proposed by the Surrey WLP


Plan, or sites proposed for development in the Aggregates Recycling Joint DPD are situated

within 5 kilometres of the SAC. The HRAs undertaken in respect of both of those plans

concluded that the ecological integrity of the SAC would not be adversely affected by their

implementation.


16.B.1 Reasons for Designation 16.6 A description of the ecological interest of the SAC, and the particular habitats and species

that are cited as reasons for its designation, are given below.

Site Description

Wimbledon Common supports an extensive area of open, wet heath on acidic soil & also contains a variety of other acidic heath & grassland communities. The high plateau in the east & north of the site has a capping of glacial gravels overlying Claygate Beds & London Clay, which are exposed on the western slope of the Common. The acidic soils & poor drainage give rise to a mosaic of wet heath & unimproved acidic grassland. Semi-natural broadleaved woodland covers the deeper, clay soils of the western slope.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Wimbledon Common SAC

Wimbledon Common

SAC

N

S

W E

Site 2: Weylands TW

ILAS04

ILAS03

20 km

30 km

40 km

50 km

Site 1: Oakleaf

Farm

Site 3: Slyfield IE

Site 4: Leatherhead

STW

Site 5: Lambs BP

Site 6: Trumps Farm

ILAS01;ILAS15

ILAS02ILAS05;ILAS09;ILAS22


ILAS10

ILAS11

ILAS12;ILAS13

ILAS16;ILAS14

ILAS17

ILAS18ILAS19

ILAS20;ILAS21


218

A significant cover of heather Calluna vulgaris distinguishes areas of dry & wet heath. The wet heath supports typical species such as the heath rush Juncus squarrosus. The brown sedge Carex disticha is present, as is mat-grass Nardus stricta on drier parts. Localised areas of dry heath support bell heather Erica cinerea & dwarf gorse Ulex minor.

The semi-natural woods of the clay soils comprise a dense canopy of maturing pedunculate oak Quercus robur & silver birch Betula pendula, with beech Fagus sylvatica, hornbeam Carpinus betulus & aspen Populus tremula in parts. Holly Ilex aquifolium is the dominant understorey species. Hazel Corylus avellana & alder buckthorn Frangula alnus, also occur. Where sufficient light penetrates there is a herb layer of bracken Pteridium aquilinum & bramble Rubus fruticosus agg. Wimbledon Common has a large number of old trees & much fallen decaying timber. The site supports a number of other scarce invertebrate species associated with decaying timber, including stag beetle Lucanus cervus.

Qualifying Habitats


European dry heaths


Qualifying Species


Stag beetle Lucanus cervus










Qualifying Features



S1083. Lucanus cervus; Stag beetle


219


report for the Wimbledon Common SSSI20 (see Table 16-A), the designated site extends to

some 351.38 hectares, of which some 94.99% is in ‘unfavourable – recovering’ condition,

and some 5.01% is in ‘unfavourable – no change’ condition. The SSSI is composed of three

main habitat types, ‘dwarf shrub heath –lowland’ (81.85 hectares), ‘broadleaved, mixed

and yew woodland – lowland’ (140.23 hectares), and ‘acid grassland – lowland’ (129.31

hectares).

Table 16-A: Wimbledon Common SSSI – Condition Survey Findings

Main Habitat Type



Unfavourable – No Change

Dwarf shrub heath – lowland 81.85 ha

(23.29%)

64.23 ha

(18.28%)

17.62 ha

(5.01%)


140.23 ha

(39.91%)

140.23 ha

(39.91%)

0.0 ha

(0.0%)

Acid grassland – lowland 129.31 ha

(36.80%)

129.31 ha

(36.80%)

0.0 ha

(0.0%)

Totals 351.38 ha 333.77 ha

(94.99%)

17.62 ha

(5.01%)

16.9 For the 17.62 hectares of lowland dwarf shrub heath habitat (SSSI unit number 9, last

surveyed on 12/09/2013) classified as exhibiting ‘unfavourable – no change’ condition, the


Commentary: This unit contains areas of grassland at the edge of a golf course and areas of heathland in the rough & at the edges of the fairways. Signs of gorse control where visible when visited & the rough areas did not seem to be suffering from significant over management/ high footfall. However the unit fails on frequency of gramanoids & the proportion of dwarf shrubs in building/ mature & pioneer stage. The majority of the heather is at pioneer stage suggesting that it has been cut at the same time – however there is a small proportion of heather at the mature degenerate stage & little encroachment by scrub suggesting that more sympathetic management is taking place.

Reasons for adverse condition: Agriculture - inappropriate cutting/mowing


16.10 The published Site Improvement Plan (SIP) for the SAC (24 November 2014) identifies the


20 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004317&ReportTitle=Wimbledon%20Common%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004317&ReportTitle=Wimbledon%20Common%20SSSI


220


16.C.1;

Changes due to habitat fragmentation – discussed further in section 16.C.2;



in section 16.C.4.

16.C.1 Public access / disturbance 16.11 The features affected by changes in public access and the incidence of disturbance are the

wet heathland with cross-leaved heath (H4010) habitat, the European dry heaths (H4030)

habitat, and the Stag beetle (S1083) population. The SIP (p.3/9) offers the following

explanation of the nature of the identified pressure:

“High visitor use of the site causes damage to sensitive habitats, and results in adverse

impacts such as compaction around the base of mature trees and removal of fallen timber.”


concerned with reviewing the management plan to ensure that visitor pressure is

addressed, and with implementing measures to reduce impacts arising from public access

and use of the site.





county of Surrey. The closest site (Site 2 – Weylands TW, Walton on Thames) allocated

under Policy 11 of the Surrey WLP is located some 9.9 kilometres to the south west of the

SAC. The closest ILAS (ILAS04 – Longmead IE, Epsom) identified under Policy 10 of the

Surrey WLP is located some 8.5 kilometres to the south of the SAC. Operational waste

facilities would not typically be a source of prospective visitors to the SAC, compared with,

for example, new residential development.






pathway.

16.C.2 Habitat fragmentation 16.15 The feature affected by habitat fragmentation is the Stag beetle (S1083) population. The

SIP (p.3/9) offers the following explanation of the nature of the identified threat:


221

“The Stag beetle remains vulnerable to extinction in the UK as a result of habitat loss &

fragmentation of populations. Much work has been carried out to improve understanding of

the distribution & habitat requirements of the species. Effective conservation is dependent

upon protection not only of core sites such as Wimbledon Common, but public awareness of

the value of gardens & retention of dead wood. Continuation of work by the Peoples Trust for

Endangered Species is likely to play an important role.”


concerned with the continued implementation of the established Peoples Trust for

Endangered Species project.


by the Surrey WLP would impact, either negatively or positively, on the connectivity of

habitats suited to the requirements of stag beetles within the SAC or the surrounding area.

The Surrey WLP is concerned with the provision of additional waste management capacity

on land situated within the county of Surrey over a 15 year period, to meet projected

growth in waste arisings. The Surrey WLP would exert no influence over the siting of

development outside the boundaries of the county of Surrey. As the SAC is not located

within the county of Surrey, its habitats and those of the surrounding area would be

unaffected by development brought forward under the Surrey WLP.






16.C.3 Invasive species 16.19 The features affected are the wet heathland with cross-leaved heath (H4010) habitat, the

European dry heaths (H4030) habitat, and the Stag beetle (S1083) population The SIP

(p.4/9) offers the following explanation of the nature of the identified threat:

“Oak processionary moth is now well-established at Richmond Park & other sites in the

London area; this species represents a serious threat to human health. Control is potentially

damaging to invertebrate populations & is expensive which may result in reduced nature

conservation management.”


concerned with developing an invasive species protocol, particularly for Oak processionary

moth, and within implementing invasive species monitoring and control programmes.



waste management facilities within the county of Surrey. The Plan could support ongoing

efforts to manage the Oak processionary moth infestation of the SAC, by enabling the

provision of waste management facilities that are equipped to safely dispose of material


222

affected by Oak processionary moth infestation. The implementation of the Surrey WLP

would involve development on land situated within the county of Surrey, which at its point

of closest proximity is some 4.6 kilometres distant from the SAC, and therefore be unlikely

to present further infestation risks to the SAC habitats.



would not give rise to significant adverse impacts on the SAC with reference to the

management of the Oak processionary moth. No further assessment is required in respect

of the invasive species impact pathway.


the wet heathland with cross-leaved heath (H4010) habitat, and the European dry heaths

(H4030) habitat. The SIP (pp.4/9 to 5/9) offers the following explanation of the nature of

the identified threat:

“Nitrogen deposition exceeds site relevant critical loads. Wimbledon Common is subject to

high levels of atmospheric nitrogen oxide and ammonia deposition which is likely to be having

deleterious effects on sensitive habitats, particularly the heath and mire vegetation.”


concerned with reducing atmospheric nitrogen impact through the preparation and

implementation of a Site Nitrogen Action Plan.







16.26 The potential for thermal treatment development at one of the sites allocated under Policy

11a (Site 2: Weylands TW, Walton on Thames) to give rise to likely significant effects has

been identified on the basis of predicted process contributions being equivalent to 1% of

more of the minimum site relevant critical load for the most sensitive habitat within the

SAC (see Part B10, Appendix B).

16.27 Two of the ILAS (see below) identified under Policy 10 are located within 10 kilometres of

the SAC. The development of thermal treatment facilities on land located within either of

those two ILAS could, in theory, present risks of nutrient nitrogen deposition on land within

the SAC.

ILAS03 – Molesey Industrial Estate, West Molesey.

ILAS04 – Longmead Industrial Estate, Epsom.


223

16.28 In terms of the potential for diffuse emissions, the Transport Study for the Surrey WLP does

not anticipate that vehicles from the allocated site that is situated within 10 kilometres of

the SAC would travel along any of the ‘A’ or ‘B’ class roads that pass through the SAC. The

HRA report (2016) for the Merton Borough Council Estates Plan (part of the Local Plan)

concluded that its implementation would have no significant impacts on the SAC, as a

consequence of air pollution.



strategic road networks. Neither of the ILAS that are located within 10 kilometres of the


SAC.


or indirect significant impacts on nutrient nitrogen deposition within the SAC as a


development). The potential for significant impacts on the SAC as a consequence of point

source emissions of nutrient nitrogen, from the development and operation of some scale

and type of thermal treatment plant situated within 10 kilometres of the SAC cannot be

ruled out at the screening stage. Further assessment is required in respect of the air

pollution (emission and deposit of nitrogen) impact pathway in respect of point source

emissions from allocated sites and identified ILAS.



deposition of nitrogen) by which development of one of the sites(Site 2 – Weylands TW)

allocated under Policy 11a and two of the ILAS (ILAS03; ILAS04) identified under Policy 10 of

the Surrey WLP could give rise to likely significant effects on the SAC. The mechanism by

which the development of the proposed site could contribute to the deposit of nutrient

nitrogen would be emissions from thermal treatment plants.

16.32 In total three areas of land allocated or otherwise identified under policies in the Surrey

WLP are located within 10 kilometres of the Wimbledon Common SAC. Modelling of the

potential effects of a range of scales of thermal treatment plants has been carried out for

the allocated site (see Part B10, Appendix B, and Appendix C). For the ILAS, for which








224

loads for all the features covered by the SAC designation can be found in Part B10 of


16.33 For Site 2 (Weylands TW, Walton on Thames) the modelling (see Part B10, Appendix B)

indicated that the emissions arising under three of the four scenarios considered would

account for more than 1% of the minimum site relevant critical loads across both habitat

types covered by the SAC designation. For the fourth scenario (construction of a <50,000

tpa gasification facility) the modelled process contributions accounted for 0.7% of the

minimum site relevant critical loads for both the SAC habitats. The estimated background

deposition rates for nutrient nitrogen within the area of the SAC closest to Site 2 exceed the

minimum site relevant critical loads for both the habitat types covered by the SAC

designation (see Part B10, Appendix B). The PEC (background plus process contribution)

would increase by between 0.5% to 2.2% for both the wet and dry heathland habitats.

16.34 For the two ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SAC it was concluded that each (ILAS03: Molesey IE, West Molesey;

ILAS04: Longmead IE, Epsom) could accommodate a small sale (<50,000 tpa) thermal

treatment facility without giving rise to nitrogen deposition within the SAC equivalent to

more than 1% of the minimum site relevant critical loads for both habitat classes, subject to

it being demonstrated at the planning application stage that the ecological integrity of the

SAC would not be adversely affected. The scope for the development of a thermal

treatment facility on land at ILAS03 or ILAS04 would also be dependent on the type and

scale of waste related development that proceeds on the site allocated (Site 2) under Policy

11a of the Surrey WLP that lies within 10 kilometres of the SAC. If the allocated site were

brought forward for some scale and type of thermal treatment facility the need to manage

the possibility of in-combination effects arising would reduce the suitability of ILAS03 and

ILAS04 as potential locations for thermal treatment facilities. Implementation of Policy 14

of the Surrey WLP, which requires that all waste related planning application be supported

by sufficient information for the WPA to ascertain whether the proposed development

would result in significant adverse impacts on the natural environment, including SPAs and

SACs, will ensure that permitted development does not compromise the ecological integrity

of the SAC.

16.E Conclusions


ecological integrity of the Wimbledon Common SAC has concluded that overall there would

be no potential for ‘likely significant effects’ to arise.

16.35.1 One of the sites allocated under Policy 11a (Site 2: Weylands TW, Walton on

Thames) and two of the ILAS (ILAS03; ILAS04) identified under Policy 10 of the


operation of a large scale (>50,000 tpa) thermal treatment facility is not


225

recommended for the allocated site, subject to the outcome of detailed

modelling and assessment at the planning application stage..



allocated site and identified ILAS to the road network and potential sources of


management facilities would travel along roads pass through or within 200

metres of the SAC.







Level




16.C.1



WLP

Screening






WLP

Screening

Changes due to the


species– discussed further in

section 16.C.3



WLP

Screening





16.C.4

One allocated site (Site 2) and two ILAS (ILAS03;

ILAS04) located within 10 km of the SAC. Potential




Small scale (<50,000 tpa) feasible at Site 2, ILAS03

and ILAS04.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)


226

16.F References


process for the Wimbledon Common SAC.


and Flora: Citation for Special Area of Conservation (SAC) – Wimbledon

Common SAC (Natural England (English Nature), May 2005).



& designated SACs) – Wimbledon Common SAC (Joint Nature Conservation


16.37.3 European Site Conservation Objectives for Wimbledon Common Special Area

of Conservation (Site Code: UK0030301) (Natural England, 30 June 2014, v.2).

16.37.4 Site Improvement Plan: Wimbledon Common SAC (Natural England, 17

November 2014).



16.37.6 Wimbledon Common SSSI Condition Survey Report (Natural England,




June 2018.

16.37.9 Surrey Waste Local Plan: Air Quality Impact Assessment report, AECOM for

Surrey County Council, June 2018.

16.37.10 Habitat Regulations Assessment for the Estates Plan (part of the Local Plan),

Merton Borough Council, 2016.




227

Chapter 17 Windsor Forest & Great Park SAC



17.1 The Windsor Forest & Great Park SAC (see map) covers an area of 1,687.26 hectares, as

stated on the SAC citation, and was designated on 1 April 2005. The SAC is primarily located

in the former county of Berkshire, within the areas covered by the Windsor & Maidenhead

council, and by the Bracknell Forest Council. A small part (approximately 11.5 hectares) of

the SAC lies within the county of Surrey, in the borough of Runnymede. The SAC is

composed of a single SSSI, the Windsor Forest & Great Park SSSI (1,778.85 hectares).

17.2 The following ‘A’ class roads and ‘B’ class roads pass through or within 200 metres of the

SAC.

17.2.1 The A332 (Sheet Street Road) – which passes through the SAC.

17.2.2 B3022 (Winkfield Road) – which passes through the SAC.

17.2.3 The A329 (Blacknest Road) – which passes within 200 metres of the southern


17.2.4 The B383 (Mounts Hill) – which passes within 200 metres of the southern


17.3 The SAC is situated across a number of different surface water catchments, which lie wholly

or partly within the county of Surrey.

17.3.1 The Chertsey Bourne (Virginia Water to Chertsey) (GB106039017070).

17.3.2 The Chertsey Bourne (Sunningdale to Virginia Water) (GB106039017040).

17.3.3 The Chertsey Bourne (Ascot to Virginia Water) (GB106039017050).

17.3.4 The Thames (Cookham to Egham) (GB106039023231).


17.4 The Windsor Forest & Great Park SAC is located within 10 kilometres of the following sites

proposed for allocation under Policy 11, and the following ILAS identified under Policy 10 of

the Surrey WLP (see Figure 17-A – a full size version can be found in Appendix A). The Plan

does not specify the type or scale of waste related development that could be




228

Site 1 (Oakleaf Farm, Horton Road, Stanwell Moor), 5.9 kilometres to the east of the

SAC.

Site 6 (Land at Trumps Farm, Kitsmead Lane, Longcross) 3.0 kilometres to the south

east of the SAC.

ILAS14 (Thorpe Industrial Estate, Ten Acre Lane, Egham), 4.8 kilometres to the east of

the SAC.

ILAS22 (Monument Way Industrial Estate, Woking), 9.9 kilometres to the south east of

the SAC.

Figure 17-A: Windsor Forest & Great Park SAC – Relationship to sites & ILAS proposed by the Surrey

WLP

17.5 The following sites proposed for minerals related development in the adopted Surrey

Minerals Plan are located within 5 kilometres of the SAC.

17.5.1 The area of land identified as ‘Preferred Area D: Milton Park Farm, Egham’ in

the Primary Aggregates DPD of the Surrey Minerals Plan lies some 3.8

kilometres to the east of the SAC. A planning application for the extraction of

sand and gravel, and restoration of the site by means of infilling with inert

waste has been lodged with the County Planning Authority.

<2.5 km

2.5 - 5 km

5 – 10 km

>10 km

Windsor Forest & Great Park SAC

Windsor Forest &

Great Park SAC

Site 6: Trumps Farm


ILAS14

ILAS22

N

S

W E

20 km

30 km

40 km

50 km

Site 5: Lambs BP

Site 2: Weylands TW

Site 3: Slyfield IE

Site 4: Leatherhead

STW

ILAS01;ILAS15

ILAS02

ILAS03;ILAS16

ILAS04


ILAS07

ILAS08

ILAS10


ILAS17

ILAS18

ILAS19

ILAS20;ILAS21


229

17.5.2 The area of land identified as ‘Preferred Area E: Whitehalll Farm, Egham’ in the

Primary Aggregates DPD of the Surrey Minerals Plan lies some 2.9 kilometres

to the east of the SAC. The key development criteria for the preferred area

state that the land should not be worked in parallel with Preferred Area D

(Milton Park Farm).

17.5.3 The area of land identified as ‘Preferred Area H: King George VI Reservoir,

Stanwell’ in the Primary Aggregates DPD of the Surrey Minerals Plan lies some

5.3 kilometres to the east of the SAC.





Site Description

Windsor Forest contains dry oak-dominated woodland. Relicts of the primary forest still survive as ancient oak pollards scattered throughout the Park & Forest. Veteran trees occur with a mosaic of unimproved & semi-improved grassland & grass-heath. It has the largest number of ancient oaks Quercus spp. in Britain (& probably in Europe), a consequence of its management as wood-pasture. Many of these trees are over 500 years old & some reputed to be up to 800 years. Of equal importance, although not reaching such a great age, are numerous over-mature beech trees Fagus sylvatica.

Being partially hollow & decayed, the oaks & beech afford habitats for a number of extremely rare & specialised insects. The site is of importance for its range & diversity of saproxylic (dead wood) invertebrates, including many rare species (e.g. the violet click beetle Limoniscus violaceus), & has recently been recognised as having rich fungal assemblages.

Qualifying Habitats


Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion). (Beech forests on acid soils)

Old acidophilous oak woods with Quercus robur on sandy plains. (Dry oak-dominated woodland)

Qualifying Species


Violet click beetle Limoniscus violaceus




230









Qualifying Features

H9120. Atlantic acidophilous beech forests with Ilex & sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils

H9190. Old acidophilous oak woods with Quercus robur on sandy plains; Dry oak-dominated woodland

S1079. Limoniscus violaceus; Violet click beetle

17.B.3 Condition


report for the Windsor Forest & Great Park SSSI21 (see Table 17-A), the designated site

extends to some 1,778.85 hectares, of which some 51.84% is in ‘favourable’ condition, and

some 48.16% is in ‘unfavourable – recovering’ condition. The majority of SSSI is composed

of one main habitat type, ‘broadleaved, mixed & yew woodland’ (1,626.00 hectares), with

the remainder of the site composed of a mixture of acid grassland, coniferous woodland,

and standing open water and canals.

Table 17-A: Windsor Forest & Great Park SSSI – Condition Survey Findings

Main Habitat Type



Recovering


1,626.00 ha

(91.41%)

836.15 ha

(47.01%)

789.85 ha

(44.40%)

Acid grassland – lowland 71.91 ha

(4.04%)

71.91 ha

(4.04%)

0.0 ha

(0.0%)


(3.76%)

0.0 ha

(0.0%)

66.87 ha

(3.76%)


(0.79%)

14.07 ha

(0.79%)

0.0 ha

(0.0%)

Totals 1,778.85 ha 922.13 ha

(51.84%)

856.72 ha

(48.16%)

21 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004110&ReportTitle=Windsor%20Forest%20and%20Great%20Park%20SSSI

https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004110&ReportTitle=Windsor%20Forest%20and%20Great%20Park%20SSSIc


231

17.9 The SAC designation does not cover the whole of the SSSI, with Unit 11 (66.87 hectares of

coniferous woodland habitat in ‘unfavourable – recovering’ condition) falling outside the

SAC boundary.


17.10 The published Site Improvement Plan (SIP) for the SAC (4 November 2014) identifies the


Forestry and woodland management (beech) – discussed further in section 17.C.1;

Forestry and woodland management (oak) – discussed further in section 17.C.2;


Changes due to the incidence of plant disease – discussed further in section 17.C.4;


in section 17.C.5.

17.C.1 Forestry & Woodland Management – Beech

17.11 The features affected are the beech forests on acid soils (H9120) habitat, and the Violet

click beetle (S1079) population. The SIP (pp.3/12 to 5/12) offers the following explanation

of the nature of the identified pressure/threat:

“The loss of ancient/veteran beech trees due to gaps in age classes results in loss of the beech

forest habitat & reduced habitat for the violet click beetle. There is a lack of understanding of

current veteran tree & microhabitat resource, as well as the distribution of violet click beetles,

& methods to ensure provision of its habitat requirements. This makes it difficult to establish

appropriate management measures (such as the planting or 'promotion' of trees in the right

locations).”


pressure/threat are concerned with

Prolonging the life of existing veteran beech trees.

Updating assessments of veteran tree health using revised veteran tree assessment

protocols – to establish current distribution and condition of ancient / veteran beech

population and the rate of decline/loss, and include an 'audit' of current provision of

key microhabitats required to maintain the fungi and invertebrate assemblages,

including fallen decaying wood habitats.

Planting or 'promoting' future veteran beech tree population, and management/

creation of new pollards where appropriate.

Undertaking research to help develop a 'smart' action plan for sustainable Limoniscus

habitat provision.


232

Undertaking research to improve techniques for survey and monitoring of Limoniscus,

and other notable species.

Undertaking survey for Limoniscus across the site, to get a better understanding of its

Windsor distribution and preferred habitat.

Reducing habitat fragmentation, through a landscape scale project to maintain/

restore ancient tree populations and improve linkage with other supporting habitats in

wider area around Windsor, and to include development and implementation of an

education, awareness and strategic action plan with key partners.

Restoring additional areas as extensively managed /grazed wood pasture landscape.








provision of additional waste management capacity within the county of Surrey would be

unlikely to be situated in close enough proximity to the SAC to be of significant benefit to

the ongoing management of its woodland habitats. Wastes arising from the management

of the SAC would more likely be dealt with by facilities situated in the Royal Borough of

Windsor & Maidenhead.





those habitats. No further assessment is required in respect of the changes in forestry or


17.C.2 Forestry & Woodland Management – Oak

17.15 The feature affected is the dry oak dominated woodland (H9190) habitat. The SIP (p.6/12)

offers the following explanation of the nature of the identified pressure/threat:

“The loss of ancient/veteran oak trees, & associated reduction in the abundance & diversity of

veteran tree micro habitats, due to gaps in age classes has implications for Old acidophilous

oak woods habitat & associated flora (inc fungi) & fauna.”


pressure/threat are concerned with

Prolonging the life of existing veteran oak and other native or relevant tree species.

Updating assessments of veteran tree health using revised veteran tree assessment

protocols – to establish current distribution and condition of ancient / veteran oak and


233

other native or relevant tree populations and the rate of decline/loss, including an

'audit' of current provision of key microhabitats required to maintain the fungi and

invertebrate assemblages, including fallen decaying wood habitats.

Planting or 'promoting' future veteran oak and other native or relevant tree

populations, and management/creation of new pollards where appropriate.








provision of additional waste management capacity within the county of Surrey would be

unlikely to be situated in close enough proximity to the SAC to be of significant benefit to

the ongoing management of its woodland habitats. Wastes arising from the management

of the SAC would more likely be dealt with by facilities situated in the Royal Borough of

Windsor & Maidenhead.





those habitats. No further assessment is required in respect of the changes in forestry or


17.C.3 Invasive Species

17.19 The features affected are the dry oak dominated woodland (H9190) habitat, and the beech

forests on acid soils (H9120) habitat. The SIP (p.7/12) offers the following explanation of the

nature of the identified threat:

“Oak processionary moth is widespread in south west London & is present within 20 miles of

the site. If oak processionary moth colonises the site it could accelerate loss of the ancient oak

population &/or cause serious management problems. Turkey oak is a significant threat to

acorn viability & hence the natural regeneration potential of native oak. Rhododendron

represents a threat to scrub /grassland /flower rich supporting habitats of saproxylic species.”


concerned with undertaking surveillance for oak processionary moth and preparing a

strategy for when it is found at Windsor, with eradicating Turkey oak, and with eradicating

Rhododendron.




234


implementation of the Plan could result in the introduction of the oak processionary moth

into the SAC, as the infestation is typically spread by the movement of young trees. Whilst it

is conceivable that the Plan could result in the construction and operation of green waste

management facilities, any facility offering services in respect of the management of

material infested by oak processionary moth would have to operate in accordance with

relevant plant health law (Plant Health (Forestry) Order 2005, as amended) and the

relevant Forestry Commission good practice guidance. The Plan could support ongoing

efforts to reduce the amounts of Turkey oak and Rhododendron present in the SAC, by

enabling the provision of waste management facilities that are equipped to appropriately

dispose of the green waste arising from the removal of the invasive plant species.




management of the Oak processionary moth, of Turkey oak, and of Rhododendron. No

further assessment is required in respect of the invasive species impact pathway.

17.C.4 Disease

17.23 The feature affected is the dry oak dominated woodland (H9190) habitat. The SIP (p.7/12)


“Diseases of native oak are known from the local area. It is uncertain how significant this

could be for the ancient oak population.”


concerned with undertaking surveillance for tree diseases that might impact on veteran

trees.

17.25 Screening Evaluation: The construction and operation of facilities that treat green waste

present a potential source from which plant diseases could spread into sensitive habitats

within the SAC. One plant disease of potential concern for the SAC would be sudden oak

death, which is caused by the water mould Phytophthora ramorum. Whilst the indigenous

sessile and pedunculate oak trees of the British Isles are fairly resistant beech trees can be

affected by the disease. The disease can be spread by means of windborne spores, amongst

other mechanisms, but aeolian dispersal would be the most relevant to green waste


17.26 Guidance adopted in other waste local plans around the UK (e.g. Essex & Southend Waste

Local Plan, 2017; East Sussex Minerals & Waste Local Plan, 2013) has applied a screening

distance of 1 kilometre to the consideration of biopathogen dispersal from waste

management sites. Applying that screening distance to the sites allocated under Policy 11

and the ILAS identified under Policy 10 of the Surrey WLP it is possible to conclude that

none of the allocated sites or ILAS would be a likely source for the spread of plant disease


235

onto the SAC. The closest site (Site 6 – Land at Trumps Farm, Longcross) is located some 3.0

kilometres to the south east of the SAC, and the closest ILAS (ILAS14 – Thorpe IE, Thorpe) is

some 4.8 kilometres to the east.




potential introduction of plant disease into the designated site. No further assessment is

required in respect of the plant disease impact pathway.


17.28 The features affected by changes in levels of nutrient nitrogen deposition from the

atmosphere are the dry oak dominated woodland (H9190) habitat, and the beech forests

on acid soils (H9120) habitat. The SIP (p.8/12) offers the following explanation of the nature


“Nitrogen deposition exceeds site relevant critical loads. Likely sources include Heathrow

airport which is close to Windsor Forest. Air quality is likely to be an issue for old trees, fungi

and lichens.”










17.31 The potential for thermal treatment development at one of the sites allocated under Policy

11a (Site 1: Oakleaf Farm, Stanwell Moor) to give rise to likely significant effects has been

identified on the basis of predicted process contributions being equivalent to 1% of more of

the minimum site relevant critical load for the most sensitive habitat within the SAC (see

Part B11, Appendix B).

17.32 Two of the ILAS (see below) identified under Policy 10 are located within 10 kilometres of

the SAC. The development of thermal treatment facilities on land located within either of

those two ILAS could, in theory, present risks of nutrient nitrogen deposition on land within

the SAC.

ILAS14 – Thorpe Industrial Estate, Thorpe.

ILAS22 – Monument Way East Industrial Estate, Woking.


236

17.33 In terms of the potential for diffuse emissions, the Transport Study for the Surrey WLP does

not anticipate that vehicles from either of the two allocated sites (Site 1 – Oakleaf Farm,

Stanwell Moor; Site 6 – Trumps Farm, Longcross) situated within 10 kilometres of the SAC

would travel along any of the ‘A’ or ‘B’ class roads that pass through the SAC. The HRA

report (January 2018) for the Royal Borough of Windsor & Maidenhead Local Plan

concluded that its implementation would have no significant impacts on the SAC, as a

consequence of traffic emissions.



strategic road networks. Neither of the ILAS that are located within 10 kilometres of the


SAC.

17.35 Screening Conclusion: The implementation of the Surrey WLP would not give rise to

significant impacts on nutrient nitrogen deposition within the SAC, as a consequence of

emissions from traffic sources. However, the potential for significant impacts as a

consequence of emissions from the development and operation of some scale and type of

thermal treatment plant on land situated within 10 kilometres of the SAC cannot be ruled

out at the screening stage. Further assessment is required in respect of the air pollution

(emission and deposit of nitrogen) impact pathway in respect of point source emissions

from allocated sites and identified ILAS.

17.D Assessment of Likely Significant Effects


deposition of nitrogen) by which development of one of the sites(Site 1 – Oakleaf Farm,

Stanwell Moor) allocated under Policy 11a and two of the ILAS (ILAS14; ILAS22) identified

under Policy 10 of the Surrey WLP could give rise to likely significant effects on the SAC. The

mechanism by which the development of the proposed site could contribute to the deposit

of nutrient nitrogen would be emissions from thermal treatment plants.

17.37 In total three areas of land allocated or otherwise identified under policies in the Surrey

WLP are located within 10 kilometres of the Windsor Forest & Great Park SAC. Modelling of

the potential effects of a range of scales of thermal treatment plants has been carried out

for the allocated site (see Part B11, Appendix B, and Appendix C). For the ILAS, for which







loads for all the features covered by the SAC designation can be found in Part B11 of



237

17.38 For Site 1 (Oakleaf Farm, Stanwell Moor) the modelling (see Part B11, Appendix B) indicated

that the emissions arising under three of the four scenarios considered would account for

more than 1% of the minimum site relevant critical loads across both habitat types covered

by the SAC designation. For the fourth scenario (construction of a <50,000 tpa gasification

facility) the modelled process contributions accounted for 0.84% of the minimum site

relevant critical loads for both the SAC habitats. The estimated background deposition rates

for nutrient nitrogen within the area of the SAC closest to Site 1 exceed the minimum site

relevant critical loads for both the habitat types covered by the SAC designation (see Part

B11, Appendix B). The PEC (background plus process contribution) would increase by

between 0.3% to 1.5% for both the oak and beech woodland habitats.

17.39 For the two ILAs identified under Policy 10 of the Surrey WLP that are located within 10

kilometres of the SAC it was concluded that each (ILAS14: Thorpe IE, Thorpe; ILAS22:

Monument Way East IE, Woking) could accommodate a small sale (<50,000 tpa) thermal

treatment facility without giving rise to nitrogen deposition within the SAC equivalent to

more than 1% of the minimum site relevant critical loads for both habitat classes, subject to

it being demonstrated at the planning application stage that the ecological integrity of the

SAC would not be adversely affected. Implementation of Policy 14 of the Surrey WLP, which

requires that all waste related planning applications be supported by sufficient information

for the WPA to ascertain whether the proposed development would result in significant

adverse impacts on the natural environment, including SPAs and SACs, will ensure that

permitted development does not compromise the ecological integrity of the SAC.

17.E Conclusions


ecological integrity of the Windsor Forest & Great Park SAC has concluded that overall

there would be no potential for ‘likely significant effects’ to arise.

17.40.1 One of the sites allocated under Policy 11a (Site 1: Oakleaf Farm, Stanwell

Moor) and two of the ILAS (ILAS14; ILAS22) identified under Policy 10 of the




modelling and assessment at the planning application stage.






metres of the SAC.


238







Level


woodland management (oak)


17.C.1



WLP

Screening


woodland management

(beech) – discussed further in

section 17.C.2



WLP

Screening

Changes due to the



section 17.C.3



WLP

Screening

Changes due to the incidence

of plant disease – discussed




WLP

Screening





17.C.5







and ILAS22.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

17.E References


process for the Windsor Forest & Great Park SAC.


239


and Flora: Citation for Special Area of Conservation (SAC) – Windsor Forest &

Great Park SAC (Natural England (English Nature), May 2005).



& designated SACs) – Windsor Forest & Great Park SAC (Joint Nature


17.42.3 European Site Conservation Objectives for Windsor Forest & Great Park Special

Area of Conservation (Site Code: UK0012586) (Natural England, 30 June 2014,

v.2).

17.42.4 Site Improvement Plan: Windsor Forest & Great Park SAC (Natural England, 4

November 2014).



17.42.6 Windsor Forest & Great Park SSSI Condition Survey Report (Natural England,



17.42.8 Essex & Southend-on-Sea Waste Local Plan, Essex County Council and

Southend-on-Sea Borough Council, 2017

17.42.9 East Sussex, South Downs & Brighton & Hove Waste & Minerals Local Plan:

Waste & Minerals Plan, East Sussex County Council, Brighton & Hove City

Council, and the South Downs National Park Authority, 2013.


June 2018.

17.42.11 Surrey Waste Local Plan: Air Quality Impact Assessment report, AECOM for

Surrey County Council, June 2018.

17.42.12 Habitat Regulation & Air Quality Assessment Update, Ricardo Energy &

Environment for the Royal Borough of Windsor & Maidenhead, January 2018.




240

Chapter 18 Summary of HRA Conclusions

18.A Introduction

18.A.1 Overview of conclusions

18.1 The assessment has considered the potential for the implementation of the emerging

Surrey WLP to give rise to likely significant effects on the SPAs and SACs that are situated

within the county of Surrey, or within 10 kilometres of the county boundary. The

assessment has considered the policies and proposals set out in the Surrey WLP against the

impact pathways identified in the published SIPs for each SPA and SAC. Detailed assessment

was carried out in respect of one of the sites covered in Part A of this report (the Woolmer

Forest SAC), and in respect of ten of the fourteen SPAs and SAC in Part B of this report (the

exceptions being Ashdown Forest SPA, Richmond Park SAC, the South West London

Waterbodies SPA and Ramsar Site, and the Wealden Heaths Phase 2 SPA).

18.2 The assessment has concluded that implementation of the Surrey WLP is not likely, alone or

in combination with other plans, strategies or proposals, to give rise to significant adverse

impacts on the integrity of any of the SPAs or SACs covered by the assessment, subject to

observation of the decision rules (avoidance measures) outlined in part B-1 of Appendix B

to this report. The identified avoidance measures relate to those sites allocated or ILAS

identified in the Surrey WLP, which could be developed in ways that may be harmful to the

integrity of one or more SPAs or SACs.

18.B The Mens SAC


ecological integrity of The Mens SAC has concluded that overall there would be no potential

for ‘likely significant effects’ to arise. None of the sites allocated under Policy 11 or the ILAS

identified under Policy 10 of the Surrey WLP are located within 10 kilometres of the SAC,

and it is unlikely that strategic waste management facilities of the types (i.e. thermal

treatment plants) with the potential to give rise to long range impacts would be brought

forward successfully on land that has not been identified as suitable for waste related

development by the Plan. In addition, Policy 14 (Development Management) of the Surrey

WLP provides protection for sensitive ecological sites at the planning application stage.

18.4 The assessment considered the six impact pathways identified as key threats and pressures

of concern with reference to the conservation objectives for the SAC. The conclusions

reached in respect of the likely impact of the Surrey WLP on the SAC via each pathway are

summarised in Table 18-A.


241

Table 18-A: Summary of assessment conclusions for The Mens SAC


Level



section 2.C.1



WLP

Screening

Changes in habitat

connectivity – see section

2.C.2



WLP

Screening



2.C.3



WLP

Screening





WLP

Screening






WLP

Screening



2.C.6



WLP

Screening

18.C Woolmer Forest SAC


ecological integrity of the Woolmer Forest SAC has concluded that overall there would be



of the SAC, and it is unlikely that strategic waste management facilities of the types (i.e.

thermal treatment plants) with the potential to give rise to long range impacts would be

brought forward successfully on land that has not been identified as suitable for waste

related development by the Plan. The SAC is dissected by a section of the A3 road, and the

A3 would also likely be a major transport link for one of the allocated sites (Site 3: Land

north east of Slyfield IE, Guildford) and three of the ILAS (ILAS05; ILAS06; ILAS08) identified

in the Surrey WLP. However, it is unlikely that 100% of traffic from that allocated site and

those three ILAS would travel along the section of the A3 that passes through the A3. In

addition, Policy 14 (Development Management) of the Surrey WLP provides protection for

sensitive ecological sites at the planning application stage.






242

Table 18-B: Summary of assessment conclusions for the Woolmer Forest SAC


Level


practices – discussed in

section 3.C.1



WLP

Screening


invasive species – discussed

in section 3.C.2



WLP

Screening

Changes in local hydrology –

discussed in section 3.C.3



WLP

Screening

Changes in the location,

extent and condition of the

features for which the SAC is

designated – discussed in

section 3.C.4



WLP

Screening

Changes in military use of the

land – discussed in section

3.C.5



WLP

Screening



nitrogen) – discussed in

section 3.C.6 & section 3.D

One allocated site (Site 3) and three ILAS (ILAS05,

ILAS06, ILAS06) could give rise to additional traffic

on the A3. Potential for adverse impacts from

nutrient nitrogen deposition arising from traffic

emissions.



disperse to the wider network, unlikely that 100%

of traffic servicing Site 3 and the three ILAS would

travel along the section of the A3 that passes

through Woolmer Forest.


on the SAC.

Screening

(Process

Emissions)

Assessment

of Likely

Significant

Effects

(Traffic

Emissions)

Changes in the risks of

wildfire / arson – discussed in

section 3.C.7



WLP

Screening

18.D Ashdown Forest SAC


ecological integrity of the Ashdown Forest SAC has concluded that overall there would be


11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS18 – Hobbs IE,

Felbridge) identified under Policy 10 of the Surrey WLP is 8.6 kilometres to the north west.

Development of a thermal treatment facility on land at ILAS18 could, in theory result in



243

the ILAS could also contribute to such deposition. Given the relationship of ILAS18 to

potential sources of waste (e.g. Horley, Crawley, East Grinstead, Smallfield, Lingfield) and to





assessment).




pathway are summarised in Table 18-C.

Table 18-C: Summary of assessment conclusions for the Ashdown Forest SAC


Level

Change in land management


4.C.1



WLP

Screening




& section 4.D






at ILAS18.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

Hydrological changes –


4.C.3



WLP

Screening

18.E Ashdown Forest SPA


ecological integrity of the Ashdown Forest SPA has concluded that overall there would be



of the SPA, but one of the ILAS (ILAS18 – Hobbs IE, Felbridge) is 8.6 kilometres to the north


244

west. The primary issue of concern for the ecological integrity of the SPA identified in the

published SIP is that of public access and disturbance, the incidence of which would be

unaffected by the development of new waste management capacity on the identified ILAS

or on other land within Surrey.

18.10 The assessment considered the single impact pathway identified as key threats and


conclusions reached in respect of the likely impact of the Surrey WLP on the SPA via the

identified pathway are summarised in Table 18-D.

Table 18-D: Summary of assessment conclusions for the Ashdown Forest SPA


Level



5.C.1



WLP

Screening

18.F East Hampshire Hangers SAC


ecological integrity of the East Hampshire Hangers SAC has concluded that overall there


under Policy 11 are located within 10 kilometres of the SAC, but two of the ILAS (ILAS20 –

Coxbridge BP, Farnham; ILAS21 – Farnham TE, Farnham) identified under Policy 10 of the

Surrey WLP are 6.0 kilometres and 9.5 kilometres to the north east. Development of

thermal treatment facilities on land at ILAS20 and/or ILAS21 could, in theory result in


the two ILAS could also contribute to such deposition. Given the relationship of ILAS20 and

ILAS21 to the wider road network it is unlikely that any waste related development would

result in vehicle movements through the SAC. To address the risk of nutrient nitrogen

deposition from process emissions from thermal treatment of waste it is recommended

that ILAS20 is unsuitable for all scales of such development (subject to the conclusions of

any project level assessment) and that ILAS21 may accommodate a small scale (<50,000

tpa) facility (subject to the conclusions of any project level assessment) with reference to

the East Hampshire Hangers SAC.






245

Table 18-E: Summary of assessment conclusions for the East Hampshire Hangers SAC


Level



section 6.C.2



WLP

Screening



6.C.3



WLP

Screening




& section 6.D

Two ILAS (ILAS20 and ILAS21) located within 10 km

of the SAC. Potential for adverse impacts from



emissions.


at ILAS20 with reference to the EHH SAC, and only

small-scale (<50,000 tpa) facilities could be

accommodated at ILAS21.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

18.G Ebernoe Common SAC


ecological integrity of the Ebernoe Common SAC has concluded that overall there would be


11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS19 – Dunsfold

Aerodrome, Cranleigh) identified under Policy 10 of the Surrey WLP is 8.8 kilometres to the

north east. Development of a thermal treatment facility on land at ILAS19 could, in theory

result in nutrient nitrogen deposition within the SAC, and traffic arising from development

within the ILAS could also contribute to such deposition. Given the relationship of ILAS19 to





assessment).


246




pathway are summarised in Table 18-F.

Table 18-F: Summary of assessment conclusions for the Ebernoe Common SAC


Level


woodland management


in section 7.C.1



WLP

Screening

Changes in off-site habitat

availability– discussed further

in section 7.C.2



WLP

Screening






WLP

Screening



in section 7.C.4



WLP

Screening



in section 7.C.5



WLP

Screening




& section 7.D






at ILAS19.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)




7.C.7



WLP

Screening


247

18.H Mole Gap to Reigate Escarpment SAC


ecological integrity of the Mole Gap to Reigate Escarpment SAC has concluded that overall

there would be no potential for ‘likely significant effects’ to arise, subject to the



18.15.1 Two of the sites allocated under Policy 11 (Site 4: Leatherhead STW,

Leatherhead; and, Site 5: Lambs BP, South Godstone) and five of the ILAS

(ILAS04; ILAS10; ILAS11; ILAS12; and, ILAS13) identified under Policy 10 of the


operation of large scale (>50,000 tpa) thermal treatment facilities is not

recommended on either of the allocated sites, although there may be greater

scope for the development of a facility with a capacity of more than 50,000 tpa

at Site 5 (Lambs BP, South Godstone), subject to the outcome of detailed

modelling and assessment at the planning application stage. In the interests of

managing the risk of in-combination effects it is recommended that four of the

identified ILAS, ILAS10, ILAS11, ILAS12 and ILAS13, would be unsuitable

locations for small-scale (<50,000 tpa) thermal treatment plants.





management facilities, even in the event of all seven sites being brought

forward for such development, would travel along those sections of the A24

and the M25 that pass through or within 200 metres of the SAC.




pathway are summarised in Table 18-G.

Table 18-G: Summary of assessment conclusions for the Mole Gap to Reigate Escarpment SAC


Level


incidence of plant disease

(box blight) – discussed




WLP

Screening



in section 8.C.2



WLP

Screening


248


Level



in section 8.C.3



WLP

Screening




8.C.4



WLP

Screening





8.C.5

Two allocated sites (Site 4 and Site 5) and five ILAS

(ILAS04, ILAS10, ILAS11, ILAS12, ILAS13) located

within 10 km of the SAC. Potential for adverse





at Site 4, ILAS10, ILAS11, ILAS12 and ILAS13.

Small scale (<50,000 tpa) feasible at Site 5 and

ILAS04.











Assessment

of Likely

Significant

Effects

(Process

Emissions &

Traffic

Emissions)

18.I Richmond Park SAC


ecological integrity of the Richmond Park SAC has concluded that overall there would be no

potential for ‘likely significant effects’ to arise. One of the sites allocated under Policy 11

(Site 2: Weylands TW, Walton on Thames) and four of the ILAS (ILAS02; ILAS03; ILAS04 and

ILAS16) identified under Policy 10 of the Surrey WLP are located within 10 kilometres of the

SAC. The SAC is not susceptible (according to the published SIP) to adverse impacts due to

the deposition of nutrient nitrogen, and is not close enough to the allocated site and ILAS to

be directly or indirectly affected by the more localised impacts of waste related

development (e.g. noise and light disturbance).

18.18 No key threats and pressures have been identified by Natural England with reference to the

conservation objectives for the SAC. The conclusions reached in respect of the likely impact

of the Surrey WLP on the SAC are based on an assessment of the extent to which

implementation of the Plan might influence or affect habitat management practices within

the SAC.


249

18.J Shortheath Common SAC


ecological integrity of the Shortheath Common SAC has concluded that overall there would

be no potential for ‘likely significant effects’ to arise. None of the sites allocated under

Policy 11 are located within 10 kilometres of the SAC, but one of the ILAS (ILAS20 –

Coxbridge BP, Farnham) identified under Policy 10 of the Surrey WLP is 9.4 kilometres to

the north east. Development of thermal treatment facilities on land at ILAS20 could, in

theory result in nutrient nitrogen deposition within the SAC, and traffic arising from

development within ILAS20 and the more distant ILAS21 (12.7 kilometres north east) could

also contribute to such deposition. Given the relationship of ILAS20 and ILAS21 to the wider

road network it is unlikely that any waste related development would result in vehicle

movements through the SAC. To address the risk of nutrient nitrogen deposition from

process emissions from thermal treatment of waste it is recommended that ILAS20 is

unsuitable for large scale (>50,000 tpa) thermal treatment facilities but could accommodate

a smaller plant (<50,000 tpa) (subject to the conclusions of any project level assessment).

18.20 The assessment considered the four impact pathways identified as key threats and



pathway are summarised in Table 18-H.

Table 18-H: Summary of assessment conclusions for the Shortheath Common SAC


Level




& section 10.D






recommended at ILAS20 but small-scale (<50,000

tpa) facilities could be accommodated with

reference to the Shortheath Common SAC.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)


250


Level



in section 10.C.1



WLP

Screening




10.C.2



WLP

Screening

Changes due to direct

encroachment onto the land

by a third party (householder)


10.C.3



WLP

Screening

18.K South West London Waterbodies SPA & Ramsar Site


ecological integrity of the South West London Waterbodies SPA and Ramsar Site has

concluded that overall there would be no potential for ‘likely significant effects’ to arise.

Three of the sites allocated under Policy 11 (Site 1 – Oakleaf Farm, Stanwell Moor; Site 2 –

Weylands TW, Walton on Thames; Site 6 – Trumps Farm, Longcross) and seven of the ILAS

(ILAS01; ILAS02; ILAS03; ILAS14; ILAS15; ILAS16; ILAS22). However, taking account of the

nature of the waterbodies that together form the SPA complex, of which those located in

closest proximity to allocated sites and ILAS comprise of established public water supply

reservoirs with engineered banks, there is little risk to the integrity of the SPA (and Ramsar

Site) from the development of land located in close proximity. In addition, the issues

identified as matters of concern for the SPA in the published SIP are mainly concerned with

the use and management of the designated waterbodies, or with the control of invasive

species, all of which are matters that would be unaffected by waste related development

on nearby land.


pressures of concern with reference to the conservation objectives for the SPA and the

Ramsar Site. The conclusions reached in respect of the likely impact of the Surrey WLP on

the SPA and the Ramsar Site via each pathway are summarised in Table 18-I.

Table 18-I: Summary of assessment conclusions for the South West London Waterbodies SPA


Level




11.C.1




Screening


251


Level

Changes in species

distribution – discussed





Screening

Changes due to the


species (Crassula helmsii) –


11.C.3




Screening


natural maturation of

wetland habitats– discussed





Screening

Changes in fish stocking

densities and practices –


11.C.5




Screening

Changes in waterweed

control practices – discussed





Screening


incursion of invasive species

(Egyptian geese) – discussed





Screening

18.23 The further information provided in parts B (paragraphs 2-4, pp.8-9), H-1 (paragraphs 21-

24, pp.17-18) and H-7 (paragraphs 47-48 and 50, pp.24-25) of the appendix to the

Statement of Common Ground between Natural England and Surrey County Council, dated

8 August 2019, does not alter the conclusions reached by the HRA process in respect of the

likely impacts of the Surrey WLP on the South West London Waterbodies SPA and Ramsar

Site. That further information provides detailed descriptions of the physical relationship

between one proposed allocated site (Site 1 – Oakleaf Farm, Stanwell Moor) and two

proposed ILAS (ILAS03 – Molesey Industrial Estate, West Molesey; and, ILAS14 – Thorpe

Industrial Estate, Thorpe) and component parts of the SPA and Ramsar Site. Those

descriptions serve to reinforce the conclusions reached through the HRA process, that

waste development at the allocated site or either of the ILAS would not result in significant

impacts on the ecological integrity of the SPA and Ramsar Site.

18.L Thames Basin Heaths SPA


ecological integrity of the Thames Basin Heaths SPA has concluded that overall there would


252

be no potential for ‘likely significant effects’ to arise, subject to the observation of a

number of decision rules with reference to the development of thermal treatment facilities.

18.24.1 One of the sites allocated under Policy 11a (Site 3: Land north east of Slyfield

IE, Guildford) and four of the ILAS (ILAS05; ILAS07; ILAS17; and, ILAS22)

identified under Policy 10 of the Surrey WLP are located in sufficiently close

proximity to components of the SPA to render them unsuitable as locations for

different scales of thermal treatment facility. The construction and operation

of large scale (>50,000 tpa) thermal treatment facilities is not recommended

on Site 3, although there may scope for the development of a facility with a

capacity of less than 50,000 tpa, subject to the outcome of detailed modelling

and assessment at the planning application stage. In the interests of managing

the risk of in-combination effects it is recommended that four of the identified

ILAS, ILAS05, ILAS07, ILAS17 and ILAS22, would be unsuitable locations for all

scales of thermal treatment plants.






pass through the thirteen SSSIs that together form the SPA.




pathway are summarised in Table 18-J.

Table 18-J: Summary of assessment conclusions


Level




12.C.1



WLP

Screening



12.C.2



WLP

Screening


woodland management


in section 12.C.3



WLP

Screening



in section 12.C.4



WLP

Screening


253


Level






WLP

Screening


location and extent of the



12.C.7



WLP

Screening




12.C.8



WLP Screening






Three allocated sites (Site 2, Site 3 and Site4) and

seventeen ILAS (ILAS01, ILAS02, ILAS03, ILAS05,


ILAS16, ILAS17, ILAS20, ILAS21, ILAS22) located

within 10 km of the SPA. Potential for adverse





recommended on Site 3.


at ILAS05, ILAS07, ILAS17 and ILAS22.



assessment.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)






WLP Screening

18.26 The further information provided in parts C (paragraphs 5-7, p.10), E (paragraphs 11-15,

pp.12-13), H-3 (paragraphs 28-32, pp.19-20), H-4 (paragraphs 33-38, pp.20-22), H-8

(paragraphs 51 and 53-55, pp.25-26) and H-10 (paragraphs 59 and 61-62, pp.27-28) of the

appendix to the Statement of Common Ground between Natural England and Surrey


254

County Council, dated 8 August 2019, does not alter the conclusions reached by the HRA

process in respect of the likely impacts of the Surrey WLP on the Thames Basin Heaths SPA.

That further information provides detailed descriptions of the physical relationship

between two proposed allocated sites (Site 3 – Land north east of Slyfield Industrial Estate,

Guildford; and, Site 6 – Trumps Farm, Longcross) and four proposed ILAS (ILAS05 – Slyfield

Industrial Estate, Guildford; ILAS07 – Land north and south of Lysons Avenue, Ash Vale;

ILAS17 – York Town Industrial Estate, Camberley; and, ILAS22 – Monument Way East

Industrial Estate, Woking) and component parts of the SPA. Those descriptions serve to

reinforce the conclusions reached through the HRA process, that waste development at

either of the allocated sites or any of the ILAS would not result in significant impacts on the

ecological integrity of the SPA.

18.M Thursley, Ash, Pirbright & Chobham SAC


ecological integrity of the Thursley, Ash, Pirbright & Chobham SAC has concluded that

overall there would be no potential for ‘likely significant effects’ to arise, subject to the



18.27.1 One of the ILAS (ILAS07) identified under Policy 10 of the Surrey WLP is located

in sufficiently close proximity to a component of the SAC to render it

unsuitable as a location for all scales of thermal treatment plants.






pass through the four SSSIs that together form the SAC.




pathway are summarised in Table 18-K.

Table 18-K: Summary of assessment conclusions


Level

Changes in grazing practices – discussed further in section 13.C.1

No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP

Screening

Changes in forestry and woodland management practices – discussed further in section 13.C.2


Screening


255


Level

Changes in local hydrological conditions – discussed further in section 13.C.3


Screening

Changes in scrub control practices– discussed further in section 13.C.4


Screening

Changes due to the introduction of invasive species – discussed further in section 13.C.5


Screening

Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further in section 13.C.7 & section 13.7

One allocated site (Site 3) and eleven ILAS (ILAS01, ILAS05, ILAS06, ILAS07, ILAS08, ILAS09, ILAS17, ILAS19, ILAS20, ILAS21, ILAS22) located within 10 km of the SAC. Potential for adverse impacts from nutrient nitrogen deposition arising from process emissions (thermal treatment plant) and traffic emissions.

All scales of thermal treatment not recommended at ILAS07.

For all other allocated sites and ILAS thermal treatment may be feasible, subject to project level assessment.

Traffic emissions unlikely to be major source of additional deposition within the SAC – likely to disperse to the wider network.

Overall conclusion of no likely significant impacts on the SAC, subject to implementation of the recommended decision rules (see part B-1, Appendix B) and the requirements of Policy 14 (Development Management) of the Surrey WLP in respect of all applications for planning permission for waste related development.

Assessment of Likely

Significant Effects

(Process Emissions &

Traffic Emissions)

Changes in the incidence of wildfire / arson – discussed further in section 13.C.6


Screening

Changes in the use of the land for military activities – discussed further in section 13.C.8


Screening

Changes due to habitat fragmentation – discussed further in section 13.C.9


Screening

18.29 The further information provided in parts E (paragraphs 11-15, pp.12-13) and H-4

(paragraphs 33-38, pp.20-22) of the appendix to the Statement of Common Ground

between Natural England and Surrey County Council, dated 8 August 2019, does not alter

the conclusions reached by the HRA process in respect of the likely impacts of the Surrey

WLP on the Thursley, Ash, Pirbright & Chobham SAC. That further information provides


256

detailed descriptions of the physical relationship between one proposed allocated site (Site

6 – Trumps Farm, Longcross) and one proposed ILAS (ILAS07 – Land north & south of Lysons

Avenue, Ash Vale) and component parts of the SAC. Those descriptions serve to reinforce

the conclusions reached through the HRA process, that waste development at the allocated

site or the ILAS would not result in significant impacts on the ecological integrity of the SAC.

18.N Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1)

SPA (including Thursley & Ockley Bogs Ramsar Site)


ecological integrity of the Thursley, Hankley & Frensham Commons (Wealden Heaths Phase

1) SPA has concluded that overall there would be no potential for ‘likely significant effects’

to arise.

18.30.1 None of the ILAS identified under Policy 10 of the Surrey WLP are located in

sufficiently close proximity to the SPA to render them unsuitable as potential

locations for small scale thermal treatment plants in isolation.






pass through the SPA.

18.31 The assessment considered the eight impact pathways identified as key threats and



pathway are summarised in Table 18-L.

Table 18-L: Summary of assessment conclusions


Level


public access / disturbance–


14.C.1



WLP

Screening



14.C.2



WLP

Screening



in section 14.C.3



WLP

Screening


257


Level






WLP

Screening






Six ILAS (ILAS06, ILAS07, ILAS08, ILAS19, ILAS20,

ILAS21) located within 10 km of the SPA. Potential




For all ILAS thermal treatment may be feasible,

subject to project level assessment.


additional deposition within the SPA – likely to









Assessment

of Likely

Significant

Effects

(Process

Emissions &

Traffic

Emissions)


location & extent of the



14.C.6



WLP

Screening




14.C.7



WLP Screening






WLP Screening

18.O Wealden Heaths Phase 2 SPA


ecological integrity of the Wealden Heaths Phase 2 SPA has concluded that overall there


under Policy 11 are located within 10 kilometres of the SPA, but two of the ILAS (ILAS20 –

Coxbridge BP, Farnham; and ILAS21 – Farnham TE, Farnham) identified under Policy 10 of

the Surrey WLP are 7.3 kilometres to the north east and 9.7 kilometres to the north west.

The deposit of nutrient nitrogen is not identified in the published SIP as a threat or pressure


258

for the SPA, and therefore the question of the Surrey WLP influence on air quality through

process emissions or traffic emissions did not form part of the assessment.




pathway are summarised in Table 18-M.

Table 18-M: Summary of assessment conclusions


Level





WLP

Screening


location or extent of the

qualifying features –


15.C.2



WLP

Screening




15.C.3



WLP

Screening




15.C.4



WLP

Screening






WLP

Screening

18.P Wimbledon Common SAC


ecological integrity of the Wimbledon Common SAC has concluded that overall there would

be no potential for ‘likely significant effects’ to arise.

18.34.1 One of the sites allocated under Policy 11a (Site 2: Weylands TW, Walton on

Thames) and two of the ILAS (ILAS03; ILAS04) identified under Policy 10 of the




modelling and assessment at the planning application stage..


259






metres of the SAC.




pathway are summarised in Table 18-N.

Table 18-N: Summary of assessment conclusions


Level





16.C.4







and ILAS04.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)




16.C.1



WLP

Screening






WLP

Screening

Changes due to the



section 16.C.3



WLP

Screening


260

18.Q Windsor Forest & Great Park SAC


ecological integrity of the Windsor Forest & Great Park SAC has concluded that overall

there would be no potential for ‘likely significant effects’ to arise.

18.36.1 One of the sites allocated under Policy 11a (Site 1: Oakleaf Farm, Stanwell

Moor) and two of the ILAS (ILAS14; ILAS22) identified under Policy 10 of the




modelling and assessment at the planning application stage.






metres of the SAC.




pathway are summarised in Table 18-O.

Table 18-O: Summary of assessment conclusions


Level


woodland management (oak)


17.C.1



WLP

Screening


woodland management

(beech) – discussed further in

section 17.C.2



WLP

Screening

Changes due to the



section 17.C.3



WLP

Screening

Changes due to the incidence

of plant disease – discussed




WLP

Screening


261


Level





17.C.5







and ILAS22.











Screening

(Traffic

Emissions)

Assessment

of Likely

Significant

Effects

(Process

Emissions)

Habitat Regulations Assessment Report€¦ · Chapter 11 South West London Waterbodies SPA& Ramsar Site 120 Chapter 12 Thames Basin Heaths SPA 135 Chapter 13 Thursley, Ash, Pirbright

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