Policy P5: Thames Basin Heaths Special Protection Area

GBC Policy

Policy P5: Thames Basin Heaths Special Protection Area

Permission will not be granted for development proposals unless it can be demonstrated that doing so would not give rise to adverse effects on the ecological integrity of the Thames Basin Heaths Special Protection Area (SPA), whether alone or in combination with other development. Where one or more adverse effects on the SPA are likely, measures to avoid and mitigate these effects must be delivered and secured in perpetuity. These measures must be agreed with Natural England. The following principles apply:

  • There is an “exclusion zone” set at 400m linear distance from the SPA boundary. Permission will not be granted for development that results in a net increase in residential units within this zone. Proposals for other types of development within this zone must undertake Appropriate Assessment to demonstrate that they will not harm the integrity of the SPA.
  • There is a “zone of influence” between 400m and 5km linear distance from the SPA boundary. Where net new residential development is proposed within the zone of influence, mitigation measures must be delivered prior to occupation of new dwellings and in perpetuity. Measures must be based on a combination of Strategic Access Management and Monitoring (SAMM) and the provision, improvement and/or maintenance of Suitable Alternative Natural Greenspace (SANG).
  • Residential development of at least 50 net new dwellings that falls between five and seven kilometres from the SPA may be required to provide mitigation measures. This will be assessed on a case-by-case basis and agreed with Natural England.


The following principles apply to the provision of SANG.

  • A minimum of 8 hectares of SANG land (after discounting to account for current access and capacity) should be provided per 1,000 new occupants.
  • Developments must fall within the catchment of the SANG that provides mitigation, except developments of fewer than 10 net new residential units.
  • The Council will collect developer contributions towards mitigation measures, including SANG (unless bespoke SANG mitigation is provided) and SAMM.
  • Developments may secure or provide bespoke SANG. Proposals for new SANGs will not be acceptable unless approved by Natural England. Large developments may be required to provide bespoke SANG mitigation.

Where further evidence demonstrates that the integrity of the SPA can be protected using different linear thresholds or with alternative mitigation measures (including standards of SANG provision different to those set out in this policy) these must be agreed with Natural England.

GGG Response


We OBJECT to this policy. This policy is weak. 

The mitigation (cash compensation) offered for development in the special protection area is so small and negligible as to be meaningless. 

SANG (Suitable Alternative Natural Greenspace) is not beneficial; the sites identified or targeted are already green space. 

To create SANG is just using agricultural or wooded land as recreation land in order to justify building on other green spaces. 

There is no actual increase in environmental protection; it is a policy designed to permit building on otherwise protected areas. SANG – in part used to prevent dogs and cats attacking nesting birds - must ensure that it is not using land which is adjacent to the special protection areas.

Detailed response

Thames Basin Heaths Special Protection Area (TBH SPA; see Map 1, Appendix 1), is a statutory designated site and designated for its rare and vulnerable birds, specifically nightjar, Dartford warbler and woodlark under the EC Birds Directive.   This site also forms part of the Thursley, Ash, Pirbright and Chobham Special Area of Conservation (SAC), a statutory designated site and designated for its North Atlantic wet heaths, European dry heaths and peat bogs. 

We believe that the Plan is unsound as the Habitats Regulations Assessment prepared for GBC does not take sufficient account of the impact seven proposed developments will have upon the Thames Basin Heaths Special Protection Area (TBH SPA) which is a European Site (as defined under the Habitats Directive and Conservation of Habitats and Species Regulations 2010 (as amended).

The seven proposed developments are less than five kilometres away from the TBH SPA and in some cases not much beyond the 400m exclusion zone, occupying an area between under 1km to just over 2km from the TBH SPA. It has been indicated that the cumulative effect of further residential development up to 5 km from protected heathlands will have a significant adverse effect on the heaths. The TBH SPA is an internationally important habitat for three rare species of bird - the Dartford warbler, woodlark and nightjar. The latter two are ground nesting and therefore particularly susceptible to disturbance from people and animals.  In fact Natural England believes that recreational use of the heaths arising from housing developments up to five kilometres away from a SPA will create disturbance to rare bird populations. 

A survey in 2008 showed that more than 83% of visitors to the SPA arrived by car and that 70% of those had come from within 5km of its access point. A very large proportion of the TBH SPA visitors are dog walkers, many of whom visit a particular site on a regular basis. A follow-up survey in 2012 found that there was a 10% increase in visitors to the SPA.

A survey of households carried out by a veterinary team at Bristol University in 2010 “Number and ownership profiles of cats and dogs in the UK” published in the Journal of The British Veterinary Association indicates 31% households own dogs and 26% households own cats. Dogs were more likely to be owned by rural households.

Applying this analysis for all new housing at the listed strategic housing sites in the draft Local Plan within the 400m-5km mitigation zone of TBHSPA (in total 7,000 new homes), the cumulative impact of dog ownership (up to an estimated 2,200 new dogs within 5 km of TBHSPA) with dog-walker incursions on the rare bird species habitat of the TBHSPA will be a devastating increase. No amount of SANG nor SAMM programmes will change human behaviour and the draft Local Plan evidence base contains no studies or data to prove otherwise, it contains only unproven assertions. Natural England can provide no survey evidence of the effectiveness of SANG or SAMM programmes in attracting dog-walkers and other visitors away from TBHSPA.



2017 Guildford Local Plan

Guildford’s NEW local Plan has just opened for consultation. PLEASE RESPOND before 24th July 2017.  GGG has published its responses to Local Plan Policies here 

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