Upload
others
View
0
Download
0
Embed Size (px)
Citation preview
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
This page has been left intentionally blank
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
1
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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
2
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
3
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
4
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
5
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
6
ILAS identified by the Surrey WLP
SPAs & SACs located within 10km
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
7
ILAS identified by the Surrey WLP
SPAs & SACs located within 10km
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
8
ILAS identified by the Surrey WLP
SPAs & SACs located within 10km
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Further assessment required in respect
of the policy framework & ILAS
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
3.2 km south of Surrey boundary
ILAS19
Further assessment required in respect
of the policy framework & ILAS
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
Further assessment required in respect
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
Further assessment required in respect
of the policy framework, ILAS &
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
Further assessment required in respect
of the policy framework & ILAS
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
6.4 km south of Surrey boundary
No
Further assessment required in respect
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
Further assessment required in respect
of the policy framework, ILAS &
allocated sites
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Site 2 (Weylands TW)
ILAS03; ILAS04
Further assessment required in respect
of the policy framework, ILAS &
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)
Site 6 (Trumps Farm)
ILAS14; ILAS22
Further assessment required in respect
of the policy framework, ILAS &
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
Further assessment required in respect
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)
Further assessment required in respect
of the policy framework & ILAS
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
Within Surrey (partial)
Site 1 (Oakleaf Farm)
Site 2 (Weylands TW)
Site 6 (Trumps Farm)
ILAS01; ILAS02; ILAS03; ILAS14; ILAS15; ILAS16);
ILAS22
Further assessment required in respect
of the policy framework, ILAS &
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
Within Surrey (partial)
Site 2 (Weylands TW)
Site 3 (Slyfield IE)
Site 4 (Leatherhead STW)
Site 6 (Trumps Farm)
ILAS01; ILAS02; ILAS03; ILAS05 ILAS06; ILAS07; ILAS08; ILAS09; ILAS14; ILAS15; ILAS16; ILAS17; ILAS20; ILAS21; ILAS22
Further assessment required in respect
of the policy framework, ILAS &
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
Further assessment required in respect
of the policy framework & ILAS
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
Within Surrey (partial)
ILAS21
Further assessment required in respect
of the policy framework & ILAS
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
ILAS11;ILAS12;ILAS13
ILAS14
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
2.18 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
2.20 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
2.23 Screening Evaluation: There is no mechanism by which the forms of development covered
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).
2.24 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
21
2.27 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
2.28 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 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.”
2.30 The actions that have been identified as the principal means of addressing the threat are
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
2.39 The actions that have been identified as the principal means of addressing the
pressure/threat are concerned with further investigation of the impact of light pollution on
the resident bat species.
2.40 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
24
2.41 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 the SAC as a consequence of
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – see section
2.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in land management
– see section 2.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 2.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in public access
/disturbance – see section
2.C.6
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
26
Chapter 3 Woolmer Forest SAC
3.A Geographic & Development Context
3.A.1 Location of the 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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
27
Figure 3-A: Woolmer Forest SAC – Relationship to sites & ILAS proposed by the Surrey WLP
3.5 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 5 kilometres of the SAC.
None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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
reasons for its designation, is described as follows in the published citation.
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
Site 4: Leatherhead STW
ILAS20
ILAS21
ILAS19
ILAS05; ILAS06;ILAS08;
ILAS07; ILAS17
ILAS01; ILAS09;ILAS10; ILAS15;ILAS22
ILAS02; ILAS03; ILAS04; ILAS11; ILAS16
ILAS12; ILAS13
ILAS14
ILAS18
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:
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)
3.B.2 Conservation Objectives
3.7 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
3.8 Based on the information published by Natural England in the most recent condition survey
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 20 82.61 ha Lowland dwarf shrub heath habitat
Unit 27 62.84 ha Lowland dwarf shrub heath 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
Unit 22 26.83 ha Lowland dwarf shrub heath habitat
Unit 23 53.04 ha Lowland dwarf shrub heath habitat
Unit 24 22.55 ha Lowland dwarf shrub heath habitat
Unit 25 42.35 ha Lowland dwarf shrub heath habitat
Unit 26 54.79 ha Lowland dwarf shrub heath habitat
Unit 28 38.91 ha Lowland dwarf shrub heath 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C Identification of Impact Pathways & Screening Evaluation
3.10 The published Site Improvement Plan (SIP) for the SAC (23 October 2014) for identifies the
following key pressures and threats to the site’s ecological integrity.
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.C.1 Change in land management
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
3.12 The actions that have been identified as the principal means of addressing the threat are
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.
3.13 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
3.14 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 land management practices
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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
3.17 Screening Evaluation: There is no mechanism by which the forms of development covered
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).
3.18 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 the SAC as a consequence of
the introduction of invasive plant species. No further assessment is required in respect of
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.”
3.20 The actions that have been identified as the principal means of addressing the pressure are
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.
3.21 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
33
3.22 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 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.”
3.24 The actions that have been identified as the principal means of addressing the pressure are
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.
3.26 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 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:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
3.28 The actions that have been identified as the principal means of addressing the pressure are
concerned with preparing and implementing integrated management plans for military
training areas.
3.29 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
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.
3.30 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 the SAC with reference to the
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.”
3.32 The actions that have been 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.
3.33 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
3.36 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
36
3.37 In terms of the potential for diffuse emissions, traffic generated by waste related
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.
3.38 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. 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).
3.39 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). 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
3.41 The actions that have been identified as the principal means of addressing the threat are
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.
3.42 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
3.44 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 fire management practices
within the SAC, and although waste related development could, in theory, present a fire
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
3.51 The assessment of the implications of the implementation of the Surrey WLP for the
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
40
Table 3-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in land management
practices – discussed in
section 3.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – discussed
in section 3.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in local hydrology –
discussed in section 3.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the location,
extent and condition of the
features for which the SAC is
designated – discussed in
section 3.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in military use of the
land – discussed in section
3.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
3.F References
3.53 The following sources of information have been referred to as part of the assessment
process for the Woolmer Forest SAC.
3.53.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Woolmer Forest
SAC (Natural England (English Nature), May 2005).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
41
3.53.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& 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
Conservation (Site Code: UK0030304) (Natural England, 30 June 2014, v.2).
3.53.4 Site Improvement Plan: Woolmer Forest SAC & Wealden Heaths Phase 2 SPA
(Natural England, 23 October 2014).
3.53.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
3.53.6 Woolmer Forest SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
3.53.7 Environment Agency Catchment Data Explorer website.
3.53.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
3.53.9 Habitat Regulations Assessment for the emerging Local Plan, URS for East
Hampshire District Council, 2012 and 2013
3.53.10 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 2018.
3.53.11 Design Manual for Roads & Bridges, Volume 11 (Environmental Assessment),
Section 7 (Environmental Assessment Techniques), Highways England, May
2007.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
43
This page is left intentionally blank
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
44
Chapter 4: Ashdown Forest SAC
4.A Geographic & Development Context
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
45
Figure 4-A: Ashdown Forest SAC – Relationship to sites & ILAS proposed by the Surrey WLP
4.5 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 5 kilometres of the SAC.
None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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.
4.B Key Characteristics of the SAC
4.B.1 Reasons for Designation 4.6 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: 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 4: Leatherhead STW
Site 2: Weylands TWSite 3: Slyfield IE
Site 1: Oakleaf FarmSite 6: Trumps Farm
ILAS04
ILAS19
ILAS10 ILAS13ILAS12
ILAS21ILAS20
ILAS08
ILAS07; ILAS14; ILAS17
ILAS01; ILAS02;ILAS03; ILAS05;ILAS06; ILAS09;ILAS15; ILAS16;ILAS22
ILAS11
20 km
30 km
50 km
40 km
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Northern Atlantic wet heaths with Erica tetralix. (Wet heathland with cross-leaved heath)
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; &
The distribution of qualifying species within the site.
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Condition Classification
Favourable Unfavourable –
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
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable –
Declining
Broadleaved, Mixed & Yew Woodland –
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.C Identification of Impact Pathways & Screening Evaluation
4.11 The published Site Improvement Plan (SIP) (24 November 2014) for the SAC identifies the
following key pressures and threats to the site’s ecological integrity.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C.1 Change in land management
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.
4.15 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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 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.
4.17 Screening Conclusion: The implementation of the Surrey WLP, including through the
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
49
4.C.2 Air pollution: impact of atmospheric nitrogen deposition
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
of the identified pressure:
“Nitrogen deposition exceeds site relevant critical loads. Vegetation is becoming increasingly
grass dominated where previously it was heather dominated.”
4.19 The actions that have been identified as the principal means of addressing the pressure are
concerned with controlling and reducing nitrogen emissions and the deposition of nitrogen,
and with ameliorating the impacts of that deposition.
4.20 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.
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.
4.23 It is possible that proposals for waste related development could be brought forward on
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
50
4.24 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 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
(Waste Local Plan – Transport Study: Site Assessments, Table 9.1, p.54). Section 9.3 (p.55)
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).
4.26 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 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.C.2 Hydrological changes
4.27 The feature affected is the wet heathland with cross-leaved heath (H4010). The SIP (p.5/9)
offers the following explanation of the nature of the identified threat:
“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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
51
4.28 The actions that have been identified as the principal means of addressing the threat are
concerned with the undertaking of surveys and analyses of the sites hydrological and
botanical conditions.
4.29 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
4.30 Screening Conclusion: The implementation of the Surrey WLP, including through the
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
4.34 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ashdown 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 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
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 4-C.
Table 4-C: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
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
Changes in air pollution
(deposition of atmospheric
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.
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.
Screening
(Traffic
Emissions)
Assessment of
Likely
Significant
Effects (Process
Emissions)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
53
4.F References
4.36 The following sources of information have been referred to as part of the assessment
process for the Ashdown Forest SAC.
4.36.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Ashdown Forest
SAC (Natural England (English Nature), May 2005).
4.36.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Ashdown Forest SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
4.36.3 European Site Conservation Objectives for Ashdown Forest Special Area of
Conservation (Site Code: UK0030080) (Natural England, 30 June 2014, v.2).
4.36.4 Site Improvement Plan: Ashdown Forest SAC & SPA (Natural England, 24
November 2014).
4.36.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
4.36.6 Ashdown Forest SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
4.36.7 Environment Agency Catchment Data Explorer website.
4.36.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
4.36.9 Our Local Plan: 2033 (Regulation 19), Tandridge District Council, June 2018
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
lie wholly or partly within the county of Surrey, and none of which are fed by upstream
catchments that are situated in Surrey.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
55
Figure 5-A: Ashdown Forest SPA – Relationship to sites & ILAS proposed by the Surrey WLP
5.5 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 SPA.
None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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
adversely affected by their implementation.
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 4: Leatherhead STW
Site 2: Weylands TWSite 3: Slyfield IE
Site 1: Oakleaf FarmSite 6: Trumps Farm
ILAS04
ILAS19
ILAS10 ILAS13ILAS12
ILAS21ILAS20
ILAS08
ILAS07; ILAS14; ILAS17
ILAS01; ILAS02;ILAS03; ILAS05;ILAS06; ILAS09;ILAS15; ILAS16;ILAS22
ILAS11
20 km
30 km
40 km
50 km
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.B.2 Conservation Objectives
5.7 The published conservation objectives for the SPA 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 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
5.8 Based on the information published by Natural England in the most recent condition survey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
57
Table 5-A: Ashdown Forest SSSI – Condition Survey Findings
Main Habitat Type
Condition Classification
Favourable Unfavourable –
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%)
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.C Identification of Impact Pathways & Screening Evaluation
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
5.13 The actions that have been identified as the principal means of addressing the pressure are
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.
5.14 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
5.15 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 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
5.16 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ashdown Forest SPA 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
59
Table 5-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in public access
/disturbance – see section
5.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
5.E References
5.18 The following sources of information have been referred to as part of the assessment
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
Sites website, accessed 30 May 2018).
5.18.6 Environment Agency Catchment Data Explorer website.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
60
Chapter 6 East Hampshire Hangers SAC
6.A Geographic & Development Context
6.A.1 Location of the 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
61
6.3 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.
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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
62
Figure 6-A: East Hampshire Hangers SAC – Relationship to sites & ILAS proposed by the Surrey WLP
6.B Key Characteristics of the SAC
6.B.1 Reasons for Designation 6.7 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
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
ILAS01; ILAS10;ILAS14; ILAS15
ILAS02; ILAS03;ILAS04; ILAS16
ILAS12;ILAS11
ILAS18
ILAS13
50 km
40 km
30 km
20 km
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
63
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:
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.
6.B.2 Conservation Objectives 6.8 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
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
64
6.B.3 Condition
6.9 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable –
No Change Unfavourable –
Declining
Broadleaved, Mixed & Yew Woodland –
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C Identification of Impact Pathways & Screening Evaluation
6.14 The published Site Improvement Plan (SIP) (12 December 2014) for the SAC identifies the
following key pressures and threats to the site’s ecological integrity.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C.1 Air pollution: impact of atmospheric nitrogen deposition
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:
“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 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.
6.18 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.
6.19 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
67
6.21 It is possible that proposals for waste related development could be brought forward on
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.
6.22 In terms of the potential for diffuse emissions, traffic generated by waste related
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.
6.23 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 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.
6.24 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
6.25 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 diffuse sources (traffic arising from waste related
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.”
6.27 The actions identified as the principal means of addressing the pressure are concerned with
removal of the non-native ivy, and improvement in the long-term management of the
affected woodland.
6.28 Screening Evaluation: There is no mechanism by which the forms of development covered
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).
6.29 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 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.
6.C.3 Forestry & woodland management
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
following explanation of the nature of the identified pressure:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
6.31 The actions identified as the principal means of addressing the pressure are concerned with
further investigation of the causes of unfavourable condition, and with the development
and implementation of a woodland management plan.
6.32 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.
6.33 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 (<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.
6.34 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 affect the condition of
those habitats. No further assessment is required in respect of the changes in forestry and
woodland management impact pathway.
6.D Assessment of significant effects
6.35 The screening assessment has identified a single pathway (air pollution – atmospheric
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
nutrient nitrogen deposition within the SAC, and traffic arising from development within
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.
6.39 The assessment considered the three 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 6-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
71
Table 6-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 6.C.1
& 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.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
Changes in forestry &
woodland management – see
section 6.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – see section
6.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
6.F References
6.40 The following sources of information have been referred to as part of the assessment
process for the East Hampshire Hangers SAC.
6.40.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – East Hampshire
Hangers SAC (Natural England (English Nature), May 2005).
6.40.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – East Hampshire Hangers SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
72
6.40.4 Site Improvement Plan: East Hampshire Hangers SAC (Natural England, 24
November 2014).
6.40.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
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
website, accessed 30 May 2018).
6.40.8 Selborne Common SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
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
(Natural England, Designated Sites website, accessed 30 May 2018).
6.40.11 Wealden Edge Hangers SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
6.40.12 Wick Wood & Worldham Hangers SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
6.40.13 Environment Agency Catchment Data Explorer website.
6.40.14 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
6.40.15 Habitat Regulations Assessment for the emerging Local Plan, URS for East
Hampshire District Council, 2012 and 2013
6.40.16 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 2018.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
73
Chapter 7 Ebernoe Common SAC
7.A Geographic & Development Context
7.A.1 Location of the 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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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.
7.5 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 5 kilometres of the SAC.
None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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
adversely affected by their implementation.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
74
Figure 7-A: Ebernoe Common SAC – Relationship to sites & ILAS proposed by the Surrey WLP
7.B Key Characteristics of the SAC
7.B.1 Reasons for Designation
7.6 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
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 1: Oakleaf Farm
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
ILAS01; ILAS02;ILAS15; ILAS22
ILAS03; ILAS14;ILAS16
ILAS04; ILAS11;ILAS12; ILAS13
20 km
30 km
40 km
50 km
Site 5: Lambs BP
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
75
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 & 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
Bechstein’s bat Myotis bechsteinii
7.B.2 Conservation Objectives 7.7 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
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
7.B.3 Condition 7.8 Based on the information published by Natural England in the most recent condition survey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
76
Table 7-A: Ebernoe Common SAC – Condition Survey Findings
Main Habitat Type
Condition Classification
Favourable Unfavourable –
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
following key pressures and threats to the site’s ecological integrity.
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.C.1 Forestry & woodland management
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.”
7.11 The actions that have been identified as the principal means of addressing the
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
77
7.12 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.
7.13 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 (<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.
7.14 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 affect the condition of
those habitats. No further assessment is required in respect of the changes in forestry and
woodland management impact pathway.
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.”
7.16 The actions that have been identified as the principal means of addressing the pressure are
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.
7.17 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
7.18 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
7.19 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 the SAC with reference to the
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.”
7.21 The actions that have been identified as the principal means of addressing the threat are
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.
7.22 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
7.23 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
79
7.24 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 the SAC with reference to
habitat fragmentation. No further assessment is required in respect of the offsite habitat
availability / management impact pathway.
7.C.4 Change in land management
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.”
7.26 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.
7.27 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future land management practices within
or around the SAC.
7.28 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
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.
7.29 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 land management practices
within the SAC or the surrounding area. No further assessment is required in respect of the
changes in land management impact pathway.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
80
7.C.5 Hydrological changes
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.”
7.31 The actions that have been identified as the principal means of addressing the threat are
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.
7.32 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
7.33 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 the hydrology of the SAC. No
further assessment is required in respect of the changes in hydrology impact pathway.
7.C.6 Air pollution: impact of atmospheric nitrogen deposition
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:
“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.”
7.35 The actions that have been identified as the principal means of addressing the threat are
concerned with further investigation of the potential impacts of atmospheric nitrogen
deposition on the site.
7.36 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
81
thermal treatment technologies to dispose of waste and recover energy), and vehicle
movements associated with the construction and operation of waste facilities.
7.37 In terms of the potential for emissions from waste management facilities 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 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.
7.40 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 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
(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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
7.43 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 diffuse sources (traffic arising from waste related
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.C.7 Public access / disturbance
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.”
7.45 The actions that have been identified as the principal means of addressing the
pressure/threat are concerned with further investigation of the impact of light pollution on
the resident populations of bat species.
7.46 Screening Evaluation: There is no mechanism by which the forms of development covered
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
7.47 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 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.
7.D Assessment of significant effects
7.48 The screening assessment has identified a single pathway (air pollution – atmospheric
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
7.51 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ebernoe 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 (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
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 ILAS19 is
unsuitable for such development (subject to the conclusions of any project level
assessment).
7.52 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 7-B.
Table 7-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in forestry and
woodland management
practices – discussed further
in section 7.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in off-site habitat
availability– discussed further
in section 7.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to habitat
fragmentation – discussed
further in section 7.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
85
Impact Pathway Conclusion Assessment
Level
Changes in land management
practices – discussed further
in section 7.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in local hydrological
conditions – discussed further
in section 7.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 7.C.6
& section 7.D
One ILAS (ILAS19) 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 ILAS19.
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.
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
7.F References
7.53 The following sources of information have been referred to as part of the assessment
process for the Ebernoe Common SAC.
7.53.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Ebernoe Common
SAC (Natural England (English Nature), May 2005).
7.53.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Ebernoe Common SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
7.53.3 European Site Conservation Objectives for Ebernoe Common Special Area of
Conservation (Site Code: UK0012715) (Natural England, 30 June 2014, v.2).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
86
7.53.4 Site Improvement Plan: Ebernoe Common SAC (Natural England, 6 March
2015).
7.53.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
7.53.6 Ebernoe Common SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
7.53.7 Environment Agency Catchment Data Explorer website.
7.53.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
7.53.9 Habitat Regulations Assessment for the emerging Local Plan, URS for
Chichester District Council, May 2014
7.53.10 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 2018.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
87
Chapter 8 Mole Gap to Reigate Escarpment SAC
8.A Geographic & Development Context
8.A.1 Location of the 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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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 4: Leatherhead STW
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
ILAS01; ILAS14;ILAS15; ILAS22
ILAS02; ILAS03; ILAS16
ILAS05;ILAS06;ILAS08
ILAS07 ILAS09
ILAS17
ILAS19
ILAS20 ILAS21
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
8.B Key Characteristics of the SAC
8.B.1 Reasons for Designation 8.6 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
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
90
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:
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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:
Bechstein’s bat Myotis bechsteinii.
Great crested newt Triturus cristatus.
8.B.2 Conservation Objectives 8.7 The published conservation objectives for the SAC are given below.
Conservation Objectives
“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;
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
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
8.B.3 Condition 8.8 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable – No
Change
Broadleaved, Mixed & Yew Woodland –
Lowland
671.10 ha 323.77 ha
[48.2% of the habitat]
347.33 ha
[51.8% of the habitat]
0.0 ha
[0.0% of the habitat]
Calcareous Grassland –
Lowland 312.80 ha
180.27 ha
[57.6% of the habitat]
127.40 ha
[40.7% of the habitat]
5.13 ha
[1.6% of the habitat]
Earth Heritage 2.06 ha 2.06 ha
[100.0% of the habitat]
0.0 ha
[0.0% of the habitat]
0.0 ha
[0.0% of the habitat]
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
92
8.C Identification of Impact Pathways & Screening Evaluation
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;
Changes in the incidence of public access / disturbance – discussed further in section
8.C.4;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
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.”
8.12 The actions that have been identified as the principal means of addressing the
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
8.14 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 the SAC as a consequence of
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.”
8.16 The actions that have been identified as the principal means of addressing the pressure are
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
8.17 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
94
8.18 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 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.”
8.20 The actions that have been identified as the principal means of addressing the threat are
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.
8.21 Screening Evaluation: There is no mechanism by which the forms of development covered
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 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.
8.22 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 land management practices
on the SAC. No further assessment is required in respect of the changes in land
management impact pathway.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
95
8.C.4 Public access / disturbance
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.
8.25 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
8.26 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
96
8.C.5 Air pollution: impact of atmospheric nitrogen deposition
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:
“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.”
8.28 The actions that have been identified as the principal means of addressing the threat are
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
8.33 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 local or
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.
8.D Assessment of significant effects
8.35 The screening assessment has identified a single pathway (air pollution – atmospheric
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,
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
8.42 The assessment of the implications of the implementation of the Surrey WLP for the
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
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 8-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
101
Table 8-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes arising from the
incidence of plant disease
(box blight) – discussed
further in section 8.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 8.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in land management
practices – discussed further
in section 8.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
8.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
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.
All scales of thermal treatment not recommended
at Site 4, ILAS10, ILAS11, ILAS12 and ILAS13.
Small scale (<50,000 tpa) feasible at Site 5 and
ILAS04.
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)
8.F References
8.44 The following sources of information have been referred to as part of the assessment
process for the Mole Gap to Reigate Escarpment SAC.
8.44.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Mole Gap to
Reigate Escarpment SAC (Natural England (English Nature), May 2005).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
102
8.44.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – 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).
8.44.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
8.44.6 Mole Gap to Reigate Escarpment SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
8.44.7 Environment Agency Catchment Data Explorer website.
8.44.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
8.44.9 Surrey Waste Local Plan: Air Quality Impact Assessment, AECOM for Surrey
County Council, June 2018
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
103
Chapter 9 Richmond Park SAC
9.A Geographic & Development Context
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
boundary of the SAC.
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).
The Plan does not specify the type or scale of waste related development that could be
accommodated on the identified ILAS.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
kilometres to the south west of the SAC.
ILAS03 (Molesey Industrial Estate, Central Avenue, West Molesey), which is located 6.7
kilometres to the south west of the SAC.
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
adversely affected by their implementation.
<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 4: Leatherhead STW
Site 5: Lambs BPILAS01; ILAS15
ILAS05; ILAS06;ILAS09; ILAS22
ILAS07; ILAS08 ILAS10
ILAS14
ILAS11; ILAS12; ILAS13
ILAS17
ILAS18
ILAS19
ILAS20;ILAS21
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
105
9.B Key Characteristics of the SAC
9.B.1 Reasons for Designation 9.6 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
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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:
Stag beetle Lucanus cervus
9.B.2 Conservation Objectives 9.7 The published conservation objectives for the SAC are given below.
Conservation Objectives
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 extent & distribution of qualifying natural habitats & habitats of qualifying species;
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;
The distribution of qualifying species within the site.
Qualifying Features
S1083. Lucanus cervus; Stag beetle
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
106
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
107
9.B.3 Condition 9.8 Based on the information published by Natural England in the most recent condition survey
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
Broadleaved, mixed & yew woodland – lowland
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.C Identification of Impact Pathways & Screening Evaluation
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
9.11 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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 London.
9.12 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 habitat management
practices within the SAC, and therefore would not affect the condition of those habitats. No
further assessment is required.
9.D Conclusions
9.13 The assessment of the implications of the implementation of the Surrey WLP for the
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
9.15 The following sources of information have been referred to as part of the assessment
process for the Richmond Park SAC.
9.15.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Richmond Park SAC
(Natural England (English Nature), May 2005).
9.15.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Richmond Park SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
9.15.3 European Site Conservation Objectives for Richmond Park Special Area of
Conservation (Site Code: UK0030246) (Natural England, 30 June 2014, v.2).
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.
9.15.6 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
9.15.7 Richmond Park SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
9.15.8 Environment Agency Catchment Data Explorer website.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
110
Chapter 10 Shortheath Common SAC
10.A Geographic & Development Context
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.
The Plan does not specify the type or scale of waste related development that could be
accommodated on the identified ILAS.
10.5 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
10.B Key Characteristics of the Designated Site
10.B.1 Reasons for Designation 10.7 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
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 4: Leatherhead STW
Site 6: Trumps
Farm
Site 3: Slyfield IE
Site 5: Lambs BP
ILAS07
ILAS17
ILAS21
ILAS19
ILAS10
ILAS11; ILAS12;ILAS13; ILAS18
ILAS05; ILAS06;ILAS08
ILAS01;ILAS09;ILAS15;ILAS22
ILAS02; ILAS03;ILAS04; ILAS14;ILAS16
20 km
30 km
40 km
50 km
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:
Bog woodland* (Priority Habitat)
European dry heaths
Transition mires & quaking bogs. (Very wet mires often identified by an unstable ‘quaking’ surface)
10.B.2 Conservation Objectives 10.8 The published conservation objectives for the SAC are given below.
Conservation Objectives
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 extent & distribution of qualifying natural habitats & habitats of qualifying species;
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;
The distribution of qualifying species within the site.
Qualifying Features
H4030. European dry heaths
H7140. Transition mires & quaking bogs; Very wet mires often identified by an unstable `quaking` surface
H91D0. Bog woodland* (Annex I Priority habitat)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
113
10.B.3 Condition 10.9 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Unfavourable – Recovering
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.C Identification of Impact Pathways & Screening Evaluation
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
114
Changes in scrub control practices– discussed further in section 10.C.1;
Changes in the incidence of public access / disturbance – discussed further in section
10.C.2;
Changes due to direct encroachment onto the land by a third party (householder) –
discussed further in section 10.C.3;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
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.”
10.13 The actions that have been identified as the principal means of addressing the pressure are
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).
10.14 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future scrub control practices within the
SAC.
10.15 The only points at which the scrub control 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 scrub management (e.g. green waste from
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.
10.16 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
115
10.C.2 Public access / disturbance
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.”
10.18 The actions that have been identified as the principal means of addressing the threat are
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.
10.19 Screening Evaluation: There is no mechanism by which the forms of development covered
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 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
residential development.
10.20 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 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.
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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
116
10.22 The actions that have been identified as the principal means of addressing the pressure are
concerned with the undertaking of education activities for householders, and the use of
enforcement action where necessary.
10.23 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
10.24 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 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.C.4 Air pollution: impact of atmospheric nitrogen deposition
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)
offers the following explanation of the nature of the identified threat:
“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.”
10.26 The actions that have been 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.
10.27 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.
10.28 In terms of the potential for emissions from waste management facilities 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
10.30 It is 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. 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.
10.31 In terms of the potential for diffuse emissions, traffic generated by waste related
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.
10.32 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 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
118
10.33 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 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.
10.34 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 diffuse sources (traffic arising from waste related
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).
10.D Assessment of significant effects
10.35 The screening assessment has identified a single pathway (air pollution – atmospheric
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
accommodated on the identified ILAS.
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
10.38 The assessment of the implications of the implementation of the Surrey WLP for the
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
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 10-B.
Table 10-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in scrub control
practices– discussed further
in section 10.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
10.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to direct
encroachment onto the land
by a third party (householder)
– discussed further in section
10.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
120
Impact Pathway Conclusion Assessment
Level
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 10.C.4
& section 10.D
One ILAS (ILAS20) 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.
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.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
10.F References
10.40 The following sources of information have been referred to as part of the assessment
process for the Shortheath Common SAC.
10.40.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Shortheath
Common SAC (Natural England (English Nature), May 2005).
10.40.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Shortheath Common SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
10.40.3 European Site Conservation Objectives for Ashdown Forest Special Area of
Conservation (Site Code: UK0030080) (Natural England, 30 June 2014, v.2).
10.40.4 Site Improvement Plan: Shortheath Common SAC (Natural England, 12
December 2014).
10.40.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
10.40.6 Shortheath Common SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
10.40.7 Environment Agency Catchment Data Explorer website.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
121
10.40.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
10.40.9 Habitat Regulations Assessment for the emerging Local Plan, URS for East
Hampshire District Council, 2012 and 2013
10.40.10 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 2018.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
122
Chapter 11 South West London Waterbodies SPA & Ramsar Site
11.A Geographic & Development Context
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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).
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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
125
Figure 11-A: South West London Waterbodies SPA – Relationship to sites & ILAS proposed by the
Surrey WLP
11.B Key Characteristics of the Designated Site
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
its designation, is described as follows in the published citation.
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 1: Oakleaf Farm
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
ILAS11;ILAS12;ILAS13
ILAS18
ILAS19
ILAS20;ILAS21
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Conservation Objectives
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 supporting processes on which the habitats of the qualifying features rely
The population of each of the qualifying features, and,
The distribution of the qualifying features within the site.
Qualifying Features
A051 Anas strepera; Gadwall (Non-breeding)
A056 Anas clypeata; Northern shoveler (Non-breeding)
11.B.3 Condition 11.10 Based on the information published by Natural England in the most recent condition survey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Condition Classification
Favourable Unfavourable –
Recovering
Standing open water & canals 814.19 ha
(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.C Identification of Impact Pathways & Screening Evaluation
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.
Changes in the incidence of public access / disturbance – discussed further in section
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
identified pressure/threat:
“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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
11.14 Screening Evaluation: There is no mechanism by which the forms of development covered
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
framework within which development consent decisions can be made in respect of future
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-
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
11.16 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
framework within which development consent decisions can be made in respect of future
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
development of the sites allocated under Policy 11 or the ILAS identified under Policy 10,
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
the following explanation of the nature of the identified pressure/threat:
“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.”
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
131
11.22 The actions that have been identified as the principal means of addressing the
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.
11.23 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
11.24 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 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 following explanation of the nature of the identified pressure/threat:
“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).”
11.26 The actions that have been identified as the principal means of addressing the
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.
11.27 Screening Evaluation: There is no mechanism by which the forms of development covered
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
11.28 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 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
identified pressure/threat:
“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.”
11.30 The actions that have been identified as the principal means of addressing the
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.
11.31 Screening Evaluation: 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. 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.
11.32 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
11.34 The actions that have been identified as the principal means of addressing the
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.
11.35 Screening Evaluation: 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. There is no mechanism by which
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.
11.36 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 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.”
11.38 The actions that have been identified as the principal means of addressing the
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
134
11.39 Screening Evaluation: 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. There is no mechanism by which
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.
11.40 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 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
11.41 The assessment of the implications of the implementation of the Surrey WLP for the
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.
11.42 The assessment considered the seven impact pathways identified as key threats and
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.
Table 11-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance –
discussed further in section
11.C.1
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
135
Impact Pathway Conclusion Assessment
Level
Changes in species
distribution – discussed
further in section 11.C.2
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes due to the
introduction of invasive
species (Crassula helmsii) –
discussed further in section
11.C.3
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes arising from the
natural maturation of
wetland habitats– discussed
further in section 11.C.4
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes in fish stocking
densities and practices –
discussed further in section
11.C.5
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes in waterweed
control practices – discussed
further in section 11.C.6
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes arising from the
incursion of invasive species
(Egyptian geese) – discussed
further in section 11.C.7
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
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.
11.44.1 EC Directive 79/409 on the Conservation of Wild Birds: Citation for Special
Protection Area (SPA) – South West London Waterbodies SPA (Natural England
(English Nature), September 2000).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Conservation Committee (JNCC), 25 January 2016).
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,
Designated Sites website, accessed 30 May 2018).
11.44.7 Knight & Bessborough Reservoirs SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
11.44.8 Staines Moor SSSI Condition Survey Report (Natural England, Designated Sites
website, accessed 30 May 2018).
11.44.9 Thorpe Park No. Gravel Pit SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
11.44.10 Wraysbury & Hythe End Gravel Pits SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
11.44.11 Wraysbury No. Gravel Pit SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
11.44.12 Wraysbury Reservoir SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
11.44.13 Environment Agency Catchment Data Explorer website.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
137
Chapter 12 Thames Basin Heaths SPA
12.A Geographic & Development Context
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Site 2 (Land at the former Weylands Treatment Works, Molesey Road, Walton on
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
component of the SPA.
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.
ILAS01 (Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park,
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
component of the SPA.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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 1: Oakleaf Farm
Site 5: Lambs BPILAS08
ILAS05
ILAS07 ILAS09
ILAS17
ILAS05
ILAS15
Site 2: Weylands TW
Site 4:Leatherhead
STW
ILAS01
ILAS02;ILAS03;ILAS14
ILAS04
ILAS16
ILAS20
ILAS06
N
S
W E
20 km
30 km
40 km
ILAS22
ILAS21
ILAS10
ILAS11
ILAS12;ILAS13
ILAS18
ILAS19
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
141
12.5 None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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.
12.B Key Characteristics of the SPA
12.B.1 Reasons for Designation 12.6 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 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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
142
12.B.2 Conservation Objectives
12.7 The published conservation objectives for the SPA are given below.
Conservation Objectives
“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;
The distribution of the qualifying features within the site.
Qualifying Features
A224 Caprimulgus europaeus; European nightjar (Breeding)
A246 Lullula arborea; Woodlark (Breeding)
A302 Sylvia undata; Dartford warbler (Breeding)
12.B.3 Condition
12.8 Based on the information published by Natural England in the most recent condition survey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
143
Table 12-A: Thames Basin Heaths SPA complex of SSSIs – Condition Survey Findings
Main Habitat Type
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable –
No Change Unfavourable –
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Reasons for adverse condition: Lack of corrective works - inappropriate scrub control
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.
Reasons for adverse condition: Lack of corrective works - inappropriate scrub control
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
12.10 For the 32.00 hectares of lowland dwarf shrub heath habitat classified as exhibiting
‘unfavourable – no change’ condition across the SPA, the condition survey reports for the
relevant SSSIs provide the following explanations and analyses (see below).
Castle Bottom to Yateley & Hawley Commons SSSI (Hampshire), Unit 8, 5.19 ha, Last surveyed 19/09/13
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
Castle Bottom to Yateley & Hawley Commons SSSI (Hampshire), Unit 10, 2.20 ha, Last surveyed 19/09/13
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.
Reasons for adverse condition: [None given]
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
Reasons for adverse condition: [None given]
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
change’ condition, the condition survey report provides the following explanation and
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
condition survey report provides the following explanation and analysis.
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
change’ condition, the condition survey report provides the following explanation and
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.
Reasons for adverse condition: Lack of corrective works - inappropriate scrub control
12.C Identification of Impact Pathways & Screening Evaluation
12.14 The published Site Improvement Plan (SIP) for the SPA (03 November 2014) identifies the
following key pressures and threats to the site’s ecological integrity.
Changes in the incidence of public access / disturbance – discussed further in section
12.C.1;
Changes in grazing practices – discussed further in section 12.C.2;
Changes in forestry and woodland management practices – discussed further in section
12.C.3
Changes in scrub control practices– discussed further in section 12.C.4;
Changes in the incidence of wildfire / arson – discussed further in section 12.C.5;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
in section 12.C.6;
Changes in the condition, location and extent of the features of qualifying interest –
discussed further in section 12.C.7;
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
identified pressure/threat:
“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.”
12.16 The actions that have been identified as the principal means of addressing the
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.
12.17 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP could result in changes in the number of visitors to the 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 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.
12.18 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 additional visitors to the SPA, 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.
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:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
12.20 The actions that have been identified as the principal means of addressing the pressure are
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.
12.21 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
12.22 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 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
of the identified pressure:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
12.24 The actions that have been identified as the principal means of addressing the pressure are
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.
12.25 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 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.
12.26 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 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.”
12.28 The actions that have been identified as the principal means of addressing the pressure are
concerned with implementing a programme of scrub clearance to reverse effects of
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
151
encroachment of heathland to follow on from investigation of the potential for sustainable
use of the waste arising.
12.29 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future scrub control practices within the
SPA. The only points at which the scrub control 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 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.
12.30 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 scrub management practices
within the SPA, and therefore would not affect the condition of those habitats. No further
assessment is required in respect of the inappropriate scrub control impact pathway.
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.”
12.32 The actions that have been identified as the principal means of addressing the pressure are
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.
12.33 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future fire management practices within
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
12.34 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 fire management practices
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.
12.C.6 Air pollution: impact of atmospheric nitrogen deposition 12.35 The features affected by changes in nutrient nitrogen deposition from the atmosphere are
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 is most likely to be a current
issue at Chobham Common but may represent a chronic adverse impact over the complex as a
whole.”
12.36 The actions that have been identified as the principal means of addressing the
pressure/threat are concerned with controlling and reducing nitrogen emissions and
deposition, and with ameliorating the impacts of that deposition.
12.37 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 SPA. 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.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
ILAS01 (Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park,
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
component of the SPA.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
12.43 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 local or
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
12.46 The actions that have been identified as the principal means of addressing the threat are
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.
12.48 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
12.50 The actions that have been identified as the principal means of addressing the threat are
concerned with completing integrated management plans for all military training sites in
the complex.
12.51 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
either negatively or positively, on the ways in which the Ministry of Defence (MoD)
manages those areas of land that it owns within the SPA 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.
12.52 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 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
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.”
12.54 The actions that have been identified as the principal means of addressing the pressure are
concerned with commissioning a study to identify priorities for habitat management that is
able to ameliorate the effects of habitat fragmentation.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
management facilities would typically be classed as inappropriate development in a Green
Belt context.
12.56 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 the SPA with reference to
habitat fragmentation. No further assessment is required in respect of the habitat
fragmentation impact pathway.
12.D Assessment of significant effects
12.57 The screening assessment has identified a single pathway (air pollution – atmospheric
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)
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 2 exceed the minimum site
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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)
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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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 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.
12.64.2 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 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
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 each
pathway are summarised in Table 12-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
160
Table 12-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance –
discussed further in section
12.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in grazing practices –
discussed further in section
12.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in forestry and
woodland management
practices – discussed further
in section 12.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 12.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
wildfire / arson – discussed
further in section 12.C.5
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
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
impacts from nutrient nitrogen deposition arising
from process emissions (thermal treatment plant)
and traffic emissions.
Large scale (>50,000 tpa) thermal treatment not
recommended on Site 3.
All scales of thermal treatment not recommended
at ILAS05, ILAS07, ILAS17 and ILAS22.
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 SPA, 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)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
161
Impact Pathway Conclusion Assessment
Level
Changes in the condition,
location and extent of the
features of qualifying interest
– discussed further in section
12.C.7
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
12.C.8
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
Changes due to habitat
fragmentation – discussed
further in section 12.C.9
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
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.
12.67.1 EC Directive 79/409 on the Conservation of Wild Birds: Citation for Special
Protection Area (SPA) – Thames Basin Heaths SPA (Natural England (English
Nature), February 2005).
12.67.2 NATURA 2000 – Standard Data Form: Special Protection Areas under the EC
Wild Birds Directive – Thames Basin Heaths SPA (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
12.67.3 European Site Conservation Objectives for Thames Basin Heaths Special
Protection Area (Site Code: UK9012141) (Natural England, 30 June 2014, v.2).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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).
12.67.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
12.67.6 Ash to Brookwood Heaths SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
12.67.7 Bourley & Long Valley SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
12.67.8 Bramshill SSSI Condition Survey Report (Natural England, Designated Sites
website, accessed 30 May 2018).
12.67.9 Broadmoor to Bagshot Woods & Heaths SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
12.67.10 Castle Bottom to Yateley & Hawley Commons SSSI Condition Survey Report
(Natural England, Designated Sites website, accessed 30 May 2018).
12.67.11 Chobham Common SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
12.67.12 Colony Bog & Bagshot Heath SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
12.67.13 Eelmoor Marsh SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
12.67.14 Hazeley Heath SSSI Condition Survey Report (Natural England, Designated Sites
website, accessed 30 May 2018).
12.67.15 Horsell Common SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
12.67.16 Ockham & Wisley Commons SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
12.67.17 Sandhurst to Owlsmoor Bogs & Heaths SSSI Condition Survey Report (Natural
England, Designated Sites website, accessed 30 May 2018).
12.67.18 Whitmoor Common SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
12.67.19 Environment Agency Catchment Data Explorer website.
12.67.20 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
12.67.24 Surrey Waste Local Plan: Statement of Common Ground between Natural
England & Surrey County Council. 8 August 2019. Surrey County Council,
Kingston-upon-Thames.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
164
Chapter 13 Thursley, Ash, Pirbright & Chobham SAC
13.A Geographic & Development Context
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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.
ILAS01 (Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park,
Weybridge; & Byfleet Industrial Estate, Byfleet Road / Oyster Lane, Woking), 6.1
kilometres south east of the Chobham Common SSSI component of the SAC.
ILAS05 (Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford), 4.2
kilometres to the south east of the Ash to Brookwood Heaths SSSI component of the
SAC.
ILAS06 (Woodbridge Meadows Industrial Estate, Guildford), 4.7 kilometres to the
south east of the Ash to Brookwood Heaths SSSI component of the SAC.
ILAS07 (Land north & south of Lysons Avenue, Ash Vale), 0.4 kilometres west of the
Ash to Brookwood Heaths SSSI component of the SAC.
ILAS08 (Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old
Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the Thursley, Hankley &
Frensham Commons SSSI component of the SAC.
ILAS09 (Land at Burnt Common Warehouse, London Road, Send), 7.4 kilometres east
of the Ash to Brookwood Heaths SSSI component of the SAC.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
166
ILAS17 (York Town Industrial Estate, Doman Road / Stanhope Road, Camberley), 4.5
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.
ILAS21 (Farnham Trading Estate (incl. land north of Water Lane), Water Lane,
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
13.5 None of the preferred areas for mineral working identified in the adopted Surrey Minerals
Plan, or the sites allocated in the Aggregates Recycling Joint DPD, are situated within 5
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
their implementation.
<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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
167
13.B Key Characteristics of the SAC
13.B.1 Reasons for Designation 13.6 The ecological interest of the SAC, and the particular habitats and species that are cited as
reasons for its designation, is described as follows in the published citation.
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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following habitats listed in Annex I:
Depressions on peat substrates of the Rhynchosporion
European dry heaths
Northern Atlantic wet heaths with Erica tetralix. (Wet heathland with cross-leaved heath)
13.B.2 Conservation Objectives 3.7 The published conservation objectives for the SAC are given below.
Conservation Objectives
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 extent & distribution of qualifying natural habitats & habitats of qualifying species;
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;
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
168
The populations of qualifying species;
The distribution of qualifying species within the site.
Qualifying Features
H4010. Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath
H4030. European dry heaths
H7150. Depressions on peat substrates of the Rhynchosporion
13.B.3 Condition 13.8 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable –
No Change Unfavourable –
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
169
13.9 For the 7.53 hectares of lowland dwarf shrub heath habitat classified as exhibiting
‘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
Reasons for adverse condition: Lack of corrective works - inappropriate scrub control
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.
Reasons for adverse condition: Lack of corrective works - inappropriate scrub control
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C Identification of Impact Pathways & Screening Evaluation
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.
Changes in grazing practices – discussed further in section 13.C.1;
Changes in forestry and woodland management practices – discussed further in section
13.C.2;
Changes in local hydrological conditions – discussed further in section 13.C.3;
Changes in scrub control practices– discussed further in section 13.C.4;
Changes due to the introduction of invasive species – discussed further in section 13.C.5;
Changes in the incidence of wildfire / arson – discussed further in section 13.C.6;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
in section 13.C.7;
Changes in the use of the land for military activities – discussed further in section 13.C.8;
Changes due to habitat fragmentation – discussed further in section 13.C.9.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
following explanation of the nature of the identified pressure:
“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.”
13.14 The actions that have been identified as the principal means of addressing the pressure are
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.
13.15 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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 SAC 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.
13.16 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 grazing practices within the
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
172
SAC, and therefore would not affect the condition of the heathland habitats. No further
assessment is required in respect of the undergrazing impact pathway.
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
identified pressure:
“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.”
13.18 The actions that have been identified as the principal means of addressing the pressure are
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.
13.19 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. 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
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.
13.20 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 affect the condition of
those habitats. No further assessment is required in respect of the changes in forestry and
woodland management impact pathway.
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
(pp.8/20 to 9/20) offers the following explanation of the nature of the identified pressure:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
13.22 The actions that have been identified as the principal means of addressing the pressure are
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.
13.23 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
13.24 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 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
(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.”
13.26 The actions that have been identified as the principal means of addressing the pressure are
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.
13.27 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future scrub control practices within the
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
174
SAC. The only points at which the scrub control 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 scrub management (e.g. green waste from
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.
13.28 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 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.
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
(p.10/20) offers the following explanation of the nature of the identified pressure:
“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.”
13.30 The actions that have been identified as the principal means of addressing the pressure are
concerned with the preparation and implementation of invasive species control plans for all
sites where these remain a problem or pose a significant threat.
13.31 Screening Evaluation: There is no mechanism by which the forms of development covered
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
interface with waste management operations and practices would be in respect of a need
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.
13.32 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 the SAC in respect of the
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
13.34 The actions that have been identified as the principal means of addressing the pressure are
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.
13.35 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future fire management practices within
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.
13.36 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 fire management practices
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
176
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 is most likely to be a current
issue at Chobham Common but may represent a chronic adverse impact over the complex as a
whole.”
13.38 The actions that have been identified as the principal means of addressing the
pressure/threat are concerned with controlling and reducing nitrogen emissions and
deposition, and with ameliorating the impacts of that deposition.
13.39 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.
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.
ILAS01 (Brooklands Industrial Park, Weybridge; Wintersells Road Industrial Park,
Weybridge; & Byfleet Industrial Estate, Byfleet Road / Oyster Lane, Woking), 6.1
kilometres south east of the Chobham Common SSSI component of the SAC.
ILAS05 (Slyfield Industrial Estate, Moorfield Road & Westfield Road, Guildford), 4.2
kilometres to the south east of the Ash to Brookwood Heaths SSSI component of the
SAC.
ILAS06 (Woodbridge Meadows Industrial Estate, Guildford), 4.7 kilometres to the
south east of the Ash to Brookwood Heaths SSSI component of the SAC.
ILAS07 (Land north & south of Lysons Avenue, Ash Vale), 0.4 kilometres west of the
Ash to Brookwood Heaths SSSI component of the SAC.
ILAS08 (Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old
Portsmouth Road, Peasmarsh), 6.6 kilometres north east of the Thursley, Hankley &
Frensham Commons SSSI component of the SAC.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
177
ILAS09 (Land at Burnt Common Warehouse, London Road, Send), 7.4 kilometres east
of the Ash to Brookwood Heaths SSSI component of the SAC.
ILAS17 (York Town Industrial Estate, Doman Road / Stanhope Road, Camberley), 4.5
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.
ILAS21 (Farnham Trading Estate (incl. land north of Water Lane), Water Lane,
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.
13.42 In terms of the potential for diffuse emissions, traffic generated by waste related
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
178
13.44 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 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). 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.”
13.47 The actions that have been identified as the principal means of addressing the threat are
concerned with completing integrated management plans for all military training sites in
the complex.
13.48 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
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.
13.49 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,
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
179
would not give rise to direct or indirect significant impacts on the SAC with reference to the
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.”
13.51 The actions that have been identified as the principal means of addressing the pressure are
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.
13.53 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 the SAC with reference to
habitat fragmentation. No further assessment is required in respect of the habitat
fragmentation impact pathway.
13.D Assessment of significant effects
13.54 The screening assessment has identified a single pathway (air pollution – atmospheric
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
180
nutrient nitrogen would be emissions from thermal treatment plants and from waste
related traffic.
13.D.1 Emissions from thermal treatment facilities
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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.
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
13.64 The assessment of the implications of the implementation of the Surrey WLP for the
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
observation of a number of decision rules with reference to the development of thermal
treatment facilities.
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.
13.64.2 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 would travel along those parts of the road network that
pass through the four SSSIs that together form the SAC.
13.65 The assessment considered the nine 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 13-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
183
Table 13-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in local hydrological
conditions – discussed further
in section 13.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 13.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the
introduction of invasive
species – discussed further in
section 13.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
wildfire / arson – discussed
further in section 13.C.6
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
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)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
184
Impact Pathway Conclusion Assessment
Level
Changes in the use of the
land for military activities –
discussed further in section
13.C.8
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP Screening
Changes due to habitat
fragmentation – discussed
further in section 13.C.9
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
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
13.67 The following sources of information have been referred to as part of the assessment
process for the Thursley, Ash, Pirbright & Chobham SAC.
13.67.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Thursley, Ash,
Pirbright & Chobham SAC (Natural England (English Nature), May 2005).
13.67.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Thursley, Ash, Pirbright & Chobham SAC (Joint Nature
Conservation Committee (JNCC), 25 January 2016).
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).
13.67.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
185
13.67.6 Condition Survey Report for the Ash to Brookwood Heaths SSSI (Natural
England, Designated Sites website, accessed 30 May 2018).
13.67.7 Condition Survey Report for the Chobham Common SSSI (Natural England,
Designated Sites website, accessed 30 May 2018).
13.67.8 Condition Survey Report for the Colony Bog & Bagshot Heath SSSI (Natural
England, Designated Sites website, accessed 30 May 2018).
13.67.9 Condition Survey Report for the Thursley, Hankley & Frensham Commons SSSI
(Natural England, Designated Sites website, accessed 30 May 2018).
13.67.10 Environment Agency Catchment Data Explorer website.
13.67.11 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
13.67.12 Habitat Regulations Assessment for the emerging Local Plan, URS for East
Hampshire District Council, 2012 and 2013
13.67.13 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 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.
13.67.15 Design Manual for Roads & Bridges, Volume 11 (Environmental Assessment),
Section 7 (Environmental Assessment Techniques), Highways England, May
2007.
13.67.16 Surrey Waste Local Plan: Statement of Common Ground between Natural
England & Surrey County Council. 8 August 2019. Surrey County Council,
Kingston-upon-Thames.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
186
Chapter 14 Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA & Thursley & Ockley Bog Ramsar Site
14.A Geographic & Development Context
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
ILAS08 (Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old
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.
ILAS21 (Farnham Trading Estate (including land north of Water Lane), Water Lane,
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
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 4.1 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.
14.7 None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
188
Figure 14-A: Thursley, Hankley & Frensham Commons (Wealden Heaths Phase 1) SPA –
Relationship to sites & ILAS proposed by the Surrey WLP
14.B Key Characteristics of the SPA
14.B.1 Reasons for Designation 14.8 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
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
Site 4: Leatherhead STW
ILAS18
ILAS05;ILAS09;ILAS22
ILAS17 ILAS01;ILAS15
ILAS10
ILAS14
ILAS16
ILAS02;ILAS03;ILAS04
ILAS11;ILAS12;ILAS13
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.B.2 Conservation Objectives
14.9 The published conservation objectives for the SPA are given below
Conservation Objectives
“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;
The distribution of the qualifying features within the site.
Qualifying Features
A224 Caprimulgus europaeus; European nightjar (Breeding)
A246 Lullula arborea; Woodlark (Breeding)
A302 Sylvia undata; Dartford warbler (Breeding)
14.B.3 Condition
14.10 Based on the information published by Natural England in the most recent condition survey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
190
Table 14-A: Thursley, Hankley & Frensham Commons SSSI – Condition Survey Findings
Main Habitat Type
Condition Classification
Favourable Unfavourable –
Recovering Unfavourable – No
Change
Broadleaved, Mixed & Yew Woodland –
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.C Identification of Impact Pathways & Screening Evaluation
14.12 The published Site Improvement Plan (SIP) for the SPA (3 November 2014) identifies the
following key pressures and threats to the site’s ecological integrity.
Changes in the incidence of public access / disturbance – discussed further in section
14.C.1;
Changes in grazing practices – discussed further in section 14.C.2;
Changes in scrub control practices– discussed further in section 14.C.3;
Changes in the incidence of wildfire / arson – discussed further in section 14.C.4;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
in section 14.C.5;
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
191
Changes in the condition, location and extent of the features of qualifying interest –
discussed further in section 14.C.6;
Changes in the use of the land for military activities – discussed further in section 14.C.7;
Changes due to habitat fragmentation – discussed further in section 14.C.8.
14.C.1 Public access / disturbance
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.
14.15 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP could result in changes in the number of visitors to the 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 (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
residential development.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
192
14.16 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 additional visitors to the SPA, and would therefore not contribute to
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
(pp.6/20 to 8/20) offers the following explanation of the nature of the identified pressure:
“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.”
14.18 The actions that have been identified as the principal means of addressing the pressure are
concerned with:
Implementation of appropriate alternative management where grazing is not practical;
Investigation of possible economic uses of material arising from habitat management
such as biomass to bioenergy;
Development of a heathland management partnership which seeks to share resources,
expertise and equipment in order to increase efficiencies in management delivery;
Production of agreed management plans for key sites which identify priority actions to
improve condition of Natura 2000 features;
Improve long-term management of power line wayleaves with power suppliers to
avoid damaging impacts and improve habitat condition and connectivity.
14.19 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
193
for fallen stock management services, to an extent that demand would exceed the capacity
of existing service providers.
14.21 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 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.
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.”
14.23 The actions that have been identified as the principal means of addressing the pressure are
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.
14.24 Screening Evaluation: There is no mechanism by which the forms of development covered
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
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 scrub management (e.g. green waste from
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.
14.26 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 scrub control practices within
the SPA, 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.“
14.28 The actions that have been identified as the principal means of addressing the threat are
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.
14.29 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future fire management practices within
the SPA.
14.30 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
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.
14.31 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 fire management practices
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
195
within the SPA, and although waste related development could, in theory, present a fire risk
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.C.5 Air pollution: impact of atmospheric nitrogen deposition
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.”
14.33 The actions that have been 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.
14.34 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 SPA. 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.
14.35 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
ILAS08 (Riverwey Industrial Estate, Astolat Business Park & Weyvern Park, Old
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.
ILAS21 (Farnham Trading Estate (incl. land north of Water Lane), Water Lane,
Farnham), 5.0 kilometres north of the SPA.
14.37 In terms of the potential for diffuse emissions, traffic generated by waste related
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).
14.38 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 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). 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
14.41 The actions that have been identified as the principal means of addressing the threat are
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
14.42 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
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.
14.43 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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
14.45 The actions that have been identified as the principal means of addressing the threat are
concerned with completing integrated management plans for all military training sites in
the complex.
14.46 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
either negatively or positively, on the ways in which the Ministry of Defence (MoD)
manages those areas of land that it owns within the SPA 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 or land management practices employed by the military on MoD
land.
14.47 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 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 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
(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.”
14.49 The actions that have been identified as the principal means of addressing the pressure are
concerned with commissioning a study to identify priorities for habitat management which
reduce the adverse impacts of habitat fragmentation
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
14.51 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 the SPA with reference to
habitat fragmentation. No further assessment is required in respect of the habitat
fragmentation impact pathway.
14.D Assessment of significant effects
14.D.1 Emissions from thermal treatment facilities
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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 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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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 32 96.50 ha Lowland dwarf shrub heath habitat
Unit 33 30.82 ha Lowland dwarf shrub heath habitat
Unit 37 3.47 ha Lowland broadleaved mixed and yew woodland habitat
Unit 39 65.96 ha Lowland dwarf shrub heath habitat
Units in ‘Unfavourable – recovering’ Condition
Unit 21 64.35 ha Lowland dwarf shrub heath habitat
Unit 40 4.65 ha Lowland dwarf shrub heath habitat
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
14.63 The assessment of the implications of the implementation of the Surrey WLP for the
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.
13.63.2 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 would travel along those parts of the road network that
pass through the SPA.
14.64 The assessment considered the eight 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 14-B.
Table 14-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance–
discussed further in section
14.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in grazing practices –
discussed further in section
14.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 14.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
203
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
wildfire / arson – discussed
further in section 14.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
14.C.5 & section 14.D
Six ILAS (ILAS06, ILAS07, ILAS08, ILAS19, ILAS20,
ILAS21) located within 10 km of the SPA. Potential
for adverse impacts from nutrient nitrogen
deposition arising from process emissions (thermal
treatment plant) and traffic emissions.
For all ILAS thermal treatment may be feasible,
subject to project level assessment.
Traffic emissions unlikely to be major source of
additional deposition within the SPA – likely to
disperse to the wider network.
Overall conclusion of no likely significant impacts
on the SPA, 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 condition,
location & extent of the
features of qualifying interest
– discussed further in section
14.C.6
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
14.C.7
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
Changes due to habitat
fragmentation – discussed
further in section 14.C.8
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
14.G References
14.65 The following sources of information have been referred to as part of the assessment
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).
14.65.2 NATURA 2000 – Standard Data Form: Special Protection Areas under the EC
Birds Directive (includes proposed SPAs, Sites of Community Importance &
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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).
14.65.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
14.65.6 Thursley, Hankley & Frensham Commons SSSI Condition Survey Report
(Natural England, Designated Sites website, accessed 30 May 2018).
14.65.7 Environment Agency Catchment Data Explorer website.
14.65.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
June 2018
14.65.9 Habitat Regulations Assessment for the emerging Local Plan, URS for East
Hampshire District Council, 2012 and 2013
14.65.10 Habitat Regulations Assessment for the emerging Local Plan, AECOM for
Waverley Borough Council, 2016, 2017 and 2018.
14.65.11 Design Manual for Roads & Bridges, Volume 11 (Environmental Assessment),
Section 7 (Environmental Assessment Techniques), Highways England, May
2007.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
205
Chapter 15 Wealden Heaths Phase 2 SPA
15.A Geographic & Development Context
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).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
ILAS21 (Farnham Trading Estate (including land north of Water Lane), Water Lane,
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
ILAS02; ILAS03; ILAS04
ILAS05; ILAS06;ILAS08
ILAS07
ILAS11
ILAS12; ILAS13
ILAS14; ILAS16
ILAS15ILAS17
ILAS18
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
207
15.5 None of the preferred areas for mineral working identified in the adopted Surrey Minerals
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.
15.B Key Characteristics of the SPA
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.
Conservation Objectives
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 supporting processes on which the habitats of the qualifying features rely
The population of each of the qualifying features, and,
The distribution of the qualifying features within the site.
Qualifying Features
A224 Caprimulgus europaeus; European nightjar (Breeding)
A246 Lullula arborea; Woodlark (Breeding)
A302 Sylvia undata; Dartford warbler (Breeding)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
208
15.B.3 Condition 15.8 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Favourable Unfavourable –
Recovering
Broadleaved, mixed & yew woodland – lowland
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%)
Coniferous woodland 313.23 ha
(15.2%)
176.25 ha
(8.6%)
136.98 ha
(6.6%)
Standing open water & canals 2.80 ha
(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.C Identification of Impact Pathways & Screening Evaluation
15.9 The published Site Improvement Plan (SIP) for the SPA (23 October 2014) identifies the
following key pressures and threats to the site’s ecological integrity.
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;
Changes in the incidence of public access / disturbance – discussed further in section
15.C.3;
Changes in the use of the land for military activities – discussed further in section 15.C.4;
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
209
15.C.1 Change in land management
15.10 The features affected by changes in land management practices are the populations of the
European nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). 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.”
15.11 The actions that have been identified as the principal means of addressing the threat are
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.
15.12 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future land management practices within
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
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 SPA to be of significant benefit to the ongoing
management of its habitats.
15.13 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 land management practices
on the SPA. No further assessment is required in respect of the changes in land
management impact pathway.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
European nightjar A224(B), the Woodlark A246(B), and the Dartford Warbler A302(B). 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.
15.16 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
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.
15.17 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 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 monitoring of the feature of interest impact
pathway.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
211
15.C.3 Public access / disturbance
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.”
15.19 The actions that have been identified as the principal means of addressing the threat are
concerned with the development and implementation of a coordinated access strategy for
the complex which provides a basis for effective management of recreational use
15.20 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP could result in changes in the number of visitors to the 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 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.
15.21 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 additional visitors to the SPA, 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.
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.”
15.23 The actions that have been identified as the principal means of addressing the pressure are
concerned with completing integrated management plans for all military training areas.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
212
15.24 Screening Evaluation: There is no mechanism by which the Surrey WLP would impact,
either negatively or positively, on the ways in which the Ministry of Defence (MoD)
manages those areas of land that it owns within the SPA 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 or land management practices employed by the military on MoD
land.
15.25 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 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 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.“
15.27 The actions that have been identified as the principal means of addressing the threat are
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.
15.28 Screening Evaluation: There is no mechanism by which the forms of development covered
by the Surrey WLP would impact upon current or future fire management practices within
the SPA.
15.29 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
15.30 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 fire management practices
within the SPA, and although waste related development could, in theory, present a fire risk
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
15.31 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Wealden Heaths Phase 2 SPA 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 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.
15.32 The assessment considered the five impact pathways 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 each
pathway are summarised in Table 15-B.
Table 15-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in land management
– see section 15.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
214
Impact Pathway Conclusion Assessment
Level
Changes in the condition,
location or extent of the
qualifying features –
discussed further in section
15.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
15.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
15.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
wildfire / arson – discussed
further in section 15.C.5
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
15.E References
15.33 The following sources of information have been referred to as part of the assessment
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).
15.33.2 NATURA 2000 – Standard Data Form: Special Protection Areas under the EC
Wild Birds Directive – Wealden Heaths Phase 2 SPA (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
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
England, Designated Sites website, accessed 30 May 2018).
15.33.6 Broxhead & Kingsley Commons SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
15.33.7 Devils Punch Bowl SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
215
15.33.8 Woolmer Forest SSSI Condition Survey Report (Natural England, Designated
Sites website, accessed 30 May 2018).
15.33.9 Environment Agency Catchment Data Explorer website.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
216
Chapter 16 Wimbledon Common SAC
16.A Geographic & Development Context
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
boundary of the SAC.
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
boundary of the SAC.
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
accommodated on the identified ILAS.
Site 2 (Land at the former Weylands Treatment Works, Molesey Road, Walton on
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.
ILAS03 (Molesey Industrial Estate, Central Avenue, West Molesey), 9.0 kilometres to
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
217
Figure 16-A: Wimbledon Common SAC – Relationship to sites & ILAS proposed by the Surrey WLP
16.5 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 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 Key Characteristics of the SAC
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
ILAS06; ILAS07;ILAS08
ILAS10
ILAS11
ILAS12;ILAS13
ILAS16;ILAS14
ILAS17
ILAS18ILAS19
ILAS20;ILAS21
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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
Northern Atlantic wet heaths with Erica tetralix. (Wet heathland with cross-leaved heath)
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:
Stag beetle Lucanus cervus
16.B.2 Conservation Objectives
16.7 The published conservation objectives for the SAC are given below.
Conservation Objectives
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 extent & distribution of qualifying natural habitats & habitats of qualifying species;
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;
The distribution of qualifying species within the site.
Qualifying Features
H4010. Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath
H4030. European dry heaths
S1083. Lucanus cervus; Stag beetle
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
219
16.B.3 Condition 16.8 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Unfavourable – Recovering
Unfavourable – No Change
Dwarf shrub heath – lowland 81.85 ha
(23.29%)
64.23 ha
(18.28%)
17.62 ha
(5.01%)
Broadleaved, mixed & yew woodland – lowland
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
condition survey report provides the following explanation and analysis.
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.C Identification of Impact Pathways & Screening Evaluation
16.10 The published Site Improvement Plan (SIP) for the SAC (24 November 2014) identifies the
following key pressures and threats to the site’s ecological integrity.
20 https://designatedsites.naturalengland.org.uk/ReportUnitCondition.aspx?SiteCode=S1004317&ReportTitle=Wimbledon%20Common%20SSSI
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
220
Changes in the incidence of public access / disturbance – discussed further in section
16.C.1;
Changes due to habitat fragmentation – discussed further in section 16.C.2;
Changes due to the introduction of invasive species – discussed further in section 16.C.3;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
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.”
16.12 The actions that have been identified as the principal means of addressing the pressure are
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.
16.13 Screening Evaluation: There is no mechanism by which the forms of development covered
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 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.
16.14 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 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.
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:
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.”
16.16 The actions that have been identified as the principal means of addressing the threat are
concerned with the continued implementation of the established Peoples Trust for
Endangered Species project.
16.17 Screening Evaluation: There is no mechanism by which the forms of development covered
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.
16.18 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 the SAC with reference to
habitat fragmentation. No further assessment is required in respect of the habitat
fragmentation impact pathway.
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.”
16.20 The actions that have been identified as the principal means of addressing the threat are
concerned with developing an invasive species protocol, particularly for Oak processionary
moth, and within implementing invasive species monitoring and control programmes.
16.21 Screening Evaluation: 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
16.22 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 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.
16.C.4 Air pollution: impact of atmospheric nitrogen deposition 16.23 The features affected by changes in nutrient nitrogen deposition from the atmosphere are
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.”
16.24 The actions that have been identified as the principal means of addressing the threat are
concerned with reducing atmospheric nitrogen impact through the preparation and
implementation of a Site Nitrogen Action Plan.
16.25 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.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
16.29 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 local or
strategic road networks. Neither of the 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.
16.30 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 diffuse sources (traffic arising from waste related
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.
16.D Assessment of significant effects
16.31 The screening assessment has identified a single pathway (air pollution – atmospheric
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
detailed modelling has not been carried out, judgements (see Part B10, 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
224
loads for all the features covered by the SAC designation can be found in Part B10 of
Appendix B to this report.
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
16.35 The assessment of the implications of the implementation of the Surrey WLP for the
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
Surrey WLP are located within 10 kilometres of the SAC. The construction and
operation of a large scale (>50,000 tpa) thermal treatment facility is not
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
225
recommended for the allocated site, subject to the outcome of detailed
modelling and assessment at the planning application stage..
16.35.2 The potential effects of emissions from traffic generated by waste
management facilities have been considered, but the relationship of the
allocated site 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 would travel along roads pass through or within 200
metres of the SAC.
16.36 The assessment considered the three 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 16-B.
Table 16-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance –
discussed further in section
16.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to habitat
fragmentation – discussed
further in section 16.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the
introduction of invasive
species– discussed further in
section 16.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
16.C.4
One allocated site (Site 2) and two ILAS (ILAS03;
ILAS04) 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.
Small scale (<50,000 tpa) feasible at Site 2, ILAS03
and ILAS04.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
226
16.F References
16.37 The following sources of information have been referred to as part of the assessment
process for the Wimbledon Common SAC.
16.37.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Wimbledon
Common SAC (Natural England (English Nature), May 2005).
16.37.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Wimbledon Common SAC (Joint Nature Conservation
Committee (JNCC), 25 January 2016).
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).
16.37.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
16.37.6 Wimbledon Common SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
16.37.7 Environment Agency Catchment Data Explorer website.
16.37.8 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
227
Chapter 17 Windsor Forest & Great Park SAC
17.A Geographic & Development Context
17.A.1 Location of the 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
boundary of the SAC.
17.2.4 The B383 (Mounts Hill) – which passes within 200 metres of the southern
boundary of the SAC.
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.A.2 Minerals & waste development plan proposals in Surrey relevant to the SAC
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
accommodated on the identified ILAS.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
Site 1: Oakleaf 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
ILAS05;ILAS06;ILAS09
ILAS07
ILAS08
ILAS10
ILAS11;ILAS12;ILAS13
ILAS17
ILAS18
ILAS19
ILAS20;ILAS21
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
17.B Key Characteristics of the SAC
17.B.1 Reasons for Designation
17.6 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
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
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 & 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
The site is designated under article 4(4) of the Directive (92/43/EEC) as it hosts the following species listed in Annex II:
Violet click beetle Limoniscus violaceus
17.B.2 Conservation Objectives
17.7 The published conservation objectives for the SAC are given below.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
230
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
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
17.8 Based on the information published by Natural England in the most recent condition survey
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
Condition Classification
Favourable Unfavourable –
Recovering
Broadleaved, mixed & yew woodland – lowland
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%)
Coniferous woodland 66.87 ha
(3.76%)
0.0 ha
(0.0%)
66.87 ha
(3.76%)
Standing open water & canals 14.07 ha
(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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.C Identification of Impact Pathways & Screening Evaluation
17.10 The published Site Improvement Plan (SIP) for the SAC (4 November 2014) identifies the
following key pressures and threats to the site’s ecological integrity.
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 introduction of invasive species – discussed further in section 17.C.3;
Changes due to the incidence of plant disease – discussed further in section 17.C.4;
Changes arising from air pollution (atmospheric nitrogen deposition) – discussed further
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).”
17.12 The actions that have been identified as the principal means of addressing the
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
17.13 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. 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 the Royal Borough of
Windsor & Maidenhead.
17.14 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 affect the condition of
those habitats. No further assessment is required in respect of the changes in forestry or
woodland management impact pathway.
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.”
17.16 The actions that have been identified as the principal means of addressing the
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
17.17 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. 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 the Royal Borough of
Windsor & Maidenhead.
17.18 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 affect the condition of
those habitats. No further assessment is required in respect of the changes in forestry or
woodland management impact pathway.
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.”
17.20 The actions that have been identified as the principal means of addressing the threat are
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.
17.21 Screening Evaluation: The Surrey WLP is concerned with the provision of a policy
framework within which development consent decisions can be made in respect of future
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
234
waste management facilities within the county of Surrey. There is no mechanism by which
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.
17.22 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 significant adverse impacts on the SAC with reference to the
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)
offers the following explanation of the nature of the identified threat:
“Diseases of native oak are known from the local area. It is uncertain how significant this
could be for the ancient oak population.”
17.24 The actions that have been identified as the principal means of addressing the threat are
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
management facilities.
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
17.27 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 significant adverse impacts on the SAC with reference to the
potential introduction of plant disease into the designated site. No further assessment is
required in respect of the plant disease impact pathway.
17.C.5 Air pollution: impact of atmospheric nitrogen deposition
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
of the identified pressure:
“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.”
17.29 The actions that have been 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.
17.30 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.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
17.34 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 local or
strategic road networks. Neither of the 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.
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
17.36 The screening assessment has identified a single pathway (air pollution – atmospheric
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
detailed modelling has not been carried out, judgements (see Part B11, 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 B11 of
Appendix B to this report.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
17.40 The assessment of the implications of the implementation of the Surrey WLP for the
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
Surrey WLP are located within 10 kilometres of the SAC. The construction and
operation of a large scale (>50,000 tpa) thermal treatment facility is not
recommended for the allocated site, subject to the outcome of detailed
modelling and assessment at the planning application stage.
17.40.2 The potential effects of emissions from traffic generated by waste
management facilities have been considered, but the relationship of the
allocated site 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 would travel along roads pass through or within 200
metres of the SAC.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
238
17.41 The assessment considered the five 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 17-B.
Table 17-B: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in forestry and
woodland management (oak)
– discussed further in section
17.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
(beech) – discussed further in
section 17.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the
introduction of invasive
species– discussed further in
section 17.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the incidence
of plant disease – discussed
further in section 17.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
17.C.5
One allocated site (Site 1) and two ILAS (ILAS14;
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.
Small scale (<50,000 tpa) feasible at Site 1, ILAS14
and ILAS22.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
17.E References
17.42 The following sources of information have been referred to as part of the assessment
process for the Windsor Forest & Great Park SAC.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
239
17.42.1 EC Directive 92/43 on the Conservation of Natural Habitats & of Wild Fauna
and Flora: Citation for Special Area of Conservation (SAC) – Windsor Forest &
Great Park SAC (Natural England (English Nature), May 2005).
17.42.2 NATURA 2000 – Standard Data Form: Special Areas of Conservation under the
EC Habitats Directive (includes candidate SACs, Sites of Community Importance
& designated SACs) – Windsor Forest & Great Park SAC (Joint Nature
Conservation Committee (JNCC), 25 January 2016).
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).
17.42.5 Air Pollution Information System (APIS), Site Relevant Critical Loads & Source
Attribution section (http://www.apis.ac.uk/srcl ).
17.42.6 Windsor Forest & Great Park SSSI Condition Survey Report (Natural England,
Designated Sites website, accessed 30 May 2018).
17.42.7 Environment Agency Catchment Data Explorer website.
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.
17.42.10 Waste Local Plan – Transport Study: Site Assessments, Surrey County Council,
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
18.3 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.
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
241
Table 18-A: Summary of assessment conclusions for The Mens SAC
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – see section
2.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in land management
– see section 2.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 2.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in public access
/disturbance – see section
2.C.6
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
18.C Woolmer Forest SAC
18.5 The assessment of the implications of the implementation of the Surrey WLP for the
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.
18.6 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 18-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
242
Table 18-B: Summary of assessment conclusions for the Woolmer Forest SAC
Impact Pathway Conclusion Assessment
Level
Changes in land management
practices – discussed in
section 3.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – discussed
in section 3.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in local hydrology –
discussed in section 3.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the location,
extent and condition of the
features for which the SAC is
designated – discussed in
section 3.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in military use of the
land – discussed in section
3.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
18.D Ashdown Forest SAC
18.7 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ashdown 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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).
18.8 The assessment considered the three 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-C.
Table 18-C: Summary of assessment conclusions for the Ashdown Forest SAC
Impact Pathway Conclusion Assessment
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
Changes in air pollution
(deposition of atmospheric
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.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
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
18.E Ashdown Forest SPA
18.9 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ashdown Forest SPA 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 SPA, but one of the ILAS (ILAS18 – Hobbs IE, Felbridge) is 8.6 kilometres to the north
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
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 18-D.
Table 18-D: Summary of assessment conclusions for the Ashdown Forest SPA
Impact Pathway Conclusion Assessment
Level
Changes in public access
/disturbance – see section
5.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
18.F East Hampshire Hangers SAC
18.11 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
nutrient nitrogen deposition within the SAC, and traffic arising from development within
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.
18.12 The assessment considered the three 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 6-B.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
245
Table 18-E: Summary of assessment conclusions for the East Hampshire Hangers SAC
Impact Pathway Conclusion Assessment
Level
Changes in forestry &
woodland management – see
section 6.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Introduction or spread of
invasive species – see section
6.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 6.C.1
& 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.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
18.G Ebernoe Common SAC
18.13 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Ebernoe 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 (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
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 ILAS19 is
unsuitable for such development (subject to the conclusions of any project level
assessment).
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
246
18.14 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 18-F.
Table 18-F: Summary of assessment conclusions for the Ebernoe Common SAC
Impact Pathway Conclusion Assessment
Level
Changes in forestry and
woodland management
practices – discussed further
in section 7.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in off-site habitat
availability– discussed further
in section 7.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to habitat
fragmentation – discussed
further in section 7.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in land management
practices – discussed further
in section 7.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in local hydrological
conditions – discussed further
in section 7.C.5
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 7.C.6
& section 7.D
One ILAS (ILAS19) 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 ILAS19.
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.
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
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
247
18.H Mole Gap to Reigate Escarpment SAC
18.15 The assessment of the implications of the implementation of the Surrey WLP for the
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.
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
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.
18.15.2 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.
18.16 The assessment considered the five 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-G.
Table 18-G: Summary of assessment conclusions for the Mole Gap to Reigate Escarpment SAC
Impact Pathway Conclusion Assessment
Level
Changes arising from the
incidence of plant disease
(box blight) – discussed
further in section 8.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 8.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
248
Impact Pathway Conclusion Assessment
Level
Changes in land management
practices – discussed further
in section 8.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
8.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
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.
All scales of thermal treatment not recommended
at Site 4, ILAS10, ILAS11, ILAS12 and ILAS13.
Small scale (<50,000 tpa) feasible at Site 5 and
ILAS04.
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)
18.I Richmond Park SAC
18.17 The assessment of the implications of the implementation of the Surrey WLP for the
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.
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
249
18.J Shortheath Common SAC
18.19 The assessment of the implications of the implementation of the Surrey WLP for the
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
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-H.
Table 18-H: Summary of assessment conclusions for the Shortheath Common SAC
Impact Pathway Conclusion Assessment
Level
Changes in air pollution
(deposition of atmospheric
nitrogen) – see section 10.C.4
& section 10.D
One ILAS (ILAS20) 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.
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.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
250
Impact Pathway Conclusion Assessment
Level
Changes in scrub control
practices– discussed further
in section 10.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
10.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to direct
encroachment onto the land
by a third party (householder)
– discussed further in section
10.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
18.K South West London Waterbodies SPA & Ramsar Site
18.21 The assessment of the implications of the implementation of the Surrey WLP for the
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.
18.22 The assessment considered the seven impact pathways identified as key threats and
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
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance –
discussed further in section
11.C.1
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
251
Impact Pathway Conclusion Assessment
Level
Changes in species
distribution – discussed
further in section 11.C.2
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes due to the
introduction of invasive
species (Crassula helmsii) –
discussed further in section
11.C.3
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes arising from the
natural maturation of
wetland habitats– discussed
further in section 11.C.4
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes in fish stocking
densities and practices –
discussed further in section
11.C.5
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes in waterweed
control practices – discussed
further in section 11.C.6
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
Screening
Changes arising from the
incursion of invasive species
(Egyptian geese) – discussed
further in section 11.C.7
No direct or indirect significant impacts on the SPA
and Ramsar Site likely to arise from
implementation of the Surrey WLP
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
18.24 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
18.24.2 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 would travel along those parts of the road network that
pass through the thirteen SSSIs that together form the SPA.
18.25 The assessment considered the nine impact pathways 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 each
pathway are summarised in Table 18-J.
Table 18-J: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance –
discussed further in section
12.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in grazing practices –
discussed further in section
12.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in forestry and
woodland management
practices – discussed further
in section 12.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 12.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
253
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
wildfire / arson – discussed
further in section 12.C.5
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the condition,
location and extent of the
features of qualifying interest
– discussed further in section
12.C.7
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
12.C.8
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
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
impacts from nutrient nitrogen deposition arising
from process emissions (thermal treatment plant)
and traffic emissions.
Large scale (>50,000 tpa) thermal treatment not
recommended on Site 3.
All scales of thermal treatment not recommended
at ILAS05, ILAS07, ILAS17 and ILAS22.
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 SPA, 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)
Changes due to habitat
fragmentation – discussed
further in section 12.C.9
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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
18.27 The assessment of the implications of the implementation of the Surrey WLP for the
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
observation of a number of decision rules with reference to the development of thermal
treatment facilities.
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.
18.27.2 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 would travel along those parts of the road network that
pass through the four SSSIs that together form the SAC.
18.28 The assessment considered the nine 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-K.
Table 18-K: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
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
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
255
Impact Pathway Conclusion Assessment
Level
Changes in local hydrological conditions – discussed further in section 13.C.3
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
Screening
Changes in scrub control practices– discussed further in section 13.C.4
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
Screening
Changes due to the introduction of invasive species – discussed further in section 13.C.5
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
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
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
Screening
Changes in the use of the land for military activities – discussed further in section 13.C.8
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
Screening
Changes due to habitat fragmentation – discussed further in section 13.C.9
No direct or indirect significant impacts on the SAC likely to arise from implementation of the Surrey WLP
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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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)
18.30 The assessment of the implications of the implementation of the Surrey WLP for the
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.
18.30.2 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 would travel along those parts of the road network that
pass through the SPA.
18.31 The assessment considered the eight 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-L.
Table 18-L: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
public access / disturbance–
discussed further in section
14.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in grazing practices –
discussed further in section
14.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in scrub control
practices– discussed further
in section 14.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
257
Impact Pathway Conclusion Assessment
Level
Changes in the incidence of
wildfire / arson – discussed
further in section 14.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
14.C.5 & section 14.D
Six ILAS (ILAS06, ILAS07, ILAS08, ILAS19, ILAS20,
ILAS21) located within 10 km of the SPA. Potential
for adverse impacts from nutrient nitrogen
deposition arising from process emissions (thermal
treatment plant) and traffic emissions.
For all ILAS thermal treatment may be feasible,
subject to project level assessment.
Traffic emissions unlikely to be major source of
additional deposition within the SPA – likely to
disperse to the wider network.
Overall conclusion of no likely significant impacts
on the SPA, 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 condition,
location & extent of the
features of qualifying interest
– discussed further in section
14.C.6
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
14.C.7
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
Changes due to habitat
fragmentation – discussed
further in section 14.C.8
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP Screening
18.O Wealden Heaths Phase 2 SPA
18.32 The assessment of the implications of the implementation of the Surrey WLP for the
ecological integrity of the Wealden Heaths Phase 2 SPA 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 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
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
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.
18.33 The assessment considered the five impact pathways 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 each
pathway are summarised in Table 18-M.
Table 18-M: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in land management
– see section 15.C.1
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the condition,
location or extent of the
qualifying features –
discussed further in section
15.C.2
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
public access / disturbance –
discussed further in section
15.C.3
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the use of the
land for military activities –
discussed further in section
15.C.4
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
Changes in the incidence of
wildfire / arson – discussed
further in section 15.C.5
No direct or indirect significant impacts on the SPA
likely to arise from implementation of the Surrey
WLP
Screening
18.P Wimbledon Common SAC
18.34 The assessment of the implications of the implementation of the Surrey WLP for the
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
Surrey WLP are located within 10 kilometres of the SAC. The construction and
operation of a large scale (>50,000 tpa) thermal treatment facility is not
recommended for the allocated site, subject to the outcome of detailed
modelling and assessment at the planning application stage..
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
259
18.34.2 The potential effects of emissions from traffic generated by waste
management facilities have been considered, but the relationship of the
allocated site 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 would travel along roads pass through or within 200
metres of the SAC.
18.35 The assessment considered the three 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-N.
Table 18-N: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
16.C.4
One allocated site (Site 2) and two ILAS (ILAS03;
ILAS04) 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.
Small scale (<50,000 tpa) feasible at Site 2, ILAS03
and ILAS04.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)
Changes in the incidence of
public access / disturbance –
discussed further in section
16.C.1
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to habitat
fragmentation – discussed
further in section 16.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the
introduction of invasive
species– discussed further in
section 16.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
260
18.Q Windsor Forest & Great Park SAC
18.36 The assessment of the implications of the implementation of the Surrey WLP for the
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
Surrey WLP are located within 10 kilometres of the SAC. The construction and
operation of a large scale (>50,000 tpa) thermal treatment facility is not
recommended for the allocated site, subject to the outcome of detailed
modelling and assessment at the planning application stage.
18.36.2 The potential effects of emissions from traffic generated by waste
management facilities have been considered, but the relationship of the
allocated site 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 would travel along roads pass through or within 200
metres of the SAC.
18.37 The assessment considered the five 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-O.
Table 18-O: Summary of assessment conclusions
Impact Pathway Conclusion Assessment
Level
Changes in forestry and
woodland management (oak)
– discussed further in section
17.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
(beech) – discussed further in
section 17.C.2
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the
introduction of invasive
species– discussed further in
section 17.C.3
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Changes due to the incidence
of plant disease – discussed
further in section 17.C.4
No direct or indirect significant impacts on the SAC
likely to arise from implementation of the Surrey
WLP
Screening
Habitat Regulations Assessment of the Surrey Waste Local Plan –January 2020: Final
261
Impact Pathway Conclusion Assessment
Level
Changes arising from air
pollution (atmospheric
nitrogen deposition) –
discussed further in section
17.C.5
One allocated site (Site 1) and two ILAS (ILAS14;
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.
Small scale (<50,000 tpa) feasible at Site 1, ILAS14
and ILAS22.
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.
Screening
(Traffic
Emissions)
Assessment
of Likely
Significant
Effects
(Process
Emissions)