Waverley Borough Submission Local Plan 1: Strategic ... · LOCAL PLAN SPATIAL STRATEGY 3.1 The Local Plan spatial strategy includes the allocation of 2,330 homes in the Farnham area

Waverley Borough SubmissionLocal Plan 1: Strategic Policies and Sites

Topic Paper: SANG

August 2016

updated December 2016

Page | 1 SANG Topic Paper Updated December 2016

1. INTRODUCTION: THE NEED FOR SANG 1.1 The original Thames Basin Heaths Special Protection Area (SPA) Avoidance

Strategy was adopted by Waverley Borough Council in December 2009. Its purpose is to provide guidance to developers when making planning applications for new housing which may have an effect on the conservation interests of the SPA. The Strategy sets out the Council’s approach in seeking to avoid the effect of a net increase in population within 5 km of the SPA, and how it proposes to discharge its legal obligations under the Conservation of Habitats and Species Regulations 2010 (the “Habitats Regulations”).

1.2 Under the Habitats Regulations, the Council is the “competent authority” to

consider whether applications for development are “likely to have a significant effect” on the SPA. Any significant effect must be ascertained by considering the proposal both alone and in combination with other plans or projects. In practice, Natural England’s advice is that any application for residential development resulting in a net increase in dwellings within 5 km of the SPA will, without avoidance measures, be likely to have a ‘significant effect’ within the meaning of the Habitats Regulations.

1.3 The Avoidance Strategy provides guidance to developers on the level of

avoidance measures that the Council expects to see incorporated within planning applications in the light of Natural England’s advice. In this instance, “avoidance measures” means providing or contributing towards Suitable Alternative Natural Greenspace (SANG) and contributing towards a programme of Strategic Access Management and Monitoring (SAMM) of the SPA itself.

1.4 Only a small part of the SPA (about 80 ha) is within Waverley, north of Sandy

Hill, Farnham. However, for the purposes of the Avoidance Strategy, a “Zone of Influence” of the SPA extends 5 km from the perimeter of the SPA and therefore, affects most of the built-up area of Farnham (Plan 1; page 11).

2. SANG IN WAVERLEY 2.1 Farnham Park (Plan 2; page 12) is the only current SANG resource in

Waverley and lies north of the town centre, with the northern boundary about 800 metres from the SPA boundary. The park lies within the Zone of Influence of the SPA and is well placed to provide avoidance measures for developments in the Farnham area.

2.2 The overall size and location of Farnham Park means that it can serve a

development catchment of 5 km from its boundaries covering the entire Zone of Influence in Waverley. However, the (notional) amount of SANG that can be effectively enhanced and linked to development contributions in accordance with Natural England’s green space standards is only a proportion of the whole park’s area (85 ha out of a total of 130 ha). This is a function of (i) existing visitor capacity; and (ii) the range of potential enhancement measures


that, if implemented, would serve to attract or divert potential SPA users to the park.

SANG Capacity

2.3 The standard for providing SANG (at 8 ha per 1000 population) is derived from the original Natural England Delivery Plan which preceded the SPA Delivery Framework. The same standard has been carried through into the Framework and the retained South East Plan Policy NRM6. To convert the population numbers into an equivalent number of dwellings, the Framework assumed an occupancy rate of 2.4 persons per dwelling (ppd).

2.4 The amount of SANG available at Farnham Park has varied since monitoring

began with equivalent variations in the overall capacity in terms of the numbers of dwellings involved. Each meeting of the Council’s Western Area Planning Committee (WAPC) receives an update report on the capacity of the park, including where the total capacity has been amended. Table 1 below shows how these changes have affected the capacity since 2008.

Table 1: Changes in SANG capacity at Farnham Park

WAPC Meeting SANG area Total dwelling

capacity

24 September 2008 10.9 ha 567

29 September 2010 14.35 ha 746

10 April 2013 21.25 ha 1104

2.5 A number of variables determine how quickly the SANG capacity at Farnham

Park will be taken up by residential permissions. The Council’s monitoring of residential permissions within the SPA Zone of Influence is an integral part of the Avoidance Strategy and Delivery Framework. In that respect, an analysis of all planning permissions that have been liable for contributions (as at 1st April 2016) showed an average occupancy rate that is significantly lower than originally assumed (Table 2 below). This reflects the large proportion of smaller (1- and 2-bedroom) dwellings that have been permitted since monitoring began in 2007.

Table 2: Monitored Occupancy Rates (to 1.4.16)

Dwelling size Nos. of dwellings

permitted*

Occupancy rate

(ppd) Total persons

1 bedroom 232 1.31 303.9

2 bedrooms 530 1.76 932.8

3 bedrooms 218 2.51 547.2

4 bedrooms 111 2.86 317.5

5/+ bedrooms 36 3.73 134.3

Total 1,127 1.98 2,235.7

* Includes expired permissions


2.6 This has implications for the number of people for which there has been

mitigation, and the overall capacity of the park in terms of numbers of dwellings. For whilst numbers of people remain unchanged, a lower occupancy rate increases the ‘dwelling capacity’ of the SANG. At the monitored rate of 1.98 ppd, this would equate to 1,341 dwellings.

2.7 The appropriate amount of SANG that needs to be identified in the Local Plan

will depend on the proportion of Waverley’s total housing requirement that is allocated to the Farnham area. It will also depend on what assumptions are made about the average occupancy rate of new dwellings. The nature and scale of new housing permitted since 2007 (Table 2 above), suggests that the average occupancy rate of future new housing is likely to be lower than the original assumed standard.

2.8 However, until it is appropriate to assume a new ‘standard’ rate for the plan

period, the original rate of 2.4 ppd has been used as a benchmark ‘ceiling’ figure for calculating the amount of SANG required to support new housing provision in the Farnham area This is considered to represent a ‘worst case’ scenario in terms of SANG requirements.

3. LOCAL PLAN SPATIAL STRATEGY 3.1 The Local Plan spatial strategy includes the allocation of 2,330 homes in the

Farnham area over the plan period (2013-2032), made up from -

3.2 Completions and outstanding permissions (totalling 953 dwellings) have already been mitigated through developer contributions in accordance with the TBH SPA Avoidance Strategy. For the purposes of estimating the amount of new SANG required as mitigation, it has been assumed that the ‘all the potential Farnham sites identified in the Council’s 2016 Land Availability Assessment (LAA), along with the entirety of the ‘windfall’ allowance for Farnham, fall within the 5 km buffer zone.

3.3 To meet the requirements of the Avoidance Strategy, developers can:

buy into the existing ‘strategic’ SANG through S106 agreements;

contribute to the upgrading of an existing SANG site; or

provide new (bespoke) SANG themselves.

3.4 Of the proposed sites, that West of Switchback Lane (LAA ref. 546; 25 dwellings) will not rely on the capacity of the Farnham Park SANG as it is located outside the SPA 5 km buffer zone. The LAA also include three ‘urban’ sites in Farnham that have received permission since 1st April 2016, but which have been counted against the unallocated SANG capacity reported to the WPC meeting of 13th April because of earlier resolutions to grant consent subject to S106 agreements on the SANG/SAMM contributions. These are –


25-27 Hurlands Road 10 dwellings (net)

Stephensons Engineering, Wrecclesham Hill 12 dwellings (net)

2-3 The Borough 11 dwellings (net) 3.5 The total number of dwellings requiring mitigation is therefore 1,319

3.6 The unallocated SANG capacity, as at 1st April 2016 (as reported to the WAPC on 13.4.16) was 243 dwellings, but this included the three urban sites (above) and was based on an overall SANG capacity calculated against a lower (monitored) occupancy rate of 1.98 ppd.

SPA Avoidance Strategy (2016 Review)

3.7 On 19th July 2016, the Council adopted a new Avoidance Strategy that provides for an increase in the SANG (dwelling) capacity at Farnham Park.

3.8 The review of the strategy arose out of the Council’s monitoring of the SANG

capacity at Farnham Park, along with the results of a new visitor survey carried out on behalf of the Council by Footprint Ecology in May/June 2014. This found that Farnham Park is at 59.3% capacity compared with the precautionary figure of 75% as advised by Natural England and used as a basis for monitoring SANG capacity since 2007. This leaves 40.7% available for SANG, equivalent to an area of 34.6 ha, an increase of over 60% over previously assumed capacity. This method of re-assessment has been endorsed by Natural England (NE) and represents a significant increase in the capacity of the park.

3.9 Applying the SPA Delivery Framework’s standard formula to this enlarged

area produces a revised total capacity of 1,802 dwellings. This represents an increase of almost 700 over the figure against which new permissions have been monitored since 2013 (see Table 1 above). NE has also confirmed Footprint Ecology’s findings that there is sufficient car parking at Farnham Park to accommodate the increased capacity. For the purposes of monitoring that capacity, an adjustment needs to be made to account for the number of dwellings that had already been completed and occupied at the time of the Footprint survey. Using June 2014 as a new base date, the unallocated capacity at that time (adjusted for completed and occupied dwellings) stood at 1,358 dwellings – a figure that would now represent the ‘base’ capacity for monitoring purposes. By 1st April 2016, further permissions (excluding the three urban sites previously referred to) had reduced the unallocated capacity to 988 dwellings.

3.10 The table below sets out the number of homes proposed in the draft Local

Plan against the latest SANG capacity. Assuming an occupancy rate of 2.4 ppd, it shows that an additional 6.3 ha of SANG would be required to meet the full plan allocation for Farnham.

Table 5a: SANG requirements (enhanced capacity; 2.4ppd)


Numbers of Dwellings (as at 1.4.16) Additional SANG required

8 ha/1000 @ 2.4 ppd Draft Plan

Allocations Unallocated

SANG capacity Requiring mitigation

1,319 988 331 6.3 ha

3.11 Given that a lower average occupancy rate (AOR) results in an increased

dwelling capacity for the SANG, the calculated requirement of 6.3 ha is a ‘worst case scenario’ and represents the maximum amount needed. The monitored AOR at 1st April 2016 stood at 1.98 ppd – a figure that is considered unlikely to fall further over the plan period. This could therefore represent the bottom end of the range for additional SANG.

Table 5b: SANG requirements (enhanced capacity; 1.98ppd)


8 ha/1000 @ 1.98 ppd Draft Plan

Allocations Unallocated

SANG capacity Requiring mitigation

1,319 1,370 (+ 51) 0

Note: Unallocated capacity calculated as follows–

34.6 ha @ 8 ha / 1000 = 4,325 people @ 1.98 ppd = 2,184 dwellings

‘Net’ permissions at June 2014 (adjusted for completed and occupied dwellings) = 444

‘Baseline’ capacity at June 2014 = (2,184 – 444) 1,740 dwellings

Monitored permissions June 2014 to 1.4.16 = 337 dwellings

Exclude three sites with pp after 1.4.16 (total 33 no.)

Unallocated capacity (1,740 – 337 – 33) 1,370 dwellings

Opportunities for additional SANG

3.12 In April 2015, environmental consultants concluded their analysis of potential new opportunities for SANG1. This included –

A re-assessment of potential sites identified in the original (2009) SPA Avoidance Strategy

Sites in the Farnham area that were considered unsuitable for development in the Council’s 2014 Strategic Housing Land Availability Assessment (SHLAA), but which could be suitable for SANG

Sites within adjoining districts (Rushmoor, Guildford, Hart and East Hampshire) that were considered unsuitable for development by those authorities’ SHLAAs, but which could be suitable for SANG

‘Call for SANG Land’ undertaken for the Farnham Neighbourhood Plan

Quarry/sandpit sites with potential to be restored to a favourable form

Offers by site promoters for bespoke SANG

1 Analysis of Potential SANG Sites for Farnham for the Thames Basin Heaths SPA

Avoidance and Mitigation Strategy, AECOM (April 2015)


A map review of potentially suitable land within 5 km of the SPA. 3.13 A total of 45 sites were assessed against Natural England’s site quality criteria

for an individual SANG (Appendix 2). Several were discounted because of their inadequate size, existing habitats, location, unwilling land owner and/or not meeting enough of the site quality criteria (even with enhancements). Apart from existing areas of SANG in Waverley (at Farnham Park and Rowhill Copse), only part of the restored Farnham Quarry was considered “suitable and with good potential to be brought forward as strategic SANG”, i.e. part of a ‘pooled’ SANG resource as mitigation for the effect of new housing development on the SPA.

3.14 Several sites that were “suitable, but with unknown potential to be brought

forward as strategic SANG”, were also identified at -

Tongham Pools (in conjunction with Farnham Quarry)

Runfold Sandpits

Bishop’s Meadow

Land off Hale Road (Farnham Park extension)

Homefield / Jolly Farmer Sandpits

Alton Road Sandpit

Waverley Lane (if not appropriate for housing) 3.15 The Hop Fields site off Crondall Lane was also identified, but has since been

discounted by virtue of the planning permission granted by the Council in September 2015. Natural England has agreed that SANG in the developer’s ownership at Church Crookham (Hart District) would be appropriate mitigation in this instance. The number of dwellings permitted have therefore not been counted against the SANG capacity at Farnham Park (Table 4 above).

3.16 The Council’s investigations into the extent to which these sites are genuinely

suitable, available and, importantly, deliverable within the plan period are summarised as follows.

Table 6: Opportunities for additional SANG

Site Progress

Farnham Quarry Restoration is now complete, but only part of the site (around 10 ha) is identified as ‘highly suitable’ for SANG. A car park of an appropriate size and location will be required if the site is to be suitable as a strategic SANG resource.

The Tongham Pools site east of the quarry is currently being progressed as SANG jointly by Guildford Borough and Surrey County Councils. There is also an opportunity to connect the two sites and provide a linked/joint SANG resource.

Runfold Sandpits

The Council has had initial discussions with the owners about the potential use of land on the southern side of Guildford Road as SANG. Natural England has visited the site and considers that it has great potential as SANG (subject to meeting the site


quality criteria) when quarrying operations have ceased.

The total area of land (including land on the northern side of Guildford Road) amounts to around 45 ha. In principle, therefore, it could provide considerable scope for delivering SANG later in the plan period (and beyond), subject to agreement with the landowner.

Bishop’s Meadow

This site has previously been identified as having the potential to meet SANG criteria although, to date, it has not been specifically put forward by the landowner.

Land at Hale Road

Planning application discussions have taken place on a scheme for housing and bespoke on-site SANG, with the potential to be an extension to the Farnham Park SANG. A planning application for the development of the site is currently with the Council for consideration.

Homefield / Jolly Farmer Sandpits

Site owners (Chambers) have confirmed that the sites are not available at present.

Alton Road Sandpit

Given current rates of extraction and restoration, it is very unlikely that the site could be available for SANG within the local plan period.

Waverley Lane The site has not been identified as potentially suitable allocation in the LAA. Three applications for residential development, and which include bespoke on-site SANG, were refused permission by the council in July/August 2015. An appeal public inquiry is taking place in August 2016.

Developers’ SANG Proposals

3.17 The draft Local Plan’s housing provision for the Farnham area includes a strategic allocation at Coxbridge Farm (LAA ID 29; est. 350 dwellings). The site’s promoters have indicated that the effects of their development could be mitigated through the provision of ‘bespoke’ SANG, either on- or off-site.

3.18 Land off Hale Road (LAA ID 693; est. 80 dwellings). See above, if

development is approved on this site it may provide scope for SANG over and above that required for the development itself.

3.19 Land at Holt Pound Farm, Wrecclesham has been also been identified as a

privately owned SANG by the promoter of land to the rear of Three Stiles Road (LAA ID 727; est. 40 dwellings). As with Hale Road, the proposed SANG (around 12 ha) exceeds that required to mitigate the promoted site alone. It is understood that the surplus could be offered to other prospective developers to supplement (or as an alternative to) the strategic SANG resource.

3.20 The SPA Delivery Framework requires the provision of SANG to be funded by

developer contributions. The tariff collected by the Council in accordance with the Avoidance Strategy takes account of the capital, management and maintenance costs ‘in perpetuity’. While publicly-owned sites (like Farnham


Park) is Natural England’s preferred model of securing SANG, privately-owned sites can also be acceptable provided they can ensure the long-term availability of SANG through, for example, an appropriate land trust or management company.

3.21 Assuming that each of the three potential bespoke sites could satisfy the

qualitative and long-term management criteria for individual SANGs, a further (estimated) 470 dwellings would not need to rely on the existing SANG resource at Farnham Park, reducing the number of dwellings allocated in the draft plan requiring SANG accordingly (Table 7 below). Such a situation would obviate the need to identify any new SANG over the plan period, irrespective of which occupancy rate is assumed.

Table 7: SANG requirements (enhanced capacity) excl. ‘bespoke’ sites


8 ha / 1000 Draft Plan Allocations

Unallocated SANG capacity

Requiring mitigation

@2.4ppd @1.98ppd @2.4ppd @1.98ppd @2.4ppd @1.98ppd

849 988 1,370 (+ 139) (+ 521) 0 0


APPENDIX 1

SOUTH EAST PLAN POLICY NRM6 – THAMES BASIN HEATHS SPA

New residential development which is likely to have a significant effect on the ecological integrity of Thames Basin Heaths Special Protection Area (SPA) will be required to demonstrate that adequate measures are put in place to avoid or mitigate any potential adverse effects. Such measures must be agreed with Natural England.

Priority should be given to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures. Where mitigation measures are required, local planning authorities, as Competent Authorities, should work in partnership to set out clearly and deliver a consistent approach to mitigation, based on the following principles:

i. a zone of influence set at 5km linear distance from the SPA boundary will be established here measures must be taken to ensure that the integrity of the SPA is protected

ii. within this zone of influence, there will be a 400m “exclusion zone” where mitigation measures are unlikely to be capable of protecting the integrity of the SPA. In exceptional circumstances, this may vary with the provision of evidence that demonstrates the extent of the area within which it is considered that mitigation measures will be capable of protecting the integrity of the SPA. These small locally determined zones will be set out in local development frameworks (LDFs) and SPA avoidance strategies and agreed with Natural England

iii. where development is proposed outside the exclusion zone but within the zone of influence, mitigation measures will be delivered prior to occupation and in perpetuity. Measures will be based on a combination of access management, and the provision of Suitable Accessible Natural Greenspace (SANG).

Where mitigation takes the form of provision of SANG the following standards and arrangements will apply:

iv. 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

v. developments of fewer than 10 dwellings should not be required to be within a specified distance of SANG land provided it is ensured that a sufficient quantity of SANG land is in place to cater for the consequent increase in residents prior to occupation of the dwellings

vi. access management measures will be provided strategically to ensure that adverse impacts on the SPA are avoided and that SANG functions effectively

vii. authorities should co-operate and work jointly to implement mitigation measures. These may include, inter alia, assistance to those authorities with insufficient SANG land within their own boundaries, co-operation on access management and joint development plan documents

viii. relevant parties will co-operate with Natural England and landowners and stakeholders in monitoring the effectiveness of avoidance and mitigation measures and monitoring visitor pressure on the SPA and review/amend the approach set out in this policy, as necessary

ix. local authorities will collect developer contributions towards mitigation measures, including the provision of SANG land and joint contributions to the funding of access management and monitoring the effects of mitigation measures across the SPA

x. large developments may be expected to provide bespoke mitigation that provides a combination of benefits including SANG, biodiversity enhancement, green infrastructure and, potentially, new recreational facilities.

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.

The mechanism for this policy is set out in the TBH Delivery Framework by the TBH Joint Strategic Partnership and partners and stakeholders, the principles of which should be Incorporated into local authorities' LDFs.


APPENDIX 2 SITE QUALITY CRITERIA FOR AN INDIVIDUAL SANG

‘Must/Should haves’

1) For all sites larger than 4 ha there must be adequate parking for visitors, unless the site is intended for local use, i.e. within easy walking distance of the developments linked to it. The amount of car parking should be determined by the anticipated use of the site and reflect the visitor catchment of both the SANG and the SPA.

2) It should be possible to complete a circular walk of 2.3 – 2.5 km around the SANG.

3) Car parks must be easily and safely accessible by car and should be clearly sign posted.

4) The accessibility of the site must include access points appropriate for the particular visitor use the SANG is intended to cater for.

5) The SANG must have a safe route of access on foot from the nearest car park and/or footpaths.

6) All SANGs with car parks must have a circular walk which starts and finishes at the car park.

7) SANGs must be designed so that they are perceived to be safe by users: they must not have tree and scrub covering parts of the walking routes.

8) Paths must be easily used and well-maintained but most should remain unsurfaced to avoid the site becoming urban in feel.

9) SANGs must be perceived as semi-natural spaces with little intrusion of artificial structures except in the immediate vicinity of car parks. Visually sensitive way-markers and some benches are acceptable.

10) All SANGs larger than 12 ha must aim to provide a variety of habitats for users to experience.

11) Access within the SANG must be largely unrestricted with plenty of space provided where it is possible for dogs to exercise freely and safely off lead.

12) SANGs must be free from unpleasant intrusions (e.g. sewage treatment works smells, etc.).

13) SANGs should be clearly sign-posted or advertised in some way.

14) SANGs should have leaflets and/or websites advertising their location to potential users. It would be desirable for leaflets to be distributed to new homes in the area and be made available at entrance points and at car parks.

‘Desirable’

15) The ability of owners to take dogs from the car park to the SANG safely off the lead.

16) Where possible, choose sites with a gently undulating topography.

17) Access points to have signage outlining the layout of the SANG and the routes available to visitors.

18) To provide a naturalistic space with areas of open (non-wooded) countryside and areas of dense and scattered trees and shrubs. The provision of open water on part, but not the majority of sites is desirable.

19) Where possible, to have a focal point such as a viewpoint, monument etc. within the SANG.

Note: The wording in the lists above is precise and has the following meaning:

• Requirements referred to as “must” or “should haves” are essential


• SANGs should have at least one of the “desirable” feature


PLAN 1: THAMES BASIN HEATHS SPA BUFFER ZONES



PLAN 2: FARNHAM PARK

Documents

Waverley Borough Submission Local Plan 1: Strategic ... · LOCAL PLAN SPATIAL STRATEGY 3.1 The Local Plan spatial strategy includes the allocation of 2,330 homes in the Farnham area