Our Local Plan

Habitats Regulation Assessment for the Tandridge District Council Local Plan 2033 and Garden Community Appropriate Assessment Report January 2019 Local Plan Submission

2 CONTENTS

Executive Summary ...... 1 1. Introduction ...... 3 1.1 Purpose of this Report ...... 3 1.2 Structure of this Document ...... 3 1.3 Consultation ...... 4 2 Context ...... 5 2.1 The Tandridge District Local Plan 2033 ...... 5 2.2 Habitats Regulations Assessment Legislation and Regulations ...... 6 2.3 The Habitats Regulations Assessment Process ...... 8 2.4 The Protected European Sites ...... 11 2.5 Other Relevant Plans and Strategies ...... 19 3. Appropriate Assessment of the Mole Gap to Reigate Escarpment SAC ...... 32 3.1 Citation, Qualifying Features, Conservation Objectives and Condition Status 32 3.2 Process of Assessment and Duty to Cooperate ...... 32 3.4 Recreational Disturbance Impact Pathways ...... 33 3.5 Hydrology Impact Pathways ...... 40 3.6 Air Quality Impact Pathways ...... 50 4. Appropriate Assessment of the Ashdown Forest SAC ...... 56 4.1 Citation, Qualifying Features, Conservation Objectives and Condition Status 56 4.2 Initial Screening Report (August 2017) ...... 56 4.3 Natural England Screening Opinion ...... 57 4.4 Air Quality: Evidence Gathering into effects of Tandridge District Local Plan 57 4.5 Air Quality: Local Plan Considerations ...... 60 5. Appropriate Assessment of the Ashdown Forest SPA ...... 62 5.1 Citation, Qualifying Features, Conservation Objectives and Condition Status 62 5.2 Initial Screening Report (August 2017) ...... 63 5.3 Natural England Screening Opinion ...... 63 5.4 Background Evidence on Recreational Disturbance Impact Pathways ...... 64 5.5 Impact Avoidance and Mitigation Measures proposed by the Local Plan ...... 78 5.6 Recommended Local Plan Policy ...... 83

3 5.7 Strategic Green Infrastructure at South Godstone ...... 84 5.8 Partnership Working and Monitoring ...... 91 6. Conclusions ...... 93 Appendix 1: Site Citations ...... 94 Appendix 1a – Citation for Ashdown Forest SAC ...... 94 Appendix 1b – Citation for Ashdown Forest SPA ...... 95 Appendix 1c – Citation for Mole Gap to Reigate Escarpment SAC ...... 96 Appendix 2: Site of Special Scientific Condition Analysis...... 97 Appendix 2a – Ashdown Forest SSSI ...... 97 Appendix 2b – Mole Gap to Reigate Escarpment SSSI ...... 98 Appendix 3: Natural England Comments on Stage 1 Screening ...... 99 Appendix 4: Exerts from Wealden DC Draft Background Paper – Ashdown Forest SPA Mitigation Zone ...... 100

4 Executive Summary

The purpose of the Habitats Regulations Assessment (HRA) of land use plans is to ensure that consideration is given to sites protected by European Directives as part of the development of planning policy.

There are no protected sites within Tandridge District. There are however two protected sites within neighbouring districts which therefore, taking a precautionary approach, should be subject to the HRA process. These are:

 Ashdown Forest SAC and SPA; and,  Mole Gap to Reigate Escarpment SAC.

This HRA is conducted in support of the emerging Tandridge District Council ‘Local Plan 2033’ (hereafter referred to as Local Plan). The report accompanies the Local Plan Regulation 19 consultation process and assesses potential impacts upon the Ashdown Forest and Mole Gap to Reigate Escarpment.

This report represents Stage 2 ‘Appropriate Assessment’ of the Habitats Regulations Assessment conducted in support of the Local Plan. The Appropriate Assessment has considered the following potential impacts upon the protected international sites, in combination with other projects or plans.

Ashdown Forest SPA and SAC

 Recreational Disturbance  Air Quality

Mole Gap to Reigate Escarpment SAC

 Recreational Disturbance  Hydrology  Air Quality

These impacts were originally ‘screened in’ as part of Stage 1 ‘Screening’ of the HRA in August 2017. The Appropriate Assessment (AA) has investigated all the above potential impacts and demonstrated how they can be screened out as non-significant, mitigated or impacts avoided. The AA has also identified a number of Local Plan measures and policies that will have positive ecological and sustainability outcomes as part of good planning, as well as reducing the likelihood of effects occurring in future. Relevant Sections of the report containing further detail are as follows:

Ashdown Forest SPA and SAC

Recreational Disturbance: Section 5.5 -5.8. Air Quality: Section 4.5

1 Mole Gap to Reigate Escarpment SAC:

Recreational Disturbance: Sections 3.4.5, 3.4.6 Hydrology: Sections 3.5.6, 3.5.7 Air Quality: Section 3.6.4

As a consequence, provided the AA recommendations are followed through, it can be concluded that impacts of the Local Plan 2033 upon the international sites will be acceptable/non-significant.

2 1. Introduction

1.1 Purpose of this Report

The purpose of the Habitats Regulations Assessment (HRA) of land use plans is to ensure that consideration is given to sites protected by European Directives as part of the development of planning policy.

This HRA is conducted in support of the emerging Tandridge District Council ‘Local Plan 2033’ (hereafter referred to as Local Plan). The report accompanies the Local Plan Regulation 19 consultation process.

HRA is a requirement of the Conservation of Habitats and Species Regulations 2010 (as amended; ‘the Habitats Regulations’). The assessment focuses on the likely significant effects of the plan on the nature conservation interests of European-protected areas in and around the district, and seeks to establish whether or not there will be any adverse effects on the ecological integrity of these European sites as a result of proposals in the plan.

The HRA is a staged process, essentially iterative, being revisited as necessary in response to more detailed information, recommendations and any relevant changes to the plan or project until no significant adverse effects remain.

There are no protected sites within Tandridge District. However, there are two areas of protected sites within neighbouring districts which need to be considered as part of the HRA process. These are the Ashdown Forest SAC and SPA; and the Mole Gap to Reigate Escarpment SAC.

This report represents Stage 2 ‘Appropriate Assessment’ of the Habitats Regulations Assessment conducted in support of the Tandridge District Council Local Plan 2033. It follows an initial Stage 1 Screening (2017 Update) undertaken in August 2017, as well as previous iterations in 2015 and 2016.

1.2 Structure of this Document

This report is in 6 parts and consists of this introduction and the following sections:

 Section 2 provides contextual information on both the Local Plan itself and the requirement to undertake a HRA for the Local Plan;  Section 3 is the Appropriate Assessment of the Mole Gap to Reigate Escarpment SAC  Section 4 is the Appropriate Assessment of the Ashdown Forest SAC  Section 5 is the Appropriate Assessment of the Ashdown Forest SPA

3  Section 6 presents the Conclusions, Next Steps and Implications for the Local Plan 2033.

1.3 Consultation

As required by regulations that relate to the HRA, this report is published for consultation for 6 weeks, between 9am 16 July 2018 and 5pm, 28 August 2018. Comments on this report can be sent to us by:

 Web Portal: http://consult.tandridge.gov.uk/portal/  Email: [email protected];  Post: Strategy Team, Tandridge District Council, Council Offices, Station Road East, RH8 0BT

An electronic version of this document can be found online at www.tandridge.gov.uk/localplan.

Comments made on the document after the end of the consultation period will not be accepted. More information about the Local Plan can be found on our webpage www.tandridge.gov.uk/localplan.

4 2 Context

2.1 The Tandridge District Local Plan 2033

Tandridge District Council (“the Council”) is preparing a Local Plan which will set out a development strategy for the district up to 2033 in accordance with national policy and guidance, including the National Planning Policy Framework (2012) and accompanying Planning Practice Guidance (PPG). In addition, the plan will be consistent with the statutory requirements of the Town and Country Planning (Local Planning) (England) Regulations (2012).

The Local Plan will include housing and employment targets and will seek to allocate sites to ensure such targets can be delivered, whilst also containing a set of policies to manage development in a sustainable manner. If necessary, and as informed by HRA work, it will introduce policies to ensure the protection of European sites from any adverse impacts of the Local Plan.

Once adopted, the Local Plan will replace the Council’s current Core Strategy (2008) in full. Policies in the Council’s adopted Detailed Policies Development Plan Document (2014) remain unless specifically specified in the Local Plan 2033.

In preparing the Local Plan so far, the Council has carried out three formal public consultations; the Issues and Approaches (2015), Sites Consultation (2016) and Garden Villages Consultation (2017). Each of these consultations accorded with Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations (2012). This report will accompany a fourth period of public consultation alongside the proposed submission (Regulation 19) Local Plan. Subject to committee approval on 3 July 2018, this consultation is being carried out to accord with Regulation 19 and 20 of the Town and Country Planning (Local Planning) (England) Regulations (2012) for 6 weeks, between 16 July 2018 and 28 August 2018.

Once the consultation has concluded comments relating to soundness and legal compliance will be considered. In addition, minor amendments to the document may be made and all responses received will be submitted directly to the Planning Inspectorate for their consideration along with those raised through previous consultation phases in accordance with Regulation 22 Town and Country Planning (Local Planning) (England) Regulations (2012). It will be through the process of the Independent Examination that any other matters will be assessed and at the discretion of the appointed Planning Inspector.

Before the Local Plan can become formal policy it must undergo independent examination by the Planning Inspectorate. This Local Plan Consultation presents the final iteration of the plan which the Council proposes to submit and is the final stage of

5 public consultation which must be undertaken in advance of submission, anticipated in late 2018.

. 2.1.1 Levels of Development Proposed by the Local Plan

The Local Plan requires the following development quantums

Residential: 6,056 dwellings Employment: At least 15.3ha B-class use employment space.

The preferred Garden Community is South Godstone (4,000 dwellings).

It is important to note that for the purposes of HRA it will be necessary to consider this growth ‘in-combination’ with the growth in other relevant plans and programmes.

2.1.2 HRA Supporting the Local Plan 2033

Tandridge District Council is the Competent Authority for undertaking HRA in respect of the Council’s Local Plan.

This Appropriate Assessment report, which accompanies the Local Plan Regulation 19 Consultation1, follows on from HRA Stage 1 Screening Reports, the most recent version of which was published in August 2017.

2.2 Habitats Regulations Assessment Legislation and Regulations

As part of the process of developing the Local Plan, the Council must abide by relevant European2 and national legislation and regulations. Such obligations include Council Directive 92/43/EEC on the Conservation of Natural Habitats and of wild flora and fauna – most commonly referred to as the Habitats Directive.

Of particular relevance to plan-making is article 6(3) of the Habitats Directive, which 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

1 In accordance with the Town and Country Planning (Local Planning) (England) Regulations (2012) 2 The UK decision to leave the European Union does not result in an immediate removal of EU policy or legislation and compliance with relevant legislation remains necessary until such time as it is replaced, amended or revoked.

6 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.”

The Conservation of Habitats and Species Regulations 2017 transpose Council Directive 92/43/EEC, on the conservation of natural habitats and of wild fauna and flora (EC Habitats Directive), into national law. They also transpose elements of the EU Wild Birds Directive in England and Wales. The 2017 Regulations came into force on 30th November 2017 and consolidate the Conservation of Habitats and Species Regulations 2010 with subsequent amendments

Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (the ‘Habitats Regulations’) states that if a land-use plan “(a) is likely to have a significant effect on a European site or a European offshore marine site (either alone or in combination with other plans or projects); and (b) is not directly connected with or necessary to the management of the site” then the plan-making authority must “…make an appropriate assessment of the implications for the site in view of that site’s conservation objectives” before the plan is given effect.

The process by which Regulation 105 is met is known as Habitats Regulations Assessment (HRA). An HRA determines whether there will be any ‘likely significant effects’ (LSE) on any European site as a result of a plan’s implementation (either on its own or ‘in combination’ with other plans or projects) and, if so, whether these effects will result in any adverse effects on the site’s integrity. The Council has a statutory duty to prepare the Local Plan and is therefore the Competent Authority for an HRA. Regulation 105 essentially provides a test that the final plan must pass.

The HRA report will consider relevant European sites which consist of:

 Special Areas of Conservation (SAC) – sites designated to provide increased protection to a variety of wild animals, plants and habitats.  Special Protection Area (SPA) – sites designated for the breeding, feeding, wintering or the migration of rare and vulnerable species of birds found within EU countries.

It is also Government policy for sites designated under the Convention on Wetlands of International Importance (Ramsar sites) to be treated as having equivalent status to European sites (although in practice there are no Ramsar sites that are necessary to consider as part of the Council’s HRA process).

For the remainder of this report, for the sake of simplicity, the different types of sites which the HRA must consider will be collectively known as ‘protected sites’.

A number of key documents have informed this screening report, including:

7  Department for Communities and Local Government consultation paper on Appropriate Assessment of Plans (2006)  DEFRA ‘The Habitats and Wild Birds Directives in England and its seas - Core guidance for developers, regulators & land/marine managers December 2012 (draft for public consultation)  European Commission “Assessment of plans and projects significantly affecting Natura 2000 sites”;  The National Planning Policy Framework (2012);  Circular 06/2005 Biodiversity and Geological Conservation - statutory obligations and their impact within the planning system (although Planning Policy Statement 9 has been superseded the Circular remains in force);  Natural England’s guidance notes on HRA; and  Guidance on HRA of plans produced by RSPB.

2.3 The Habitats Regulations Assessment Process

Best practice has demonstrated that Local Plans should be subjected to HRA at the earliest possible stage in their production to enable any potential significant effects to be identified and mitigated early on in the plan-making process.

An “effect” includes anything which would impact upon a protected site. Temporary, permanent, direct and indirect effects need to be considered. A plan or project does not need to be located on a site in order to impact on it. Generally the closer an activity is, the greater the chance it will affect a site. However, operations taking place far from a protected site may still be capable of having a significant effect (e.g. a project which extracts water may affect a site some distance away by altering the water table, and emissions to air or water may impact on sites distant to the source of the emission)3.

A hierarchy of avoidance, mitigation and compensatory measures is promoted by the Habitats Directive. The approach to undertaking a HRA is a step by step process which contains the following stages:

Stage 1: Likely significant effects (‘screening’); Stage 2: Appropriate Assessment (the ‘integrity test’); and Stage 3: Mitigation measures and alternative solutions

In exceptional circumstances, if following Stage 3, a plan cannot avoid an adverse effect (or risk of one) on a protected site, there may be a further stage – referred to as the Imperative Reasons of Overriding Public Interest (IROPI) Test.

More details on all these stages can be found in the following sections.

3 Source: DEFRA ‘The Habitats and Wild Birds Directives in England and its seas Core guidance for developers, regulators & land/marine managers December 2012 (draft for public consultation)

8 2.3.1 Stage 1: Likely significant effects (‘Screening’ stage)

The Screening stage seeks to identify whether the Local Plan is likely to have a significant effect on a protected site and in doing so, determines whether subsequent stages of the HRA process are required to be undertaken.

In undertaking the Screening stage, the authority has to consider relevant available information in concluding whether a significant effect is likely to occur to a protected site. This includes giving consideration to other plans and strategies, which will allow the authority to assess whether the plan is likely to have a significant effect by itself or in combination with other plans that are in force or in production.

Throughout the process the precautionary principle is applied to the HRA. This means that where there is not enough information to assess whether a plan or project is likely or not to have a significant effect on a protected site, it should be assumed that a risk may exist. If this is the case, it would result in either Stage 1 being undertaken at a later stage when more details are known or the HRA proceeding to Stage 2: Appropriate Assessment.

2.3.2 Stage 2: Appropriate Assessment

If this stage is necessary, an Appropriate Assessment (AA) will be carried out to establish the potential effects of the plan on the protected site’s integrity. In doing so, the AA will consider the site’s qualifying features, its conservation objectives and the key environmental conditions which support the site’s integrity.

Regulation 102 of the Amended Habitats Regulations 2010 requires an Appropriate Assessment to identify any potential in-combination effects; therefore, it is necessary to establish which other plans and strategies may affect the protected site(s) considered in this assessment.

If it is found that the plan will impact on the site’s integrity, it is necessary to proceed to the third stage of the process to consider mitigation measures and alternative solutions to prevent negative impacts to the protected site(s) arising from the plan.

2.3.3 Stage 3: Mitigation measures and alternative solutions

If there is an adverse effect on the integrity of the protected site(s), these effects should be mitigated. The main aim of seeking mitigation is to fully cancel out any adverse effects the plan may have on a protected site. It is accepted that it is not always possible to completely eradicate the plan’s negative impacts on a protected site. Therefore mitigation would need to ensure sufficient reduction so that an adverse impact on the integrity of the protected site(s) can be nullified. Measures will normally involve the modification of a plan or project.

9 2.3.4 When adverse effects (or risk of one) on a protected site cannot be avoided

In exceptional circumstances, an authority can implement a plan even when the HRA process concludes that there would be a negative impact on a protected site’s integrity that could not be overcome by mitigation or by choosing alternative solutions. This is because Article 6(4) of the Habitats Directive allows an authority to implement a plan if there are imperative reasons of overriding public interest (more commonly written as its acronym, IROPI) for doing so. In such an instance, compensatory measures would have to put in place to counteract some of the plan’s negative impacts. These must be taken to ensure that the overall coherence of the network of protected sites is protected.

2.3.5 In-Combination Effects

Other plans and projects being prepared or implemented in the area may have the potential to cause negative effects on the integrity of European sites. These effects may be exacerbated when experienced in combination with the effects of the District Plan, possibly leading an insignificant effect to become significant. It is therefore important to consider which other plans and projects could generate similar effects as development within Tandridge at the same European sites, and which may act in-combination. In combination effects are therefore considered throughout the Appropriate Assessment.

A decision-maker may not issue a development consent without undertaking an ‘appropriate assessment’ of a scheme’s impact on the integrity of a protected site, unless he/she can ‘exclude’ the possibility of likely significant effects of the scheme alone or in combination with other plans or projects.

That a likely significant effect from a scheme (alone or in combination) cannot be screened out under this precautionary approach does not mean that under an ‘appropriate assessment’ it will necessarily be concluded that there will be adverse impacts on the integrity of the European site, it merely requires that a more detailed study be undertaken, on the best information currently available.

At the stage of considering the matter, those ‘plans or projects’ which need to be considered ‘in combination’ are those which amount to commitments, but not yet apparent in the baseline. Future or inchoate schemes need not be included as they, in turn, will need to go through the consenting process, taking into account the approval of the scheme in question as a commitment.

10 2.4 The Protected European Sites

There are no protected sites within Tandridge District. There are however two protected sites within neighbouring districts which therefore, taking a precautionary approach, should be subject to the HRA process. These are:

 Ashdown Forest SAC and SPA; and,  Mole Gap to Reigate Escarpment SAC.

The sites and their geographic relationship to Tandridge District Council can be seen in Map 1.

Protected sites have different reasons for designation and accordingly they have different pressures. Information about both sites can be found in Table 2 below. In addition, the more detailed site citations published under the EU Directives are at Appendix 1.

There are two relevant ‘Site Improvement Plans’ (SIPs) as follows:

 Ashdown Forest Site Improvement Plan  Mole Gap to Reigate Escarpment Site Improvement Plan

These SIPs were produced by Natural England who led a 2 year programme (finished in 2015) in partnership with the Environment Agency with support from the European Union’s LIFE+ Nature and Biodiversity programme. Essentially the SIPs set out plans on how to target efforts on the protected sites to get them into a healthy state. As such, they provide some insight into the existing challenges facing the protected sites.

For example, the Ashdown Forest SIP highlights threats that include air pollution – the impact of atmospheric nitrogen deposition and public access disturbance. For each threat, a set of actions is identified. It is notable that in relation to atmospheric nitrogen deposition, the mechanism of a ‘Site Nitrogen Action Plan’ (SNAP) was identified, but the funding and delivery body not yet identified. The Mole Gap to Reigate Escarpment SIP also highlights the threats of atmospheric nitrogen deposition and public access disturbance.

Site of Special Scientific Interest (SSSI) Condition Analysis can be found in Appendix 2. SSSI monitoring is undertaken by Natural England as part of their statutory duties. The objectives of SSSI monitoring include informing agreement of the most appropriate site management and contributing to Natural England’s monitoring of long-term changes in the natural environment. It is important to note that all Natura 2000 and Ramsar sites are also covered by the statutory national SSSI designation, therefore the condition analysis of SSSI may provide useful insights into the condition of internationally protected sites. However, the data should be treated with caution since the SSSI boundaries cover a slightly greater extent than the international sites, as demonstrated in Table 1, so will include condition assessments of areas not relevant to the HRA.

Table 1: Comparison of Protected Sites by Spatial Extent

Subject to HRA Not Subject to HRA SAC Area SPA Area SSSI Area (Ha) (Ha) (Ha) Mole Gap to Reigate 894.33 N/a 1,016.42 Escarpment Ashdown Forest 2,728.31 3,205.46 3,213.09

The tables in Appendix 2 show that more than three-quarters of the Ashdown Forest SSSI is in unfavourable condition, though recovering. For the Mole Gap to Reigate Escarpment, there is a more even split, with just over half favourable and the remainder unfavourable (mostly recovering).

12 Map 1: International Sites in relation to Tandridge District

13 Table 2: Information about the Protected Sites

Ashdown Forest (SAC and SPA) Mole Gap to Reigate Escarpment SAC Location Wealden District Mole Valley District /Reigate and Banstead Borough Proximity to Around 5km at the nearest point, to the south-east of Around 3km at the nearest point, to the west of the Tandridge the district. district. District Extent 2,728 hectares (SAC), 3,205 hectares (SPA) Approximately 8 miles long and covers 894 ha area. 60% Heath, Scrub, Maquis and Garrigue, Phygrana. 15% Heath, Scrub, Maquis and Garrigue, Phygrana. 40% Mixed woodland. 25% Dry grassland, Steppes. 60% Broad-leaved deciduous woodland. Site SAC Mole Gap in south-east England supports the only Description4 Ashdown Forest contains one of the largest single area of stable box scrub in the UK, on steep chalk continuous blocks of lowland heath in south-east slopes where the River Mole has cut into the North England, with both European dry heaths and, in a Downs Escarpment, creating the Mole Gap. Here, larger proportion, wet heath. The Erica tetralix – natural erosion maintains the open conditions Sphagnum compactum wet heath element provides required for the survival of this habitat type. The site suitable conditions for several species of bog-mosses therefore supports a stable formation and has good Sphagnum spp., bog asphodel Narthecium conservation of habitat structure and function. ossifragum, deergrass Trichophorum cespitosum, common cotton-grass Eriophorum angustifolium, This site hosts the priority habitat type "orchid rich marsh gentian Gentiana pneumonanthe and marsh sites". This large but fragmented site on the North clubmoss Lycopodiella inundata. The site supports Downs escarpment supports a wide range of important assemblages of beetles, dragonflies, calcareous grassland types on steep slopes, including damselflies and butterflies, including the nationally Festuca ovina – Avenula pratensis, Bromus erectus, rare silver-studded blue Plebejus argus, and birds of Brachypodium pinnatum, Brachypodium pinnatum – European importance, such as European nightjar Bromus erectus and Avenula pubescens grasslands. It Caprimulgus europaeus, Dartford warbler Sylvia exhibits a wide range of structural conditions ranging undata and Eurasian hobby Falco subbuteo. from short turf through to scrub margins, and is particularly important for rare vascular plants, The dry heath in Ashdown Forest is an extensive including orchids. It is also significant in exhibiting example of the south-eastern Calluna vulgaris – Ulex transitions to scarce scrub, woodland and dry heath minor community. This vegetation type is dominated types, notably Stable xerothermophilous formations by heather Calluna vulgaris, bell heather Erica cinerea with Buxus sempervirens on rock slopes, yew Taxus

4 As stated from information on the Joint Nature Conservation Council’s website – www.jncc.defra.gov.uk 14 and dwarf gorse Ulex minor, with transitions to other baccata woods, and chalk heath. habitats. It supports important lichen assemblages, including species such as Pycnothelia papillaria. This At Mole Gap to Reigate Escarpment, yew Taxus site supports the most inland remaining population of baccata woodland has been formed both by invasion hairy greenweed Genista pilosa in Britain. of chalk grassland and from development within beech Fagus sylvatica woodland following destruction SPA of the beech overstorey. Yew occurs here in extensive This site qualifies under Article 4.1 of the Directive stands, with, in places, an understorey of box Buxus (79/409/EEC) by supporting populations of European sempervirens at one of its few native locations. importance of the following species listed on Annex I of the Directive:

During the breeding season; Dartford Warbler Sylvia undata, 29 pairs representing at least 1.8% of the breeding population in Great Britain (Count as at 1994).

Nightjar Caprimulgus europaeus, 35 pairs representing at least 1.0% of the breeding population in Great Britain (Two year mean, 1991 & 1992). Qualifying SAC European dry heaths. Features5 Northern Atlantic wet heaths with Erica tetralix; Wet Stable xerothermophilous formations with Buxus heathland with cross-leaved heath. sempervirens on rock slopes (Berberidion p.p.); European dry heaths Triturus cristatus; Great crested Natural box scrub. newt. Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia) SPA (important orchid sites); Dry grasslands and Caprimulgus europaeus; European nightjar scrublands on chalk or limestone (important orchid (Breeding). sites). Sylvia undata; Dartford warbler (Breeding). Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils Taxus baccata woods of the British Isles; Yew- dominated woodland Triturus cristatus; Great crested newt

5 Taken from the Conservation Objectives for the respective sites 15 Myotis bechsteinii; Bechstein`s bat. Key Environ- · Minimal air pollution; · Minimal air pollution; mental · Relatively unpolluted water (approx. neutral pH); · Maintenance of grazing; Conditions · Low recreational disturbance; · Absence of direct fertilisation; to support · Suitable foraging and refuge habitat · Suitable foraging and refuge habitat site integrity within 500m of ponds; within 500m of ponds; · Balanced hydrological regime to maintain wet · Maintenance of landscape features (hedgerows, heath; woodland, mature trees, etc.) and roosts used by · Grazing management to prevent succession, Bechstein’s bats · Some ponds deep enough to retain water · Low recreational pressure; and throughout February to August (at least once in three · Maintenance of tree management. years); and, · Good connectivity of landscape features. Vulnerability SAC6 Most of this site is a mosaic of chalk downland Ashdown Forest is one of the most extensive areas of habitats, ranging from open chalk grassland to scrub heathland in south-east England. The optimum and broadleaved semi-natural woodland on the scarp management for this site is grazing; however, only slope of the North Downs. Headley Heath is an area approximately 19% of the SAC is grazed. Spread of of heathland, grassland and woodland located on scrub and bracken is a major threat to the SAC. clay-with-flints on the dip slope. Both box and yew are well represented. The majority of the SAC (including the grazed area) is managed sympathetically by the Conservators of The principal risks to site integrity according to the Ashdown Forest but there is high demand on Natural England Site Improvement Plan8 are as resources for scrub clearance, bracken mowing, etc., follows: particularly in the ungrazed area. There is ongoing liaison with the Conservators and other land  Disease – pressure/threat to natural box scrub. owners/managers to increase the area of grazed  Inappropriate scrub control – pressure to dry heathland. Obstacles to grazing include public grasslands and scrublands on chalk or limestone opposition to fencing, availability of graziers/suitable (important orchid sites) livestock, and constraints on dog-walkers. In general, public access is not a threat to the SAC, unless it  Change in land management – threat to dry prevents expansion of the grazed area. grasslands and scrublands on chalk or limestone (important orchid sites)

6 From the Ashdown Forest SAC Natura 2000 data form http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0030080.pdf 8 http://publications.naturalengland.org.uk/publication/5966636066537472 [Accessed 22nd March 2018] 16 Also, possible long-term drying out of the site may  Public access/disturbance – threat to dry take place, due to borehole extraction and grasslands and scrublands on chalk or limestone transpiration from increase in vegetation cover. (important orchid sites), great crested newts and Consultations with the Environment Agency over the Bechstein’s bat. possible impact of extraction are ongoing. Recent  Air pollution: risk of atmospheric nitrogen increased scrub clearance is likely to have a beneficial deposition – threat to European dry heaths, effect on wet heath. natural box scrub, dry grasslands and scrublands on chalk or limestone (important orchid sites), Atmospheric pollution is a widespread issue, with beech forests on neutral to rich soils, yew- background air quality heavily influenced by large dominated woodlands and Bechstein’s bat. point-source emitters including transboundary sources. Local pollutant sources can affect designated sites, particularly in relation to protected habitats Recreational pressure is high and requires within SACs, and especially from road traffic management and monitoring. The National Trust and emissions. Qualifying habitats most sensitive to air Surrey County Council own and manage a significant pollution within Ashdown Forest are European dry proportion of the site. In addition smaller areas are heaths and North Atlantic wet heaths. The main owned by other local authorities and the local wildlife pollutant effects of interest are acid deposition and trust. Recreation and conservation requirements tend eutrophication by nitrogen deposition. to be taken into consideration by such bodies. The rest of the site is in smaller private ownerships. For SPA7 these areas, appropriate management has been Lack of management is the main threat to the site. addressed through the Site Management Statement Succession from open heathland to woodland is process. These areas are most under threat from rapidly taking place and a lack of resources makes neglect and a lack of appropriate grazing. appropriate and sustainable management difficult. Bechstein's bats use the site throughout the year, as The majority of the site is managed by the a winter hibernacula, autumn 'swarming' site, and as Conservators of Ashdown Forest, who manage the feeding habitat. English Nature is currently working site sympathetically and according to an agreed with local bat surveyors to locate maternity roosts, management plan. The key vulnerability is the lack of and to gain a better understanding of the movements 9 grazing which is now being addressed through a and requirements of bats on this site. Grazing Strategy. Obstacles to grazing include the

7 Taken from the Ashdown Forest SPA Natura 2000 data form - http://jncc.defra.gov.uk/pdf/SPA/UK9012181.pdf 9 Taken from the Mole Gap to Reigate Escarpment SAC Natura 2000 data form - http://jncc.defra.gov.uk/protectedsites/sacselection/n2kforms/UK0012804.pdf 17 need for fencing, constraints on dog walkers and other forms of informal recreation, the availability of appropriate stock and the fragmentation of the heathland blocks within the site. The spread of invasive/non-native species, such as bracken and rhododendron, also poses a threat. The areas not under the Conservators remit tend not to be grazed and have varying degrees of conservation management.

Most of the recreation on the site is informal, such as walking and horse riding. However, in places the use is intense resulting in damage to rights of way and disturbance to the Forest. Where possible these problems are being addressed through the Integrated Management Plan of the Conservators of Ashdown Forest and through a horse riding permit system.

18 2.5 Other Relevant Plans and Strategies

When undertaking the HRA, it is necessary to look at relevant plans produced by other authorities to understand whether the Local Plan, in combination with other plans and strategies, could have a significant effect on a protected site.

Following the Wealden District Council v. Secretary of State for Communities and Local Government, Lewes District Council and South Downs National Park Authority High Court Judgement, it is particularly important to highlight the importance of considering the cumulative impacts on the protected sites. Therefore, the impacts resulting from Tandridge’s Local Plan cannot be assessed in isolation, but need to be considered ‘in combination’ with the plans and policies of other authorities.

A summary of the main matters of contextual relevance from other plans are found in Table 3 below, based on a judgement of likely significance. For the Ashdown Forest this includes all local planning authorities currently cooperating as part of the Ashdown Forest Air Quality Group.

In terms of the general principle of in-combination development used within the technical assessment of air quality, a general principle was agreed via the Ashdown Forest Air Quality Group Statement of Common Ground as follows:

o If a Local Plan is less than 5 years old, use the adopted figure. o If an emerging Local Plan is nearing pre-submission and the Local Planning Authority is confident then use the emerging figure o If the adopted LP is over 5 years old and an emerging plan has not progressed use the ‘Objectively Assessed Need (OAN)/standard methodology (once confirmed by Ministry of Housing, Communities and Local Government) unless otherwise evidenced.

This same principle was applied for the consideration of ‘in-combination’ development for the Mole Gap to Reigate Escarpment SAC.

19 Table 3: A summary of relevant issues covered in other authorities' Plans

Local Local Plan(s) Main Matters of Relevance Authority Crawley Crawley 2030: Crawley Borough Identifies a minimum 5,100 new homes between 2015 – 2030. Local Plan 2015 -2030 (adopted Equates to at least 340 p/a but phased according to trajectory. December 2015) Between 23ha and 35ha of new employment land.

HRA: No significant impacts identified on European sites, including the Ashdown Forest SAC/SPA alone or in combination with other plans or projects.

Croydon Croydon Local Plan(Adopted A minimum of 32,890 homes between 2016 and 2036. February 2018) An HRA Stage 1 Screening was carried out in 2015. For the Mole Gap to Reigate Escarpment SAC, the HRA considered that there were no realistic pathways present.

Eastbourne Core Strategy Local Plan (2013) 5,022 dwellings by 2027 (240 pa) OAN: 520 dpa. East Local Transport Plan (LTP) 2011- HRA (2011) concluded that further amendments to wording in the LTP Sussex 2026 required before we are able to conclude that significant effects are County unlikely. Once these amendments have been made, the LTP will be Council reassessed and this conclusion can be amended.

Waste and Minerals Sites Plan The WMSP was subject to Habitats Regulation Assessment (HRA) 2017 screening, both in terms of the proposed waste sites and policies within the Plan. Details of the HRA screening were included in the site profiles of the plan. Several sites identified as needing project level HRA screening should they come forward for development.

Local Local Plan(s) Main Matters of Relevance Authority Elmbridge Core Strategy (Adopted 2011) The Core Strategy plans for approximately 3,375 net additional dwellings (225 net dwellings annual average) within the Borough Development Management Plan between 2011 and 2026. Adopted 2015 OAN: 9,480 (2015-2035) 474 p/a. (Source: SHMA 2016) New Local Plan underwent Strategic Options Consultation An HRA of 'Settlement Investment and Development Plans' was that ended in February 2017. undertaken in March 2013. It noted that Mole Gap to Reigate Escarpment was 4km from the Borough boundary, but concluded that were no additional impacts to that identified in the Appropriate Assessment from the Core Strategy and there were no likelihood in- combination effects.

A Habitats Regulations Assessment Stage 1: Initial Screening Report for the 'Spatial Strategy Options' was undertaken in November 2016. This was inconclusive regarding LSE and indicated the need to update the report at later stages to enable a more detailed assessment of likely impacts to be undertaken before deciding if adverse effects remain and need to proceed to Stage 2: Appropriate Assessment.

Epsom and Core Strategy (Adopted 2007) Provides for 181 homes per annum or 3,620 dwellings between 2006 Ewell and 2026. HRA concluded that Core Strategy would not have an impact on Natura 2000 sites due to separation distances from the Submission draft Development borough, growth locations, and mitigation/avoidance measures Management Plan 2018 included in the plan.

Submission Draft Development Management Plan 2018 requirement of 7,106 new homes up to 2032 - *418 new homes each year from 2015 to 2032. Site locations not yet confirmed.

21 Local Local Plan(s) Main Matters of Relevance Authority OAN: 8,352 (2015-2035) 418 p/a (Source: SHMA June 2016)

Greater The London Plan 2016 The Plan establishes a minimum 10 year housing target 2015-2025 London across all London Boroughs of 423,887. This includes the following: Authority Bromley: 6,413 Croydon: 14,348 Kingston-upon-Thames: 7,330 Merton: 4,107 Richmond-upon-Thames: 3,150 Sutton: 3,626

The Plan's Key Diagram identifies the broad Wandle Valley- a planning and investment corridor of city region importance connecting from Wandsworth through Croydon and down to Gatwick Airport and Crawley. Although the boundary of the Wandle Valley is non-specific, logically this would connect down the M23 through Tandridge District.

A draft new London Plan was published for consultation in December 2017 to March 2018. It has the following 10 year housing targets to 2029:

Bromley: 14,240 (1,424 p/a) Croydon: 29,490 (2,949 p/a) Kingston-upon-Thames: 13,640 (1,364 p/a) Merton: 13,280 (1,328 p/a) Richmond-upon-Thames: 8,110 (811p/a) Sutton: 9,390 (939p/a)

A Draft HRA (November 2017) was included alongside the consultation. It noted the Mole Gap to Reigate Escarpment SAC is just

22 Local Local Plan(s) Main Matters of Relevance Authority over 5km from Greater London at its closest. The HRA concluded that ‘Since it is not a conveniently situated site for casual recreational visits for most Londoners, and London (particularly the boroughs closest to the SAC) has a large amount of its own high quality recreational natural greenspace, recreational pressure from the new London Plan is unlikely to arise either alone or in combination.’ Regarding air quality, the HRA concluded that The draft London Plan contains fourteen policies that either make reference to improving air quality in London (other than greenhouse gases which are not directly relevant to impacts on European sites), or which will improve air quality via their delivery, demonstrating a strong commitment to improve air quality within the Greater London Authority boundary. Whilst it is noted that the aim is in general to improve air quality from a public health perspective, any improvement in air quality will have a positive knock-on-effect to European designated sites that are sensitive to atmospheric pollution.

Guildford Local Plan 2003 2003 Policy on housing provision no longer being applied; interim housing target of 322. Proposed Submission Local Plan 2018 2018 Submission Plan: 12,426 homes are planned over the Plan period 2015-2034. Staggered as follows:

23 Local Local Plan(s) Main Matters of Relevance Authority

36,100 to 43,700sqm of office and R&D floorspace, 3.7-4.1ha of industrial floorspace, 41,000sqm of comparison retail floorspace, 4 gypsy and traveller pitches to and 4 travelling show people plots.

OAN: 693 p/a to 2033 (Source; 2015 SHMA)

An HRA (2016) was published to support the Proposed Submission Local Plan: strategy and sites (2016). This has been updated to take account of changes in the Proposed Submission Local Plan: strategy and sites (2017). It focused upon issues related to the Thames Basin Heaths SPA and does not refer other international sites.

Horsham Horsham District Planning The Horsham District Planning Framework (HDPF), with the exception Framework (Adopted November of land within South Downs National Park, replaces policies contained 2015) in the Horsham District Core Strategy and General Development Control Policies adopted in 2007.

The HDPF proposes 16,000 new homes over the plan period 2011 – 2013. It includes a general policy protecting nature conservation designated sites.

24 Local Local Plan(s) Main Matters of Relevance Authority The HRA concluded that, taking into account proposed avoidance and mitigation measures the plan will not have an adverse effect on site integrity of any European site, alone or in combination with other plans or projects.

Kingston- Kingston Core Strategy (adopted Adopted in April 2012 Provision of 5625 homes between 2012 and upon- 2012). 2027. 50000 sq.m of retail floorspace. Will be replaced by the Thames Kingston Local Plan 2019 – 2041.

Draft London Plan Consultation 1 December 2017 – 2 March 2018

Kingston 2019/20 – 2028/29 = 13,640. Per annum=1,364

Core Strategy - Potential for impact on Natura 2000 sites from recreational pressures and air pollution, however taking into account the location of most growth and measures to reduce air pollution the Plan is unlikely - either alone or in combination - to have a significant impact on these sites Lewes Core Strategy (Adopted 2016) The Core Strategy identifies 6,900 homes between 2010 and 2030, mostly distributed away from northern rural area nearest to Ashdown Forest.

Mid Sussex Mid Sussex District Plan 2014- An average of 876 new homes per year until 2023/24. An average of 2031 Adopted 2018 1,090 new home per year between 2024/5 and 2030/31 subject to no further harm to the integrity of the Ashdown Forest. 23 additional traveller pitches. 25ha business park

The HRA concluded ‘No adverse impact on Mole Gap to Reigate Escarpment SAC.

25 Local Local Plan(s) Main Matters of Relevance Authority Adverse effects resulting from atmospheric pollution are not considered likely for the Ashdown Forest SAC. Disturbance impacts are assessed as potentially affecting the Ashdown Forest SPA, however, they are considered to be adequately avoided and mitigated by the District Plan via the implementation of SANG.’

Mole Valley Core Strategy 2009 (2006-2026) Stipulates 3,760 homes, 6-7 additional traveller pitches, 2800sqm of Submission draft Development new convenience retail floorspace to be delivered in the plan period Management Plan 2018 2006 and 2026.

OAN: 7,814 (2015-2035) 391 p/a (Source: SHMA June 2016).

The Plan Introduced policy (CS15) to protect Mole Gap to Reigate Escarpment SAC and seeks to prevent development within 800m of the site, unless the effect of development can be mitigated.

An HRA was undertaken in 2008. It concluded that, with measures put in place as part of the preparation and adoption of the Core Strategy, the Plan, in-combination with others, would not have a significant in combination impact on the Natura 2000 Sites.

No change to plan since adoption of the Core Strategy. Regulation 18 consultation document for revised local plan has been consulted on, but scale/location of development has not been finalised.

Reigate Core Strategy (2012-2027) The Core Strategy identified 6,900 homes to be delivered (460 homes and adopted in 2014. per year). It introduced a policy to assist in the protection of the Mole Banstead Gap to Reigate Escarpment SAC.

Most of housing is to be delivered in existing urban areas, with some

26 Local Local Plan(s) Main Matters of Relevance Authority to be delivered on urban extensions away from close proximity to Mole Gap to Reigate Escarpment SAC.

An HRA Summary was published in March 2014. Supporting HRA was prepared for the submission stage (May 2012); an update was then published alongside the Core Strategy Further Amendments (Dec 2012). It considered both the Mole Gap to Reigate Escarpment and the Ashdown Forest but concluded that the Core Strategy, alone and in combination with other plans and projects, would have no adverse impact on the integrity of Natura 2000 sites.

Rother Core Strategy 2011 – 2028 Identifies 5,700 new dwellings over the plan period 2011 – 2028. (adopted September 2014) The accompanying HRA screened out the Ashdown Forest SAC due to Part 2: ‘Development and Site the distance from the boundary of the District and distance from Allocations Plan’ submission settlements identified as suitable for development within the Plan. expected in 2018. Reg 18 consultation undertaken December 2016 to January 2017. Sevenoaks Core Strategy (2006-2026) The Core Strategy identifies 3,300 homes to be delivered throughout the plan period. The A&DMP indicates 4,732 likely to be delivered Allocations and Development during the plan period. Management Plan (A&DMP) (Adopted Feb 2015) Their current objectively assessed needs (OAN) is 12,400 new homes.

Sevenoaks are in the process of preparing a new Local Plan from 2015 to 2035. They consulted on their Regulation 18 in August/September 2017 and are preparing to consult on another Regulation 18 in July/August 2018.

An HRA of the Sevenoaks District Local Plan 2015-2035 Issues and

27 Local Local Plan(s) Main Matters of Relevance Authority Options Consultation was published in August 2017. It considers the impacts of various Local Plan growth options. For the Ashdown Forest, it suggests a 7-9km zone for recreational pressure. For air quality it suggests that due to the distances involved and the relatively small number of journeys to work from Sevenoaks south to Ashdown Forest, even a large quantum of new growth in the District may not have much effect on daily traffic flows through the SPA/SAC, but recommends further modelling and analysis of the anticipated Local Plan air quality impact is undertaken in combination with neighbouring authorities.

South Submission South Downs Local Plan Total Housing 4,977 (2014 – 2033) Downs (April 2018) National HRA 2018: On Ashdown Forest SAC/SPA cited Ashdown Forest working Park group as a safeguard, noting ‘The shared objective of the working Authority group is to ensure that impacts on the Ashdown Forest are properly assessed through HRA and that, if required, a joint action plan is put in place should such a need arise. It should be noted that the absence of any need for ‘mitigation’ associated with future growth in a particular authority does not prevent the various Ashdown Forest authorities cooperatively working together to do whatever they jointly consider appropriate in reducing traffic and improving nitrogen deposition etc. around the Forest as a matter of general good stewardship. This would also enable future trends in air quality to be tracked and the modelling (and responses to that modelling) to be updated as necessary. The aforementioned working group would be a suitable forum for this cooperative working.’ Surrey Surrey Waste Plan 2018 Identifies Strategic Waste Site Allocation in the District – Land at County Lambs Business Park, Terra Cotta Road, South Godstone (considered Council Draft plan consultation in Air Quality Impact Assessments for Mole Gap to Reigate Escarpment (Regulation 18) November 2017 and Ashdown Forest)

28 Local Local Plan(s) Main Matters of Relevance Authority to February 2018. SCC HRA: Possible effects identified on Natura 2000 sites from thermal processing emissions, traffic emissions, dust, land take, water discharge, pest and predators and litter. Concludes that proposed developments were unlikely to result in harmful impact and that the Plan would not have any alone or in-combination effects on European sites. Surrey Minerals Plan 2011 No adverse impact on the Mole Gap to Reigate Escarpment identified. Surrey Aggregates Recycling The Plan would not give rise to any significant effects on the condition Joint DPD 2013 and integrity of Natura 2000 sites

Local Transport Plan 2014 Objective of securing reliable transport network and promoting sustainable transport options. The Plan would not give rise to any significant effects on the condition and integrity of Natura 2000 sites

Sutton Local Plan Adopted 2018 The target is to deliver at least 6,405 new homes over the plan period 2016-2031 (427 new homes per year). At least 10 ha for industrial uses, 23,000sqm office floorspace, 36,000 retail floorspace and 10,000sq gross for leisure uses.

No policies specifically relate to the Mole Gap to Reigate Escarpment SAC or to international designated sites. No likely significant effects on European sites identified. NE agreed no impact upon the designated sites as there isn’t a direct impact pathway due to the distances involved. Tunbridge Core Strategy 2010 Adopted Core Strategy figure is 300 pa. Wells Site Allocations Local Plan The latest OAN is for 648 dwellings per annum, or 12,960 over 20 (adopted July 2016) years (2013 – 2033).

29 Local Local Plan(s) Main Matters of Relevance Authority Producing a new Local Plan up to 2033 to replace existing Local Plan 2006, Core Strategy and Development Plan Documents. Waverley Local Plan (Adopted Feb 2018) Provision of 11,210 new homes between 2013 and 2032. Traveller target tbc. At least 16,000sqm of office/R&D space.

A Part 1 HRA was published in 2016 which noted that the Mole Gap to Reigate Escarpment SAC lies approximately 11km from Waverley Borough at its closest point, which is the popular tourist spot of Box Hill, north of Dorking. It commented that the SAC is relatively easy to access from settlements including Godalming and Cranleigh and that the SAC lies within the typical distance over which visitors will travel to reach a countryside site for a day visit. As the SAC is sensitive to recreational pressure, the issue was screened in within supporting text. However the overall conclusion that the Waverley Borough Local Plan Part 1 (Strategic Policies and Sites) will have no adverse effect on the integrity of any European sites, within or beyond the borough boundary, either alone or in combination with other plans and projects. For air quality, the HRA noted that Policy MT1 (Sustainable Transport) would mitigate by minimising atmospheric pollution and improve air quality, and concluded that there will be no residual likely significant effects on the Mole Gap to Reigate Escarpment SAC.

Wealden Core Strategy (2006-2027) The Core Strategy had a housing target of 9,440 homes by 2027. 32 additional traveller pitches. 40,000sqm employment floorspace. The New Local Plan 2013-2028. The New Local Plan identifies 11,456 dwellings, 7,392 granted planning Proposed Submission Plan will be permission therefore the draft Proposed Submission Local Plan published for the Local Plan Sub Committee which is scheduled for provides for an extra 4,064 built by 2028. 5th July 2018. Policy WCS12 proposed specific policy on protection of Ashdown

30 Local Local Plan(s) Main Matters of Relevance Authority Forest. This had the effect of preventing development within 7km of the forest until adequate mitigation was in place. This policy was quashed by a Court of Appeal judgement on procedural error relating to the SEA regulations. A similar policy will be applied in the interim, however.

Ashdown Forest SAC/SPA lies within Wealden District. Historic studies into transport and air quality impacts on development upon Ashdown Forest have been coordinated by Wealden District Council.

In the interim, Wealden DC have placed District wide restrictions on new development, based on the precautionary principle.

WDC is currently updating the Wealden District Council Air Quality and Ecology report to inform the Appropriate Assessment and the Habitats Regulations Assessment (HRA) in order to deliver an updated Wealden Local Plan by the end of June for consideration at the Full Council meeting on 18 July 2018.

Woking Core Strategy October 2012. 4,964 (292p/a) dwellings between 2010 and 2027.

Draft Site Allocations DPD 2017 OAN: 517 p/a to 2033 (Source; 2015 SHMA)

Development Management HRA (Dec 2016): Woking Site Allocations DPD not been fully screened Policies DPD out as having no likelihood of leading to significant adverse effects on European sites, for the following reason: Recreational Pressure on Thames Basin Heaths SPA.

31 3. Appropriate Assessment of the Mole Gap to Reigate Escarpment SAC

3.1 Citation, Qualifying Features, Conservation Objectives and Condition Status

Table 2 in section 2.4 set out the key information in relation to this site, including qualifying features conservation objectives and condition status

Appendix 1c shows the formal site citation for the SAC.

Appendix 2b shows the SSSI condition analysis. It shows that just over half the site is in favourable condition, with the remaining almost entirely unfavourable recovering. More detail regarding the condition of individual units within the SAC can be found on natural England’s website.10

It is important to note that the SSSI covers a larger area than the SAC (1,016ha to 894ha). However all areas of SAC are also SSSI, so the SSSI condition analysis is a useful proxy for the condition of the SAC.

3.2 Process of Assessment and Duty to Cooperate

Tandridge District Council initiated discussions with Mole Valley District Council and Reigate & Banstead District Council in June 2017 in relation to the SAC, in particular the implications of the Wealden judgement on consideration of air quality matters. As a result of ongoing cooperative working the three authorities agreed to jointly commission consultants to undertake Air Quality Impact Assessments, specifically looking at traffic- related effects on Mole Gap to Reigate Escarpment SAC. This work was led by Tandridge District Council and undertaken by Aecom consultants. The final output consisted of three reports, one for each authority and the Tandridge technical paper forms part of the publicly available evidence base for the Local Plan.

10 https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=S1000977&SiteName= gate&countyCode=&responsiblePerson=&SeaArea=&IFCAArea=

32 3.4 Recreational Disturbance Impact Pathways

3.4.1 Initial Screening Report (August 2017)

The HRA Stage 1 screening looked at the possible effect of the Local Plan on the Mole Gap to Reigate Escarpment SAC in terms of ‘Low recreational disturbance’. It noted that ‘Additional development promoted in the Local Plan has an associated risk of leading to additional recreational visitors to the site, having a negative impact on the integrity of the site’. In terms of ‘Likely Significant Effects (including in-combination impacts)’, HRA Stage 1 stated the following:

‘Natural England suggest that recreational disturbance can have a negative impact on the chalk grassland, with dog walking and related nutrient enrichment of grassland impacting on the integrity of the site.

The potential location promoted for a ‘Garden Village’11 at Redhill Aerodrome is approximately 5km from the Mole Gap to Reigate Escarpment SAC. Proximity to protected international sites is associated with increased risk of recreational disturbance.

At this stage it cannot be ascertained whether development anticipated from the Local Plan, including the Redhill Aerodrome Garden Village option, will affect the integrity of the site either alone or in-combination with other plans. Consequently, using the precautionary principle, we will have to consider this effect at the next stage of the HRA process or undertake another Screening Assessment when more information is known.’

3.4.2 Natural England Screening Opinion

In response to HRA Stage 1, Natural England has advised that recreational impact on the Mole Gap and Reigate Escarpment SAC can be screened out (see Appendix 3).

The following sections serve to examine the available evidence to confirm and validate the Natural England statement, in light of the Council’s statutory role as Competent Authority.

11 Please note the term ‘Garden Village’ has now been changed to ‘Garden Community’

33 3.4.3 Current Recreational Pressures

3.4.3.1 Species and Habitats

The Mole Gap to Reigate Escarpment Site Improvement Plan has the following Issues and Actions in relation to Public Access/Disturbance: ‘As a beautiful place to visit, this area of Surrey is heavily populated. Increasing pressure by increased numbers of visitors on protected sites and disturbance on the species which live here can become damaging. Trampling of orchid-rich grasslands, repetitive disturbance to Great crested newt breeding ponds, and spread of disease (such as box blight) are examples,’ The SIP also highlights the need to protect Bechstein's bat hibernacula (Deciduous woodland) in relation to recreational disturbance’.

Bechstein's Bat

The HRA Screening of Gatwick Runway 2 by RPS in December 2017 provided useful indication of the locations of the orchid-rich grasslands – the habitat cited as particularly vulnerable in Natural England’s Site Improvement Plan (SIP). Their analysis identified two SSSI units that were described as supporting good populations of orchid species.

 Unit 011 South of Zig Zag Road  Unit 036 Dawcombe

011 Unit South of Zig Zag Road - favourable, no identified condition threat Diverse area of chalk grassland with scattered scrub and some predominantly Yew woodland bordering the grassland. Very steep with the main access road to the visitor centre running through it and generally well used by visitors making it a difficult site to manage. Cattle grazing is carried out and rabbits are evident, scrub management and some cutting and raking of selected areas are all contributing to a valuable, varied and favourable unit. Tor grass and upright brome are scattered throughout but at acceptable levels (together about 20%) thatch and other negative indicators (ragwort 1%) are well below threshold levels or absent. Dominant indicator species (10 of 10) Birdsfoot trefoil, Salad burnett, also Rough hawkbit (9 of 10) Dwarf thistle (7 of 10) and Squinancywort (6 of 10). Gentians and Carline thistle both (4 of 10) Clustered bell flower, Ladies bedstraw, and Small scabious all (3 of 10) Also Kidney vetch

34 and Common Rockrose (1 of 10) Other species include Eyebright, Orchid spp, Harebell, Burnett saxifrage and Yellow-wort.

036 Dawcombe - unfavourable recovering, low condition threat Grassland adjacent to woodland with areas of scattered scrub and a boundary of trees against the road. Site is only grazed by rabbits and the local wildlife trust have been very active in keeping scrub down to acceptable levels by hand, grazing is planned. Salad Burnett dominant (10 of 10) Thyme abundant (8 of 10) Squinancywort, Dwarf thistle and common rockrose frequent (6 of 10). Birds foot trefoil and Mouse- ear Hawkweed occasional (4 of 10) Cowslip, Rough Hawkbit and Small scabious rare (2 of 10) Also present on the site are a variety of Orchid species and Twayblades, Autumn Gentian, Carline thistle and Burnett saxifrage. Regenerating scrub is present throughout the grassland areas with Torgrass in 3 small patches, but grazing, when introduced, is expected to get this under control.

These two units have been highlighted green on Map 2 to illustrate the location of the priority habitats.

Unit 36 is 7.8km from the Tandridge District Council boundary and Unit 11 is 11km, so the main areas of ecological pressure are notably further from the Tandridge District Council area.

Map 2: Mole Gap to Reigate Escarpment Priority Habitats

Source: RPS Gatwick Runway 2 Mole Gap to Reigate Escarpment SAC & Ashdown Forest SPA/SAC Revised Habitat Regulations Assessment Report: Stage 1 (Screening) Appendix 5

35 3.4.3.2 Visitor Patterns and ‘Honeypot’ Sites

Bournemouth University undertook Visitor Surveys of the Mole Gap to Reigate Escarpment in 2005 and 2006, on behalf of the National Trust. In addition a further National Trust Visitors Survey was undertaken at Box Hill in 2004. These two surveys provide the most recent information regarding visitors to the SAC. The two studies have been analysed within HRAs undertaken by Mole Valley DC, Reigate & Banstead BC and Croydon BC. This section draws on previous analysis, as well as giving further consideration to the findings and their implications.

The studies indicate that recreational pressure at the Mole Gap to Reigate Escarpment SAC is focused mainly around honey pot sites, with the majority of impact being within a small radius of the car parks. The identified ‘honeypot’ sites are set out in Table 4 below:

Table 4: Mole Gap to Reigate Escarpment ‘Honeypot’ Sites

Site Estimated Annual Visitors Distance from Tandridge DC Boundary Box Hill 828,000 11.8 km Headley Heath 209,000 9.4 km Reigate Hill & Gatton Park 268,000. 4.1 km

Bournemouth University surveyed the area around the car park. They found that the visitor area was small, the majority of visitors travelling only a short distance from the car park. There was found to be a large visitor impact within about 100m of the car park, but beyond about 1 km of the car park, the impact was very low. This supports other findings that recreational pressure on the SAC is focused around honeypot sites.

Table 5: Mole Gap to Reigate Escarpment ‘Honeypot’ Sites – Travel Distances of Visitors

Distance from Percentage of visitors at each site by origin (distance from home (Miles) home). 75th percentile highlighted bold*. Box Hill Headley Reigate Hill and Gatton Park Under 5 14 18 7 5 -14 15 28 12 15-24 10 20 15 25 – 49 41 29* 28 50 -74 12* 3 20* 75 + 8 2 18

The studies showed that the SAC has a very wide Zone of Influence. For the two most popular sites (Box Hill and Reigate Hill/Gatton Park), the 75th percentile of visitors travel falls at 50-75 miles (80-121km), indicating a large and dispersed catchment.

36 In this case, using a distance of less than 50 miles to define the core catchment (i.e. the zone within which most visitors arise) would risk failing to capture the majority of visitors, while one of greater than 50 miles would involve such a large catchment as to be completely unmanageable from the point of view of assessment or mitigation responsibility (i.e. bringing in not only London but also most other parts of the South- East).

3.4.4 Effect of Tandridge District Local Plan

Given the extremely large and populated catchment area, which includes all of Greater London (population 8.8 million) as well as much of the South-East, Tandridge residents are likely to make very modest proportion of overall visitor numbers. Analysis of the National Trust Visitors Survey of Box Hill (2004) supports this hypothesis. As stated in Croydon’s 2016 HRA: ‘In 2004 visitors to Box Hill were asked to note down the postcode from which they had travelled. There were over 5,300 responses. The results showed that there was a considerable spread in terms of visitor origin but that the main sources were Leatherhead and South London including Sutton, Carshalton and Croydon.’

Therefore, this validates the Natural England recommendation that recreational impacts from the Tandridge Local Plan 2033 can be screened out.

However, although not considered significant, it is nonetheless reasonable to assume that new Tandridge residents may still contribute marginally to overall recreational pressure on the SAC, unless the Local Plan promotes policies that will dissuade them. The matter can be considered within the context of other initiatives within the Tandridge Local Plan that may lead to a decrease in recreational pressure.

Such an approach is consistent with the approach of the Greater London Plan (GLP). The GLP Draft HRA (November 2017) which was included alongside the consultation noted the Mole Gap to Reigate Escarpment SAC is just over 5km from Greater London at its closest. It concluded that ‘Since it is not a conveniently situated site for casual recreational visits for most Londoners, and London (particularly the boroughs closest to the SAC) has a large amount of its own high quality recreational natural greenspace, recreational pressure from the new London Plan is unlikely to arise either alone or in combination.’ Regarding air quality, the HRA concluded that The Draft London Plan contains fourteen policies that either make reference to improving air quality in London (other than greenhouse gases which are not directly relevant to impacts on European sites), or which will improve air quality via their delivery, demonstrating a strong commitment to improve air quality within the Greater London Authority boundary. Whilst it is noted that the aim is in general to improve air quality from a public health perspective, any improvement in air quality will have a positive knock-on-effect to European designated sites that are sensitive to atmospheric pollution.

37 Therefore, it is still considered appropriate for Tandridge Local Plan to consider suitable measures to reduce the risk of significant impacts occurring in future, as set out in the following section.

3.4.5 Local Plan Considerations

In Local Plan consultation representations, the Surrey Wildlife Trust recommended development of impact avoidance strategies in relation to the Mole Gap to Reigate Escarpment SAC.

In terms of avoidance, it is important to note that now that South Godstone has been chosen as the preferred location for the new Garden Community, there are no allocated residential development sites within the Tandridge Local Plan 2033 that are within 7km of the Mole Gap to Reigate Escarpment SAC. Nationwide, 5km or 7km are typically the threshold distances applied to SACs within which residential development is required to mitigate its recreational impact.

A further reassurance and safeguard in the Local Plan 2033 will be the allocation of new open spaces and identification of improved links to the countryside from urban areas, and improvement of existing open spaces for recreation.

A particular benefit on a strategic scale would be a commitment to a large scale (100ha+) area of green infrastructure alongside the new Garden Community. This is justified by the access deficit to strategic scale natural and semi natural greenspace demonstrated by applying Natural England’s ANGSt standard in the Open Space Study background evidence paper (2017). However, there are knock-on benefits to such provision – it will serve many of the functions of a Suitable Alternative Natural Greenspace (SANG), being attractive to local residents and in turn discouraging them from travelling further afield to make recreational visits to the more ecologically vulnerable international sites outside the District boundaries.

There are other measures that could be included in Local Plan policies that would have a positive effect in respect of recreational pressures on the Mole Gap to Reigate Escarpment SAC. Protection of ancient woodland with suitable buffers; policies promoting creation, enhancement and improved connectivity of woodlands; and/or adoption of Woodland Trust access standards would all be beneficial in supporting habitats for Bechstein`s Bat (Myotis bechsteinii), a qualifying feature of the SAC.

Similarly, policies promoting creation, enhancement and improved connectivity of wetland habitat and ponds may benefit the Great Crested Newt, also a qualifying feature of the SAC. In particular, the potential for green infrastructure alongside the Garden Community to overlap with the Eden Biodiversity Opportunity Area provides such opportunity. However, ponds would be an expected feature of any large area of green infrastructure, regardless of location.

38 3.4.6 Conclusions

The Mole Gap to Reigate Escarpment is not a conveniently situated site for casual recreational visits for Tandridge residents and the implementation of policies within the Local Plan, including new green infrastructure, will add further reassurance that the Local Plan will not result in any significant adverse effects on the integrity of the SAC, either alone or in combination.

39 3.5 Hydrology Impact Pathways

3.5.1 Introduction

The River Mole originates south of Crawley in West Sussex and flows through the Surrey districts of Tandridge, Mole Valley, Reigate and Banstead and Elmbridge for approximately 50 miles before reaching the Thames at Molesey. Parts of Tandridge District are within the operational catchment of the Upper Mole tributaries, as Maps 3 and 4 illustrate.

Much of the river flows over Wealden and London clays. Between Dorking and Leatherhead, in the area known as the Mole Gap, the river cuts its way through the North Downs chalk. In this area some of the river water disappears through holes in the chalk into the groundwater aquifers before flowing back into the river near to Leatherhead. This phenomenon has been suggested as giving the river its name.

Potential impact vulnerability from hydrology has been highlighted via a couple of sources. Initial Natural England advice in 2017 suggested looking at river flow from the District connecting to the SAC, which the August 2016 screening report did, and this report elaborates on. Natural England subsequently agreed that the issue should be ‘screened in’. In addition the emerging Reigate & Banstead HRA dating back to 2016 highlighted a specific vulnerabilities associated with the Mole Gap to Reigate Escarpment SAC is: ‘Hydrological changes may impact on ponds within the chalk heath, either through pollution or groundwater abstraction.’

40 Map 3: River Mole Catchment by Local Authority Map 4: Upper Mole Tributaries operational catchment

Source: Environment Agency, River Mole Catchment Management Plan 1995 Source: The Environment Agency

41 The TDC Strategic Flood Risk Assessment (SFRA) identifies the main watercourses in the study area, including the following that connect Tandridge District to the River Mole:

 River Mole  Salfords Stream (Tributary to River Mole)  Burstow Stream (Tributary to River Mole)

Map 5: Main watercourses in the study area

Source: TDC Strategic Flood Risk Assessment (SFRA)

42 3.5.2 Initial HRA Screening Report (August 2017)

The HRA Stage 1 screening looked at the possible effect of the Local Plan on the Mole Gap to Reigate Escarpment SAC in terms of Drainage and Water Pollution. It noted that:

Natural England’s SSSI Impact Risk Zones (IRZs) extend from the Mole Gap to Reigate Escarpment SSSI out across an area of the west side of Tandridge District that includes much of the Redhill Aerodrome potential Garden Village location, as well as other areas including Nutfield and land west of Chaldon. The IRZ notes that any proposals that generate a discharge of water or liquid waste greater than 20 cubic metres per day (that would not go into a mains sewer) would need to be looked at in more detail. A more stringent threshold of 5 cubic metres per day applies to a much smaller area of Tandridge District east of Redhill and north of the Redhill to Godstone railway line.

As noted in Table 1 the Mole Gap to Reigate Escarpment SSSI covers a similar area than the SAC of the same name. So impacts upon the SSSI are highly relevant to consideration of likely significant effects on the SAC.

The possibility of several thousand homes being constructed on the Redhill Aerodrome potential Garden Village Location, which may be partially within the SSSI IRZ therefore needs further consideration. This is, particularly as there appears to be a hydrological pathway in the form of the River Mole and its tributaries which flows north-west from this area connecting to the Mole Gap to Reigate Escarpment SAC.

Development of any significant scale (i.e. to warrant a Local Plan allocation) would link to the mains sewer system. TDC Local Plan ‘Detailed Policies’ (Adopted 2014) DP21 on Sustainable Water Management encourages the use of SuDS. However, The Local Plan 2033, which will also take forward a preferred Garden Village Option, will need policy to categorically ensure the delivery of SuDS in the IRZ before this possible effect can be fully screened out.

3.5.3 Natural England Screening Opinion and Views

In response to HRA Stage 1, Natural England agreed that hydrology should be screened in (see Appendix 3). However subsequent queries to Natural England regarding the interpretation of the SSSI impact zone requirements have proven inconclusive.

As part of the process of AA, other sources of information have been investigated in regard to this issue.

3.5.4 Evidence Gathering

43 According to the latest Environment data available online12 there are 22 water bodies in the Mole Management Catchment. The Ecological classification for surface waters 2016 Cycle 2 breaks down as follows: Bad: 1 Poor: 7 Moderate: 12 Good: 2 High: 0

Reasons for not achieving good status and reasons for deterioration in the Mole management catchment are diverse, but include: domestic general public, urban and transport. The EA’s 2014 ‘Mole management catchment’ Report suggested that the water bodies of the Upper Mole tributaries were of comparatively worse quality

Figure 1– Classification and long term objectives of all water bodies in the Upper Mole tributaries catchment in cycle 2.

Source: Environment Agency: The Mole management catchment: A summary of information about the water environment in the Mole management catchment

In their 2014 report ‘The Mole management catchment: A summary of information about the water environment in the Mole management catchment’ the EA state that

12 http://environment.data.gov.uk/catchment-planning/ManagementCatchment/3058/Summary

44 their assessments have shown all ground water bodies in the area are at risk from rising concentrations of pollutants and over abstraction.

Since the initial assessment of status was made, the Environment Agency and its partners have been working to determine the reasons why water bodies in the Mole management catchment have not achieved good status and the likely causes. The EA’s 2014 report states that pollution from waste water is the main challenge affecting the water environment in this catchment, the main source of this pollution is from treated sewage discharges containing phosphate and in some cases ammonia which adversely affect the waters ability to support fish and invertebrates. In addition, man-made physical modifications have led to a build-up of silt in many places. The EA 2014 report also states that ‘Diffuse pollution, which is pollution from widespread activities rather than a specific source, is also a challenge and is present along the river. This comes from both urban areas where run off from roads and misconnected properties add to pollution and from rural areas where pollutants can run off fields into the river if not managed properly.’

The Water Framework Directive assessment, which is summed up in Table 6 below, also cites surface water run-off as a key issue for the Upper Mole tributaries.

45 Table 6: Ecological potential/status of surface waterbodies and catchments in Surrey (2015)

Source: Surrey Local Waste Plan 2018 -2033 (December 2017) derived from data for the 2015 reporting cycle under the Water Framework Directive (data source: http://environment.data.gov.uk/catchment-planning/)

3.5.5 Effect of Tandridge District Local Plan

In light of the above factors, it is considered that the Tandridge Local Plan 2033 needs to be mindful of this issue, in relation to development that takes place within the River Mole catchment. This includes settlements of Smallfield, South Nutfield and others (see Map 4).

It also includes the Redhill Aerodrome Garden Community site, which has been considered but is no longer the preferred option for a Garden Community in the plan period to 2033, whilst South Nutfield has been classified as a Tier 3 ‘rural settlement’ and therefore unsuitable for development. However, Smallfield has been classified as a Tier 2 settlement hierarchy and is likely to have residential development allocations.

However, whilst the focus of the HRA is on international sites, it is perhaps worth highlighting that this issue may also be relevant to other protected areas, such as the network of Sites of Special Scientific Interest (SSSIs) – so may be beneficial on a plan- wide basis.

3.5.6 Local Plan Considerations

46 Sustainable Drainage (SuDS) techniques can address issues of water quality. The 2014 DEFRA/DCLG report ‘Delivering Sustainable Drainage Systems’ stated that ‘Planning applications that fail to meet a policy requirement to normally deliver SuDS first over conventional drainage could be rejected’.

Other background evidence supporting the Local Plan overlaps with the issue of appropriate SuDS techniques. The ‘South East Seven’ Lead Local Flood Authorities (LLFA), which include Surrey County Council have published 'Water, People, Places - A guide for master-planning sustainable drainage into developments' (WPP) for use by developers and planners and other practitioners involved in the planning and design of the built environment in the South East of England. It includes guidance on designing SuDS to deliver specific benefits, including both 'Water Treatment' and ‘Biodiversity and Habitat'. Regarding 'Water Treatment' it states 'Pollution typically found in runoff including sediment, oils, metals, fertilizer, pesticides, and rubbish can be harmful to watercourses and coastal waters. The soils, gravels and vegetation present in many forms of SuDS act as filters, removing many pollutants before returning cleansed water to the natural environment. WPP also advises on techniques to prevent runoff from reducing the quality of a receiving body of water. It notes that 'Different SuDS will provide different types of treatment, and a ‘treatment train’ of SuDS (see chapter 3) should be introduced to ensure water is exposed to a variety of filtration mechanisms and attenuated to allow pollutants to settle out. For example, runoff can be conveyed from permeable paving to a swale, before being treated in a wetland and discharged to provide three stages of treatment. Any water being discharged into a water body should be well treated to remove nutrients and sediments and a greater number of treatment stages is likely to be required when the receiving body quality is high.'

WPP contains a matrix to inform the selection of appropriate SuDS for these benefits. The key sections that apply by focusing on water treatment are set out in Table 7 below.

Table 7: ‘Water People Places’ SuDS Selection Matrix

Tandridge’s own SFRA (December 2017) echoes this approach, containing the following table and stating the text below it.

Table 9: TDC SFRA SuDS Selection Matrix

47

A key part of the four pillars of SuDS is to provide the maximum improvement to water quality through the use of the SuDS Treatment Train. To maximise the treatment within SuDS, CIRIA recommends the following good practice guide is implemented in the treatment process:

Manage surface water runoff close to source: This makes treatment easier due to the slower velocities and also helps isolate incidents rather than transport pollutants over a large area. Treat surface water runoff on the surface: This allows treatment to be delivered by vegetation and the sources of pollution to be more easily identified. It also helps with future maintenance work and identifying damaged or failed components of the treatment train. Treat a range of contaminants: SuDS should be chosen and designed to deal with the likely contaminants that may pose a risk to the receiving environment and be able to reduce them to acceptably low levels. Minimise the risk of sediment remobilisation: SuDS should be designed to prevent sediments being washed into receiving water bodies or systems during events greater than those for which the component may have been specifically designed. Minimise the impact of a spill: Designing SuDS to be able to trap spills close to the course, facilitate contamination management and removal. The selected SuDS should also provide robust treatment along several components in series.

The number of treatment stages required depends primarily on the source of the runoff. The C753 SuDS Manual advises a simple index approach to determining the number of treatment stages. This involves determining a pollutant hazard score for each pollutant type. An index is then used to determine the treatment potential of different SuDS features for different pollutant types. This is known as the mitigation

48 index. The total SuDS mitigation index should be equal or greater than the pollution hazard score to deliver adequate treatment.

3.5.7 Recommendations

In order to minimise the conveyance of pollutants to the Mole Gap to Reigate Escarpment SAC, it is a recommendation of this HRA that policies are applied ensuring that SuDS schemes mitigate the potential for surface water runoff from sites to affect water quality.

To achieve this, SuDS selection should ‘achieve improvements in water quality through a sustainable drainage management train’. In practice this will be in accordance with the SFRA techniques to prevent runoff from reducing the quality of a receiving body of water (i.e. by implementation of SuDS benefitting ‘water quality treatment and enhancement’ via a treatment management train). This is in accordance with the ‘precautionary approach’

An additional benefit of this policy is that by providing biodiversity and habitat benefits, SuDS can provide additional associated and supporting 'Stepping Stone' Priority habitats (i.e. ponds, watercourses or reed beds). This will benefit the Great Crested Newt in particular, as well as helping contribute towards the Plan achieving a net gain in biodiversity.

49 3.6 Air Quality Impact Pathways

3.6.1 Initial Screening Report (August 2017)

The HRA Stage 1 screening looked at the possible effect of the Local Plan on the Mole Gap to Reigate Escarpment SAC in terms of ‘Minimal air pollution’. It noted that ‘additional development promoted in the Local Plan, in combination with other plans or programmes, causing increase in traffic movements on roads which pass close to the protected site, increasing air pollution within the site.’

In terms of likely significant effect on the protected site (including in-combination impacts), the stage 1 screening stated the following:

‘There is a need to consider additional transport movements upon roads that pass near to the protected site. It is necessary to consider cumulative impacts and in combination impacts alongside other the other relevant local planning authorities.

As a result we are unable to say at this point that the Local Plan would not have a significant effect on air pollution, either alone or in combination. Thus, using the precautionary principle, we will have to consider this effect at the next stage of the HRA process, unless the Council undertake another Screening Assessment when more information is known.’

3.6.2 Natural England Screening Opinion

In response to HRA Stage 1, Natural England agreed that air quality should be screened in (see Appendix 3).

3.6.3 Evidence Gathering into effects of Tandridge District Local Plan

Tandridge District Council, in conjunction with Reigate & Banstead Borough Council and Mole Valley District Council commissioned Aecom to analyse the risks posed to the European site via the air pollution pathway as a result of proposed growth in the three authorities to 2033, including growth ‘in combination’ with surrounding authorities.

Specifically this entailed assessing the risk of atmospheric nitrogen deposition and associated threat to European dry heaths, natural box scrub, dry grasslands and scrublands on chalk or limestone (important orchid sites), beech forests on neutral to rich soils, yew-dominated woodlands and Bechstein’s Bat.

The full report is available on the Councils Local Plan evidence webpage.

The report examined four types of pollution:

50 1. The concentration of oxides of nitrogen (known as NOx) in the atmosphere. In extreme cases NOx can be directly toxic to vegetation but its main importance is as a source of nitrogen, which is then deposited on adjacent habitats.

2. The rate of the resulting nitrogen deposition. The addition of nitrogen is a form of fertilization, which can have a negative effect on heathland and other habitats over time by encouraging more competitive plant species that can force out the less competitive species that are more characteristic. Unlike NOx in atmosphere, the nitrogen deposition rate below which we are confident effects would not arise is different for each habitat. The rate (known as the Critical Load) is provided on the UK Air Pollution Information System (APIS) website (www.apis.ac.uk) and is expressed as a quantity (kilograms) of nitrogen over a given area (hectare) per year (kgNha-1yr-1).

3. Ammonia emissions from traffic. In ecological terms ammonia differs from NOx in that it is not only a source of nitrogen but can also be directly toxic to vegetation in relatively low concentrations.

4. Rates of acid deposition have also been calculated. Acid deposition derives from both sulphur and nitrogen. It is expressed in terms of kilo equivalents (keq) per hectare per year.

Vehicle exhaust emissions generally only have a local effect within approximately 200m of the centreline of the road. The rate of decline is steeply curved rather than linear. In other words concentrations will decline rapidly as one begins to move away from the roadside, slackening to a more gradual decline over the rest of the distance.

‘A’ road links within 200m of Mole Gap to Reigate Escarpment Special Area of Conservation (SAC) were identified for investigation. These links were chosen as they are all representative points on the busiest roads through the SAC and are also the roads likely to experience the greatest increase in flows over the period to 2033. As such, these are the roads where an air quality effect due to additional traffic growth is most likely to be observed.

Traffic data were generated for three scenarios:

 Base Case – measured flows for base year 2017  Do Nothing (DN) – flows in 2033 without consideration of the Local Plan  Do Something (DS) - reflects the role of the Tandridge District Council Local Plan, in addition to growth in other authorities. This considered six different scenarios for Tandridge – essentially different options for citing the Garden Community (2b being the preferred South Godstone option).

Using Local Plan growth scenarios and information on total traffic flow, average vehicle speeds and percentage Heavy Duty Vehicles (which influence the emissions profile),

51 Aecom air quality specialists calculated expected NOx concentrations, nitrogen deposition rates, ammonia concentrations and acid deposition rates at receptor points along each modelled road link. The predictions for NOx and nitrogen deposition are based on the assessment methodology presented in Annex F of the Design Manual for Roads and Bridges (DMRB), Volume 11, Section 3, Part 1 (HA207/07)13 for the assessment of impacts on sensitive designated ecosystems due to highways works14.

Background data for NOx and NO2 were sourced from the Department of Environment, Food and Rural Affairs (Defra) background maps15. Background data for ammonia was sourced from the UK Air Pollution Information System (APIS) website.

Given that the assessment year (2033) is a considerable distance into the future, Aecom took account of improvements in background air quality and vehicle emissions that are expected nationally over the plan period. Making an allowance for a realistic improvement in background concentrations and deposition rates is in line with the Institute of Air Quality Management (IAQM) position as well as that of central government16. Background nitrogen deposition rates were sourced from the Air Pollution Information System (APIS) website. Although in recent years improvements have not kept pace with predictions, the general long-term trend for NOx has been one of improvement (particularly since 1990) despite an increase in vehicles on the roads. There is also an improving trend for nitrogen deposition, although the rate of improvement has been much lower than for NOx17. The current DMRB guidance for ecological assessment suggests reducing nitrogen deposition rates by 2% each year between the base year and assessment year. However, due to some uncertainty as to the rate with which projected future vehicle emission rates and background pollution concentrations are improving, the precautionary assumption has been made in this assessment that not all improvements projected by DMRB (for nitrogen deposition) or Defra (for NOx concentrations) will occur. With regards to background ammonia concentrations; as there is greater uncertainty associated with rates of improvement over time, background concentrations were kept the same through all assessment years.

Therefore, the air quality calculations assume that conditions in 2023 (an approximate midpoint between the base year and the year of assessment) are representative of conditions in 2033 (the year of assessment). The effect on the 2033 data is equivalent

13 Design Manual for Roads and Bridges, HA207/07, Highways Agency 14 DMRB advocates a nitrogen deposition velocity of 0.1 cms-1 and that velocity is therefore used in AECOMs modelling. 15 Air Quality Archive Background Maps. Available from: http://laqm.defra.gov.uk/review-and- assessment/tools/background-maps.html

16 For example, The UK Government’s recent national Air Quality Plan also shows expected improvements over the relevant time period (up to 2030) https://www.gov.uk/government/publications/air-quality-plan-for-nitrogen-dioxide-no2-in-uk- 2017 17 Total nitrogen deposition (i.e. taking account of both reduced and oxidised nitrogen, ammonia and NOx) decreased by 13% between 1988 and 2010. This is an improvement of 0.59% per annum on average.

52 to assuming a 0.75% per annum improvement in background NOx concentrations and nitrogen deposition rates between 2017 and 2033.

Annual mean concentrations of NOx were calculated at varied intervals back from each road link up to a maximum of 200m, with the closest distance being the closest point of the designated site to the road.

Traffic flows were modelled on the road links, and differences between ‘Do Something’ and ‘Do Nothing’ scenarios calculated, as well as estimates of the relative contribution of Tandridge Local Plan to ammonia, NOx, nitrogen deposition and acid deposition.

The report concludes that traffic growth on the M25 will not result in a likely significant effect on the SAC due to the absence of SAC quality interest features within 200m of the M25 and the fact that the affected area will experience a net improvement in air quality to 2033. Therefore, the report concentrates on the impacts upon the A217 Reigate Hill and the A24.

With ammonia, no direct toxicity effects of ammonia are expected on the habitats of the SAC irrespective of which Do Something scenario was selected.

NOx concentrations on both the A24 and A217 are forecast to experience a large net reduction by 2033 due to changes in vehicle emissions, notwithstanding the projected increase in traffic on both roads, including that attributable to the Tandridge Local Plan.

For nitrogen deposition, the deposition from additional traffic (irrespective of source) is forecast to be offset by a much larger reduction in background deposition over the same timescale due to improved vehicle emission factors. As a result a net reduction in deposition of 1.5 - 1.9 kgN/ha/yr (depending on link) is actually forecast at the closest parts of the SAC to the A24 and A217 notwithstanding traffic growth.

Therefore, the Local Plan will not prevent the SAC achieving its conservation objectives, even where those objectives involve seeking a net improvement in the conservation status of the SAC.

Scenario 2b (preferred Garden Community at South Godstone) was one of the most preferable in terms of its impacts.

3.6.4 Air Quality: Local Plan Considerations

In line with the recommendations of the Aecom report, whichever scenario is selected, the local authority should introduce a strong sustainable transport policy. Aecom noted that elsewhere in Surrey four broad types of mitigation measure have been identified:

 Behavioural measures and modal shift - reducing the amount of traffic overall;

53  Traffic management - modifying traffic behaviour to control where emissions are generated;  Emissions reduction at source - reducing the emissions level per vehicle; and  Roadside barriers - reducing the impact on the public of emissions.

Through the planning system the Council can secure a range of sustainable travel options and choices to reduce the impact and consequence of the significant travel movements that take place within and across the District. This will include working with partners such as Surrey County Council (as the Highway Authority) and the Highways Agency, to promote travel options which, amongst other things, recognise the importance of – but reduce dependency on – the car, and promote alternative transport choices. In addition, the planning system can also promote more sustainable communities by minimising the need for people to travel to essential services, for example, by:

a. directing development to accessible areas conveniently located near to the services and facilities needed to support communities b. coordinating the provision of services and facilities as part of new development, and ensuring they are adaptable to change in the local population c. promoting better travel choices for existing and new development d. by helping improve the vitality and viability of local shopping centres and parades To conclude: In accordance with recommendations from the Aecom report, the Council should also work with other local authorities (particularly Mole Valley District Council and Reigate & Banstead Borough Council in the first instance), land managers, and strategic highway authorities to develop a framework by which forecast improvements in roadside air quality along the A217 Reigate Hill can be monitored, both in order to confirm that forecast improvements are occurring as predicted and to facilitate introduction of supplementary measures beyond those that will already be implemented by Local Plan policies, if required.

It is also important to note that air quality has been separately investigated as part of the plan evidence base in light of National and European legislation/policy related to human health. Measures and recommendation stemming from this work will inevitably have wider air quality impacts that may in turn benefit the protected international sites. The Local Plan 2033 contains strong commitments to improve air quality. The emerging Air Quality policy requires adherence to the recommendations of the Councils AQA, the Surrey Air Alliance and the Local Transport Plan. Through the Surrey Air Alliance, various measures are being brought forward and developed in the context of air quality, including a draft Low Emissions Strategy (LES), Electric Vehicle Strategy and a set of county wide air quality planning conditions. Also to be considered is the Surrey Transport Plan Air Quality Strategy, Low Emissions Transport Strategy and Electric

54 Vehicle Strategy. In addition the Council’s emerging ‘Sustainable Transport & Travel’ policy requires the provision of electric vehicle charging points for electric vehicles on all developments.

Other policies within the Local plan could have a key role in negating air quality impacts. This may include the provision of green infrastructure, commitments to sustainable transport and development in support of accessible services.

55 4. Appropriate Assessment of the Ashdown Forest SAC

4.1 Citation, Qualifying Features, Conservation Objectives and Condition Status

Table 2 in section 2.4 set out the key information in relation to this site, including qualifying features conservation objectives and condition status

Appendix 1a shows the formal site citation for the SAC.

The SSSI condition analysis (Appendix 2a) shows that the majority (more than three quarters) of the site is unfavourable recovering, with the remainder almost entirely favourable. More detail regarding the condition of individual units within the SAC can be found on natural England’s website.18 It is important to note that the SSSI covers a larger area than the SAC (3,213ha to 2,728ha). However all areas of SAC are also SSSI, so the SSSI condition analysis is a useful proxy for the condition of the SAC.

4.2 Initial Screening Report (August 2017)

The HRA Stage 1 screening looked at the possible effect of the Local Plan on the Ashdown SAC in terms of ‘Minimal air pollution’. It noted that ‘additional development promoted in the Local Plan, in combination with other plans or programmes, causing increase in traffic movements on roads which pass close to the protected site, increasing air pollution within the site.’

In terms of likely significant effect on the protected site (including in-combination impacts), the stage 1 screening stated the following:

‘There is a need to consider additional transport movements upon roads that pass near to the protected site. It is necessary to consider cumulative impacts and in combination impacts alongside the other relevant local planning authorities o. As the recent Lewes District Council High Court decision indicated, even relatively minor increases in traffic can result in a likely significant effect when considered in combination with the plans and policies of other local planning authorities.

As a result we are unable to determine at this point that the Local Plan would not have a significant effect on air pollution, either alone or in combination. Thus, using the precautionary principle, we will have to consider this effect at the next stage of the HRA process, or as part of a further Screening Assessment when more information is known.’

18 https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=S1000977&SiteName= gate&countyCode=&responsiblePerson=&SeaArea=&IFCAArea=

56 4.3 Natural England Screening Opinion

In response to HRA Stage 1, Natural England agreed, in abiding by the precautionary principle, that air quality should be screened in (see Appendix 6).

Image: Ashdown Forest

4.4 Air Quality: Evidence Gathering into effects of Tandridge District Local Plan

Tandridge District Council commissioned Aecom to analyse the risks posed to the European site via the air pollution pathway as a result of proposed growth in the Local Plan to 2033, including growth ‘in combination’ with surrounding authorities. Specifically this entailed assessing the risk of atmospheric nitrogen deposition and associated threat to European dry heaths and Northern Atlantic wet heaths. The full report is available on the Councils webpage.

The report examined four types of pollution:

1. The concentration of oxides of nitrogen (known as NOx) in the atmosphere. In extreme cases NOx can be directly toxic to vegetation but its main importance is as a source of nitrogen, which is then deposited on adjacent habitats.

57 2. The rate of the resulting nitrogen deposition. The addition of nitrogen is a form of fertilization, which can have a negative effect on heathland and other habitats over time by encouraging more competitive plant species that can force out the less competitive species that are more characteristic. Unlike NOx in atmosphere, the nitrogen deposition rate below which we are confident effects would not arise is different for each habitat. The rate (known as the Critical Load) is provided on the UK Air Pollution Information System (APIS) website (www.apis.ac.uk) and is expressed as a quantity (kilograms) of nitrogen over a given area (hectare) per year (kgNha-1yr-1). 3. Ammonia emissions from traffic. In ecological terms ammonia differs from NOx in that it is not only a source of nitrogen but can also be directly toxic to vegetation in relatively low concentrations. 4. Rates of acid deposition have also been calculated. Acid deposition derives from both sulphur and nitrogen. It is expressed in terms of kilo equivalents (keq) per hectare per year.

Vehicle exhaust emissions generally only have a local effect within approximately 200m of the centreline of the road. The rate of decline is steeply curved rather than linear. In other words concentrations will decline rapidly as one begins to move away from the roadside, slackening to a more gradual decline over the rest of the distance.

‘A’ road links within 200m of Ashdown Forest Special Area of Conservation (SAC) were identified for investigation. These links were chosen as they are all representative points on the busiest roads through the SAC and are also the roads likely to experience the greatest increase in flows over the period to 2033. As such, these are the roads where an air quality effect due to additional traffic growth is most likely to be observed.

Traffic data were generated for three scenarios:

 Base Case – measured flows for base year 2017  Do Nothing (DN) – flows in 2033 without consideration of the Local Plan  Do Something (DS) - reflects the role of the Tandridge District Council Local Plan, in addition to growth in other authorities. This considered six different scenarios for Tandridge – essentially different options for citing the Garden Community (2b being the preferred South Godstone option).

Using Local Plan growth scenarios and information on total traffic flow, average vehicle speeds and percentage Heavy Duty Vehicles (which influence the emissions profile), AECOM air quality specialists calculated expected NOx concentrations, nitrogen deposition rates, ammonia concentrations and acid deposition rates at receptor points along each modelled road link. The predictions for NOx and nitrogen deposition are based on the assessment methodology presented in Annex F of the Design Manual for

58 Roads and Bridges (DMRB), Volume 11, Section 3, Part 1 (HA207/07)2 for the assessment of impacts on sensitive designated ecosystems due to highways works. Background data for NOx and NO2 were sourced from the Department of Environment, Food and Rural Affairs (Defra) background maps. Background data for ammonia was sourced from monitoring undertaken at Ashdown Forest.

Given that the assessment year (2033) is a considerable distance into the future, it is important for the air quality calculations to take account of improvements in background air quality and vehicle emissions that are expected nationally over the plan period. Making an allowance for a realistic improvement in background concentrations and deposition rates is in line with the Institute of Air Quality Management (IAQM) position6 as well as that of central government. Background nitrogen deposition rates were sourced from the Air Pollution Information System (APIS) website. Although in recent years improvements have not kept pace with predictions, the general long-term trend for NOx has been one of improvement (particularly since 1990) despite an increase in vehicles on the roads. There is also an improving trend for nitrogen deposition, although the rate of improvement has been much lower than for NOx10. The current DMRB guidance for ecological assessment suggests reducing nitrogen deposition rates by 2% each year between the base year and assessment year. However, due to some uncertainty as to the rate with which projected future vehicle emission rates and background pollution concentrations are improving, the precautionary assumption has been made in this assessment that not all improvements projected by DMRB (for nitrogen deposition) or Defra (for NOx concentrations) will occur. With regards to background ammonia concentrations; as there is greater uncertainty associated with rates of improvement over time, background concentrations have been kept the same through all assessment years.

Therefore, the air quality calculations assume that conditions in 2023 (an approximate midpoint between the base year and the year of assessment) are representative of conditions in 2033 (the year of assessment). The effect on the 2033 data is equivalent to assuming a 0.75% per annum improvement in background NOx concentrations and nitrogen deposition rates between 2017 and 2033.

Annual mean concentrations of NOx were calculated at varied intervals back from each road link up to a maximum of 200m, with the closest distance being the closest point of the designated site to the road.

Traffic flows were modelled on the road links, and differences between ‘Do Something’ and ‘Do Nothing’ scenarios calculated, as well as estimates of the relative contribution of Tandridge Local Plan to ammonia, NOx, nitrogen deposition and acid deposition.

With regard to each potential pollutant sources, the report concludes as follows:

With ammonia, no direct toxicity effects of ammonia are expected on the habitats of the SAC, whether associated with traffic emissions or other sources such as agriculture.

59 NOx concentrations are forecast to experience a large net reduction by 2033 due to changes in vehicle emissions, notwithstanding the projected increase in traffic on roads, including that attributable to the Tandridge Local Plan.

For nitrogen deposition, the deposition from additional traffic (irrespective of source) is forecast to be offset by a much larger reduction in background deposition over the same timescale due to improved vehicle emission factors. As a result a net reduction in deposition is actually forecast on the A22 notwithstanding traffic growth.

Therefore, since a) air quality in 2033 is forecast to be significantly better than in 2017 notwithstanding the precautionary assumptions made about both growth and improvements in vehicle emissions factors, b) no significant in combination retardation of vegetation improvement at the closest and most affected areas of heathland is expected and c) the contribution of Tandridge Local Plan to the ‘in combination’ scenario is negligible, the modelling in does not provide any basis to conclude an adverse effect on integrity of Ashdown Forest SAC or SPA from growth in Tandridge District over that period in combination with other plans. Since no net adverse effect on integrity is forecast, no mitigation as such would be required.

4.5 Air Quality: Local Plan Considerations

In line with the recommendations of the Aecom report, the above conclusion is not intended to suggest that no active attempt should be made to reduce background NOx concentrations and nitrogen deposition around Ashdown Forest as a matter of general good stewardship. Tandridge DC and other relevant authorities already have a forum for collaborative involvement in this issue via the working group that has recently been convened by South Downs National Park Authority. The aforementioned forum will also be important in monitoring long-term trends in roadside air quality within Ashdown Forest SAC at regular (e.g. five-year) intervals, in order to track the forecast improvements and, if necessary, trigger updates to the modelling and its conclusions during the plan period. The first practical outcome of this forum is a multi-authority agreement to prepare a Statement of Common Ground (SoCG) relating to nitrogen impacts on Ashdown Forest. The SoCG has now been signed and can be found on the Council’s website. Further outcomes will include actions such as initial suggestions and consideration of potential mitigation/solutions/compensation on a ‘without prejudice’ basis in the event of them proving necessary in future (Table 15 of SoCG). It was agreed to maintain a table of mitigation options in a transparent manner on an ongoing basis. It was recognised that Wealden District Council as the SAC host, and Natural England, will necessarily have the key lead roles in identifying potential mitigations and/or compensation to benefit the SAC, although all parties may contribute.

This Ashdown Forest Air Quality group will provide a further safeguard to ensure that changes in traffic flows and vehicular emissions stemming from development do not result in adverse effects upon the integrity of Ashdown Forest SAC in isolation or in combination.

60 It is also important to note that air quality has been separately investigated as part of the plan evidence base in light of National and European legislation/policy related to human health. Measures and recommendation stemming from this work will inevitably have wider air quality impacts that may in turn benefit the protected international sites. The Local Plan 2033 contains strong commitments to improve air quality. The emerging Air Quality policy requires adherence to the recommendations of the Councils AQA, the Surrey Air Alliance and the Local Transport Plan. Through the Surrey Air Alliance, various measures are being brought forward and developed in the context of air quality, including a draft Low Emissions Strategy (LES), Electric Vehicle Strategy and a set of county wide air quality planning conditions. Also to be considered is the Surrey Transport Plan Air Quality Strategy, Low Emissions Transport Strategy and Electric Vehicle Strategy. In addition the Council’s emerging ‘Sustainable Transport & Travel’ policy requires the provision of electric vehicle charging points for electric vehicles on all developments.

Other policies within the Local Plan could have a key role in negating air quality impacts upon the Ashdown Forest. This may include the provision of green infrastructure, commitments to sustainable transport (including electric vehicle charging points) and promoting more sustainable communities by minimising the need for people to travel to essential services (i.e. by focusing development in Urban Settlements and Semi-Rural Service Settlements).

61 5. Appropriate Assessment of the Ashdown Forest SPA

5.1 Citation, Qualifying Features, Conservation Objectives and Condition Status

The key information in relation to this site, including qualifying features conservation objectives and condition status was set out in Table 2 in section 2.4, while Appendix 1b shows the formal site citation for the SPA.

SPAs are strictly protected sites classified in accordance with Article 4 of the EC Directive on the conservation of wild birds (79/409/EEC), also known as the Birds Directive, which came into force in April 1979. They are classified for rare and vulnerable birds, listed in Annex I to the Birds Directive, and for regularly occurring migratory species.

Ashdown Forest is an extensive block of common land covering around 3,000ha between East Grinstead in West Sussex and Crowborough in East Sussex and forms one of the largest areas of continuous heathland in south-east England. Ashdown Forest was classified as an SPA in March 1996 because it supports bird populations of European importance which are listed on Annex I of the Directive:

 Dartford Warbler Sylvia undata, 29 pairs representing at least 1.8% of the breeding population in Great Britain (count as at 1994);

 Nightjar Caprimulgus europaeus, 35 pairs representing at least 1.0% of the breeding population in Great Britain (two year mean, 1991 & 1992). The Nightjar is a ground-nesting bird.

Left: Dartford Warbler (Courtesy of RSPB) Above: Nightjar (Courtesy of David Bull) 62 5.2 Initial Screening Report (August 2017)

The HRA Stage 1 screening looked at the possible effect of the Local Plan on the Ashdown Forest SPA in terms of ‘Recreational disturbance’. It noted that the possible effects of the Local Plan on the protected site were:

Additional development promoted in the Local Plan will result in additional visitors to the site, having a negative impact on the integrity of the site.

The likely significant effects on the protected site (including in-combination impacts) were cited as follows:

Recreational disturbance (particularly dog walkers) could be having a significant effect on the breeding success of the protected ground nesting birds at the site. The Council will continue to work with such authorities in relation to issues at the Ashdown Forest.

Historic visitor data suggested that most visitors come from areas local to the Forest (within 7km), meaning that additional development in parts of Tandridge near to the Forest may increase recreational disturbance in combination with development planned by other authorities. An updated Visitor Survey was published in March 2017, the implications of which will need consideration in partnership with other planning authorities that potentially impact upon the Ashdown Forest.

All four garden villages are at least 11km from the Ashdown Forest and relatively remote from likely zones of recreational impact. However, at this stage it cannot be categorically determined that the development outlined in the Tandridge District Council Local Plan would not cause recreational disturbance alongside proposed development planned in other authorities. As such, and taking into account the precautionary principle, this will have to be considered at the next stage of the HRA process, or as part of a further Screening Assessment when more information is known.

Tandridge is a co-signatory to an Interim Strategic Access Management and Monitoring (SAMM) Strategy. The SAMM Strategy should help introduce measures to mitigate against the effect of increased patronage to the Ashdown Forest that new development would bring. Further stages of the AA may also consider the potential for Suitable Alternative Green Space (SANGs) to mitigate any impacts from recreational pressure.

5.3 Natural England Screening Opinion

In response to HRA Stage 1, Natural England agreed, in abiding by the precautionary principle, that recreational impacts should be screened in (see Appendix 3).

63 5.4 Background Evidence on Recreational Disturbance Impact Pathways

5.4.1 Vulnerability of SPA Species to Disturbance

As noted by Urban Edge Consulting in their HRA for Mid-Sussex, animals often react to human disturbance as a form of predation risk. Such a response can include elevated heart rate, heightened defensive behaviour, including evasive measures with associated energy expenditure, and the avoidance of high risk areas (Murison et al. (2007), Liley & Sutherland (2007)). High levels of human activity in important nature conservation areas might then change the behaviour of animals to such a degree that conservation priorities become compromised. This may result from reduced breeding success, increased predation or exposure of nests, eggs or young to trampling and the elements (Liley & Sutherland, 2007).

Dartford Warbler

The Dartford Warbler is vulnerable to disturbance, particularly in heather dominated areas, less so in areas dominated by gorse. In a study into the relationship between habitat type and disturbance effects on the breeding Dartford Warbler, Murison et al. (2007) noted the following as important measures of disturbance. First, they noted that indirect disturbance was associated with factors such as the distance from the centre of the heathland patch (or nest) to the nearest road, path, building or car park. Second, the proximity of a nest territory to the nearest access point showed a strong, negative relationship with the timing of a first brood. Third, disturbance appeared to be associated with increased stress levels, with birds exhibiting an extended period of agitation while searching for cover, leading to increased energy expenditure.

They suggest that the mechanisms by which disturbance affects the Dartford Warbler’s breeding success are associated with its particular susceptibility to disturbance during nest-building, with birds often abandoning their work and materials. The effects of this are threefold. The timing of the first brood was delayed for long enough (up to six weeks) to prevent multiple broods in one season. Second, the fledgling success of a first brood delayed until June was limited by the decreased availability of invertebrate prey. Finally, that continued disturbance events reduced the foraging effectiveness of the birds, and their ability to feed their young, by keeping the adults away from the nest for longer than normal.

Analysing the results of their study, Murison et al. (2007) found that breeding pairs with territories in areas experiencing as many as 13 to 16 disturbance events each hour of every day, delayed breeding for sufficiently long enough to prevent multiple broods in one season. Importantly, they also found a significant correlation between the reproductive success of Dartford Warbler and the proportion of different species of gorse present in the heathland patch. They discovered a strong positive relationship with European gorse Ulex europaeus, where heathland patches containing more of this type produced more successful broods. While the significance of disturbance events in

64 delaying breeding among pairs nesting in heather-dominated territories was high, often leading to reduced breeding success, the correlation was weaker in territories dominated by Western gorse U. gallii. During their surveys, dogs were observed ranging as far as 45m into heather dominated areas, but never strayed from the path in areas with vegetation dominated by gorse.

Nightjar

Evidence has shown Nightjars are negatively affected by urbanisation. Liley and Clarke (2003), following field studies into the population density of nightjar on 36 patches of heathland in Dorset, demonstrated that patches surrounded by higher levels of development supported smaller populations of nightjar. Effects associated with urbanisation identified as relevant in this respect included human disturbance, light pollution, predation from natural predators and domestic pets (as well as corvids, Fox Vulpes vulpes, and Hedgehog Erinaceus europaeus), and habitat change.

In a study investigating the relationship between walkers with dogs and the success of breeding nightjar, Langston et al. (2007) observed that the flushing of birds from the nest by a disturbance event during daylight hours led to predation by diurnal predators, particularly of eggs. Moreover, birds tend to flush more readily in response to dogs than to humans, and take longer to return to the nest. Langston et al. (2007) noted that disturbance effects on nightjar were accentuated when breeding conditions were less favourable due to incidental factors such as weather conditions. Birds flushing the nest as a result of disturbance events during harsh or wet weather tended to bear smaller, less successful broods. Overall, they found a significant relationship between nest failure and disturbance, with failure being more likely in nests with higher total footpath length within 50m, 100m and 500m of the nest clearing.

Woodlark

The woodlark is also vulnerable to human disturbance. It has been observed that the removal of human disturbance effects could result in an increase of between 13% and 48% in the breeding population of woodlark over 16 heathland sites (Mallord et al. 2007a, Mallord et al. 2007b). At sites with recreational access woodlark was found to be less likely to colonise suitable habitat in areas with greater disturbance. The probability of colonisation was reduced to below 50% with disturbance levels at eight events per hour.

Summary of Disturbance Impacts to Breeding Birds

In summary, disturbance impacts to heathland breeding birds can be described as:

 Increased nest predation by natural predators or dogs when adults are flushed from the nest or deterred from returning to it by the presence of people or dogs;

 Chicks or eggs dying of exposure because adult birds are kept away from the nest;

65

 Accidental trampling of eggs by people, where nests are on the ground and may be close to paths;

 Reduced productivity resulting from delayed breeding, fewer young, decreased food availability and/or nest failure;

 Displacement from / avoidance of otherwise suitable areas of habitat; and

 Increasing stress levels in adult birds in response to perceived predation risk.

Historic Evidence for Disturbance Impacts upon Key Species within Ashdown Forest

Urban Edge Consulting summed up the historic evidence for disturbance impacts upon key species within Ashdown Forest in their HRA for Mid-Sussex. This work noted that the study by Clarke et al. (2010), analysed data on visiting patterns collected through face-to-face questionnaire surveys conducted at Ashdown Forest in 2008 (UE Associates & University of Brighton, 2009). After assessing visitor rates at each access point, they distributed visitor numbers across the path network within the Forest using a 25m by 25m cell grid to generate a series of maps showing visitor intensity levels. These were overlaid with recorded bird territories from the latest national surveys for Dartford warbler (Wotton et al., 2009), nightjar (Conway et al. 2007) and woodlark (Conway et al. 2009) to investigate whether bird density correlates with visitor or path intensity.

They found that average bird density was lowest in areas with the lowest two class levels of either visitor or path intensity. For woodlark, the highest average density occurs in areas with the highest class levels of visitor intensity at all three assessed influence distances (50m, 100m and 150m). Average nightjar density was lowest for the quarter of cells with the lowest nearby visitor or path intensity for all three influence distances. Dartford warbler average density was highest amongst the quarter of cells with the highest level of visitor intensity. For each species, several of the differences in bird density with nearby visitor or path intensity were statistically significant (Clarke et al. 2010). The positive relationship between nesting birds and presence or potential presence of visitors would seem to suggest that visitor activity is not affecting territory selection among the birds on Ashdown Forest.

However, after accounting for habitat type, Clarke et al. (2010) found that path intensity is lowest in (or very near to) areas of wet heath, and second lowest in woodland. Furthermore, visitor intensity levels were found to be much lower in areas of wet heath and woodland than other habitats, and much less than half the general level of visitor pressure in area of dry heath. Looking at the habitat preferences of the birds within Ashdown Forest, wet heath and woodland habitats are less preferred by the bird species, whereas dry heath was found to be the preferred nesting habitat for Dartford warbler and nightjar, and second choice (of six habitat types) among woodlark. Other important nesting habitats were gorse (especially for woodlark and Dartford warbler) and unimproved grassland where levels of visitor and path intensity were also higher than in woodland and wet heath habitats.

Analysis which also takes account of habitat type thus demonstrates that more open and drier habitats are generally preferred by both birds and people within Ashdown Forest, perhaps explaining why the density of nesting territories is greatest in areas with the highest presence or potential presence of visitors. But Clarke et al. (2010)

66 found no clear evidence that the current spatial distributions of woodlark, nightjar or Dartford warbler are affected by the patterns of current levels of nearby visitor pressure or by path intensity within the SPA. Nevertheless, the density of all three species is low within Ashdown Forest, and lower than might be expected when compared to other heathland sites in southern England with a similar range of habitats (see Clarke et al., 2010, Table 7 and Figure 14). By comparison, visitor pressure at the site (2.1767 visitors per ha over a 16 hour period) appears to be lower than on the Thames Basin Heaths (3.7 visitors per ha) and slightly higher than the Dorset Heaths (1.8 visitors per ha) where similar studies have been carried out.

The study concludes that the current (2008) level of visitor pressure is not affecting the distribution of nightjar, woodlark or Dartford warbler within Ashdown Forest SPA; based on the analysis undertaken, the birds do not appear to be avoiding areas of greater recreational pressure. However, recreational disturbance could still be having an impact on the Annex I bird species at the site: “It may be that the density of birds is so low (due to other, currently unknown factors) that there is little competition for space and therefore no impacts of disturbance. While the results of the analysis presented in the report are potentially encouraging, in the absence of data on breeding success, and without understanding why bird densities are low, it currently cannot be concluded on the basis of scientific evidence that the ecological integrity of nightjar and Dartford warbler populations is not being adversely affected by a combination of existing pressure and/or habitat management.” Clarke et al., 2010, p29

Clarke et al. (2010) advocate a precautionary approach when considering the implications of a plan or project proposing a significant level of increased housing, informed by wider research into the effects of disturbance on heathland birds, because it cannot be conclusively determined that current levels of recreational pressure are not affecting the breeding success of birds exposed to recreational pressure.

5.4.2 Visitor Surveys

Historic visitor data suggests that most visitors come from areas local to the Forest (within 7km), meaning that additional development in parts of Tandridge near to the Forest may increase recreational disturbance in combination with development planned by other authorities. The HRA screening (2017) further noted that all four garden villages options are at least 11km from the Ashdown Forest and relatively remote from likely zones of recreational impact. However, it could not be categorically determine that the development outlined in the Tandridge District Council Local Plan would not cause recreational disturbance alongside proposed development planned in other authorities. As such, and taking into account the precautionary principle, it proposed to consider the matter further at the next stage of the HRA process, or as part of a further Screening Assessment.

There have been two Ashdown Forest Visitor Surveys undertaken, in 2008 and 2016. For the purposes of analysis this report focuses primarily on the more recent 2016 survey. However as the cross-check (see Map 8) shows, the results are broadly similar.

67 The 2016 Visitor Survey

The Ashdown Forest Visitor Survey 2016 report was published by Footprint Ecology in March 2017. It was commissioned by six local authorities (Wealden, Mid Sussex, Lewes, Tunbridge Wells, Tandridge and Sevenoaks) and represents a comprehensive analysis of the results of visitor survey work at Ashdown Forest conducted in late spring/early summer 2016, providing up-to-date data on recreation use of the Ashdown Forest. It provides insight into the home locations, frequency of visit, distance travelled and main activities of visitors to the Ashdown Forest.

Key findings from the 2016 Visitor Survey

Some key facts, findings and insights include:

 452 interviews were completed.  Of all visitors, the majority (76.3%) live within 5km, and 81.3% live within 7km.  7% of all visitors live between 7km and 21km away, and 6.7% of all visitors live more than 21km away.  Of those who visit frequently (daily or most days), 100% live with 7km of the SPA.  Of dog-walkers, the majority (83.8%) live within 5km, and 87.8% live within 7km.  Of those dog-walkers who visit frequently (daily or most days), 97.2% live within 5km of the SPA and 100% live with 7km of the SPA.  Many (50% interviewees) were visiting on their own (i.e. no other people with them) and the majority of interviewees (71%) were accompanied by one or more dogs. Some parties had particularly large numbers of dogs (two groups had more than ten dogs with them).  Gills Lap, King’s Standing and Crowborough were the busiest survey points; together these locations accounted for nearly a third (32%) of all interviews.  The majority of interviewees were on a short trip and visiting directly from home (98% interviewees). Holiday-makers accounted for a small proportion of interviews (1% of interviewees) and were excluded from the analyses in the report, ensuring that the results directly link to local residents.  The majority of interviewees (69%) gave dog walking as their main activity. Dog walking was the most common activity at all survey points apart from Reserve (where dog walkers accounted for 19% of the interviews).  Walking was the next most common activity (18% interviewees). Other notable differences between survey points were the relatively high number of interviewees who were on a family outing/picnic at Lintons and the Forest Centre.  Around half (48% interviewees) stated they had been visiting Ashdown Forest for more than 10 years. By contrast, just 5% of interviewees were on their first visit.  Visits were typically short, with over half (59% interviewees) visiting for less than an hour.

68  Most interviewees were regular visitors to the location where interviewed, with 285 interviewees (63%) visiting at least weekly. The most regular visitors appear to be dog walkers and joggers (note that only three joggers were interviewed), with both groups having a relatively high proportion of interviewees that were daily visitors.  Nearly a third of interviewees (29% interviewees) did not tend to visit at a particular time of day. For those that did tend to visit at a particular time of day, the mornings appeared to be the preferred time.  There was little evidence that the interviewed visitors tended to visit more at particular times of year and most (81% interviewees) tended to visit equally all year round for their chosen activity.  Most interviewees (81%) had arrived at the survey point by car. Nearly a fifth had arrived on foot (18%). 80% of dog-walkers arrived by car/van, 20% on foot.  Scenery/variety of views was the most common response (48% interviewees) as to why the interviewee chose to visit Ashdown Forest that day, rather than another location. Other common reasons were close to home (46%), and good for the dog/dog enjoys it (28%). For dog walkers ‘close to home’ was the most commonly given response and scenery/variety of views, while still of importance was of less importance than the proximity to home.  53% of interviewees indicated that they would not have gone to an alternative site, or were unsure which alternative site they would have visited could they not have gone to Ashdown Forest. Of named alternative sites given by interviewees, the South Downs (named by 8% interviewees) was by far the most commonly named location. Rotherfield, Sheffield Park and Seven Sisters/Cuckmere Haven were the next most commonly named sites. Taking into account the frequency with which interviewees stated they visited the named alternative site, Rotherfield was the most commonly visited single alternative site, with South Downs ranked second.  Routes were plotted for 446 interviewees visiting from home or staying with friends and family. Route lengths ranged from 31m to 7,361m, with a typical route length (from all routes) being 2,616m (the median). There were significant differences between survey locations, with interviewees typically walking further at King’s Standing, Long and Box and undertaking shorter routes at Crowborough, Nutley, Forest Row and Poundgate.  Walkers tend to walk the furthest (median 3042m) compared to dog walkers (median 2639m) and those wildlife watching or birdwatching (median 2492m).  67% of all interviewees indicated their route was similar to the usual route when visiting the interview location for their chosen activity, with 15% saying it was much shorter than normal and just 2% saying it was much longer than usual. 72% of dog-walkers indicated their route was similar to the usual route when visiting the interview location for their chosen activity, with 16% saying it was much shorter than normal and just 2% saying it was much longer than usual.  Overall 40% indicated that they went off paths (or were planning to go off paths) during their visit. The percentage going off paths was highest for photographers (57%), those meeting up with friends (50%), those wildlife/bird watching (47%) and dog walkers (42%).  Most dog walkers (87% of dog walking interviewees) and a relatively high proportion of other visitors were aware of guidance relating to dog walking at Ashdown Forest. Of those dog walkers that were aware of guidance, 39% were

69 able to specifically mention the dog walking code of conduct (‘4Cs’) currently promoted.  However, well over half of dog-walkers (64%) had not changed their behaviour in any way as a result of the guidance, while keeping their dog on the lead more was the most commonly recorded change (17%).  Home locations (primarily postcode data) were collected for 98% of interviewees and enabled visitor origins to be mapped. The maps showed a wide scatter of visitors across Sussex and largely ranged from London to the south coast. The average straight-line distance between the home location and the survey point was 8,402m (median 4,870m). A quarter (25%) of interviewees lived within 1,459m of the survey point and three quarters (75%) lived within 9,643m.  72% of all those on a short visit from home and whose postcodes were mapped were from Wealden District, with a further 12% from Mid Sussex, 5% from Tunbridge Wells and just 1% from Tandridge. There was a clear pattern whereby those who visited Ashdown Forest more regularly tended to live closer to the SPA.

Key findings from the Visitor Count Data

Key findings from the visitor count data included:  In total, 2,794 people (adults and minors) were counted by surveyors during 320 hours of survey at the 20 access points (i.e. while interviews were conducted).  Considering only those observed entering the site, this amounted to 1,506, an average of 4.7 people per hour. A typical visiting group would consist of two adults and one dog, and half of all groups included a minor.  There were highly significant differences between visitor numbers at different locations. The four busiest locations observed from the tally data were King’s Standing, Long, Forest Centre and Gills Lap. In addition the composition of groups differed greatly between locations, particularly in the number of adults and minors at different locations.  Driving transects (which covered all parking locations) recorded an average of 159 vehicles per transect. Vehicle counts showed typically more vehicles at weekends than weekdays and a peak at midday, followed closely by morning, however these differences were not statistically significant.

5.4.3 Overview of Current Recreational Pressures and Conclusions regarding ‘zone of influence’ for Tandridge

Proportion of Visitors from Tandridge

Tandridge residents make up just 1.38% of visitors, as the following table 9 from the 2016 Visitor Survey demonstrates.

70 Table 9: Number (%) of interviewee postcodes by local authority

Source: 2016 Visitor Survey Ashdown Forest

Note: Data excludes holiday makers and those staying with friends and family, and percentages are based on the overall total of postcodes used (n=434), i.e. non-holiday makers visiting from other Districts beside the six listed in the table.

The 2016 Visitor Survey demonstrates that Tandridge residents make up an even lower proportion of dog-walkers (0.67%), as the following table 10 demonstrates.

Table 10: Number (%) of interviewee postcodes by local authority, dog walkers only.

Source: 2016 Visitor Survey Ashdown Forest

Note: Data excludes holiday makers and those staying with friends and family, and percentages are based on the overall total of postcodes used (n=302), i.e. non-holiday makers visiting from other Districts beside the six listed in the table.

The following map from the visitor Survey (map 6) shows origin of visitors with 1km buffers imposed (starting at 5km). Tandridge’s particular impact pathway is essentially

71 down the A22 via East Grinstead, in other words from the north-west of the Ashdown Forest. From this direction there is a clear drop off in visitors beyond 7km, which equates to the area beyond the broad urban area of East Grinstead. It seems likely that the e town of East Grinstead itself acts as a severance barrier due to congestion, dis- incentivising visitors from further afield.

Map 6: Home postcodes of interviewees (excluding holiday makers and those staying with friends/family) and settlements

Moreover, as the following map shows (map 7), whilst there may be visitors to the Ashdown Forest from much further afield (blue shades) they generally are not regular visitors and visit less than monthly. More regular visitors visiting weekly (orange and red shades) are overwhelmingly clustered in close vicinity to the Forest.

72 Map 7: Home postcodes of interviewees (excluding holiday makers and those staying with friends/family) by frequency of visit

73 Comparison with 2008 Survey Results

As a reliability check, visitor patterns can be compared to the 2008 survey (Map 8). This shows the pattern of visitors is broadly consistent over time.

Map 8: Comparison for postcode data from 2008 survey (right hand pane) and 2016 (left hand pane)

Dog Walking

As map 9 shows, dog-walking (red) is the dominant activity. Of dog-walkers, the majority (83.8%) live within 5km, and 87.8% live within 7km. Evidence in relation to disturbance impacts suggest dogs, particularly when not kept on a lead, may have a dis-proportionately negative influence.

There is a dog-walkers code of conduct in place in the Forest, known as the ‘4 C’s’19. The code is not unduly onerous, for example there is no requirement for dogs to be kept on leads. However, an unfortunate finding of the Visitor Survey is that the majority (64%) of dog-walkers had not changed their behaviour in any way as a result of the guidance.

19 https://www.ashdownforest.org/discover/docs/Spring15_000.pdf

74 Map 9: Home postcodes of interviewees (excluding holiday makers and those staying with friends/family) by activity

Visitor Pressure Points within the Forest

The 2016 Visitor Survey indicated a particular prevalence of dog walking/walking routes on the eastern side of the SPA, in comparison to the west. This suggests the ‘honey-pot’ destinations within the Forest are comparatively far from Tandridge District. An exception to this is the area adjacent the A22 south of Forest Row, which Map 12 indicates is a particular ‘hot-spot’ on the north or west side of the Forest. However, map 2 below shows this area to be relatively free of key Annex 1 bird species territories (Nightjar and Dartford warbler), even though other honeypot destinations to the east do not show any visible reduction in territories.

75 Map 10: Routes taken by interviewees

Map 11: The predicted number of daily visitors in each 15m x 15m cell

76 Map 12: The predicted number of daily visitors in a 600m buffer around each cell

Map 13: Bird data from previous national surveys

77 Conclusion on Mitigation Zone

The data that was collected for the Visitor Survey can be utilised to inform the identification of the Ashdown Forest SPA Mitigation Zone. A number of options for buffer / zone of influence distances have been assessed in parallel within the Sustainability Appraisal, which concludes that 7km is most appropriate.

A 7km distance does not cover the entire recreational catchment of the SPA/SAC but does cover the core catchment within which the overwhelming majority of regular visitors derive. Therefore, a net change in population within this 7km zone has a realistic possibility of a significant net change in visitor pressure within the SPA and thus an increased risk of an adverse effect. The Sustainability Appraisal has considered alternative options and distances, however the evidence shows that a 7km distance will cover the vast majority of circumstances within which recreational pressure on the SAC/SPA needs consideration as an impact.

However, because the 7km distance is somewhat artificial (and only an estimate at this stage), it is conceivable that developments slightly outside this zone may still contribute to recreational activity to a material extent. For example, the impacts from recreational pressure of a large housing development slightly further than 7km from the SAC/SPA boundary may also warrant HRA screening.

It is to cover these circumstances an approach is recommended whereby ‘large scale [housing] developments taking place outside 7km but close to its boundary will be considered on a case by case basis for potential effects on Ashdown Forest and the need for avoidance and mitigation measures’. In relation to the garden community, this will be taken forward as a future Action Area Plan (AAP). The preferred location (South Godstone) is approximately 15km away, so considered unlikely to lead to significant visitor pressure on the Ashdown Forest. However, visitor patterns may be different for the population of a new settlement compared to additional population to an existing settlement. Therefore, as part of the development of the AAP, further monitoring and investigation may be appropriate to assess future visitor patterns from a new garden community.

5.5 Impact Avoidance and Mitigation Measures proposed by the Local Plan

Impacts can be mitigated in two ways.

The provision of Suitable Alternative Natural Greenspace (SANG) which is a greenspace that is of a quality and type suitable to be used as mitigation to offset the impact of new development on the Ashdown Forest SPA. A SANG site could either be provided on the development site itself or through a financial contribution towards a strategic SANG.

The second part of the mitigation is to provide a financial contribution towards a Strategic Access Management and Monitoring (SAMM) strategy. This aims to manage

78 visitors on-site at Ashdown Forest and the strategy will involve joint working with the other affected local authorities, the Conservators of Ashdown Forest and Natural England.

5.5.1 Strategic Access Management and Monitoring Programme (SAMM)

Local Authorities (Wealden, Mid Sussex, Lewes, Tunbridge Wells, Tandridge and Sevenoaks) near to Ashdown Forest SPA have agreed to coordinate a strategic approach to collect developer contributions to deliver access management and monitoring measures. Such a strategic approach ensures development can be delivered and ensures potential issues with recreation are resolved. Conformity with the strategic approach means the decision maker can give permission with confidence that the legislation has been adhered to. All assessment work has effectively been undertaken 'upfront' and furthermore the necessary mitigation has been carefully secured through plan policy and designed to absorb the cumulative, in-combination effects of development. Similar approaches have been established around other heathland sites in England such as the Dorset Heaths, the Thames Basin Heaths, the East Devon Pebblebed Heaths and Cannock Chase. It is essential that a strategic approach is based on up to date visitor data, so the 2016 Visitor Survey served to:

 Provide up-to-date baseline data to inform the implementation of access management measures;  Inform the direction of strategic access management and monitoring;  Inform the design and ongoing management of Suitable Alternative Natural Greenspace (SANGs) to ensure they are an effective alternative visitor destination; and  Assist local authorities in undertaking their planning functions as relevant to the Habitats Regulations.

Tandridge District Council is a co-signatory of an ‘Inter-Authority Agreement’ (IAA) to the deliver the ‘Strategic Access Management and Monitoring Strategy’ (SAMM) in the Ashdown Forest. The SAMM Strategy should help introduce measures to mitigate against the effect of increased patronage to the Ashdown Forest that new development would bring. The other five signatories are Wealden District Council, Mid-Sussex District Council, Sevenoaks District Council, Tunbridge Wells District Council and Lewes District Council.

Access management projects have been identified by the authorities in partnership with the Ashdown Forest Conservators. The aim and purpose is to promote responsible behaviour and use of Ashdown Forest and therefore mitigate impacts associated with increased recreation pressure that may arise from an increase in populations from new residential development. The Conservators will ultimately implement and manage the delivery of these projects, with the funding provided by developer contributions. The projects include the following: • Project 1 - Code of conduct for dog walkers • Project 2 - Code of conduct review and promotional materials • Project 3 - Access Management Officer • Project 3a - Volunteer Dog Rangers • Project 3b - Community events • Project 4 - Assistant Access Management Officer

79 • Project 5 - Delivery of access management objectives through the Dog Training Programme

Further details are in the Ashdown Forest SPA Monitoring Strategy 2018.

Development contributions should be collected towards the SAMM Strategy via Section 106 of the Town and Country Planning Act 1990, the Community Infrastructure Levy or alternative mechanisms.

It is not considered necessary to look at alternative types of access management projects that would sit within the Strategic Access Management and Monitoring Strategy (SAMMS). This is because the SAMMS policy approach has been in progress for several years during which time the neighbouring authorities have cooperatively entrusted the consideration and design of the SAMMS to Wealden District Council as the ‘Lead Authority’ and sole point of contact with the Conservators of the Forest (Ashdown Forest lies wholly within Wealden district). This agreement has enabled Wealden DC, working with Natural England as advisors, to efficiently explore and negotiate with the Conservators deliverable projects capable of mitigating the effects of visitor pressure on the Forest. It would not be appropriate at this stage to undermine that established and cooperative approach by re-visiting potential SAMMS projects. Such an approach would also be disproportionate for the very small area of Tandridge District Council that will contribute to the current SAMMS.

5.5.2 Suitable Alternative Natural Greenspace (SANG)

Suitable Alternative Natural Greenspace otherwise known as SANG can be defined as alternative green space used as mitigation to reduce the recreational use of the Special Protection Area (SPAs). These areas are protected for the conservation of birds and habitats under the Habitats Regulations which aim to protect the habitats and species living in these areas from disturbances such as dog walkers or ramblers. The Sustainability Appraisal (SA) set out options for SANG.

As set out in Wealden DC SANG guidance, the aim of SANGS is to provide alternative green space to accommodate additional levels of recreation and divert visitors away from the Ashdown Forest SPA to mitigate together with other on-site and other management measures, recreational impacts to Ashdown Forest. It is considered that by increasing the amount of or improving existing green space in an area by providing sites designed to be welcoming and attractive to particular users that this will counterbalance or even reduce the levels of visitor use and the effect of recreational pressure on Ashdown Forest resulting from new development. This in turn will reduce the potential for adverse impacts on the protected bird species nightjar and Dartford warbler during their breeding season.

SANG is required at the level of 8ha per 1,000 net increase in population. In terms of design, at a very minimum a SANG must be large enough to provide an attractive

80 circular walk of 2.5km. To achieve a 2.5km circular walk will require a site around 40 hectares in size. The design of routes within sites smaller than around 40 hectares will therefore be critical to providing routes of sufficient length and attractiveness for mitigation purposes. A SANG must have car parking provision, since most visitors to the protected international sites visit by car.

Two pieces of more detailed guidance on SANG design are available. Natural England have advised reference to the SANG guidance for the Thames Basin Heaths, which they advise is universally applicable to all geographic areas. In addition, Wealden District Council20 have published SANG guidance on their web-site.

SANG should be designed to replicate the high quality of the international sites visitor experience as far as possible. Therefore careful adherence to the principles set out in the above two guidance documents will need to be demonstrated.

The Visitor Survey showed that large numbers of respondents could name at least one location they would have visited if they did not visit Ashdown Forest on the day interviewed. The South Downs was the most common answer. However a similar number said there was nowhere where they would have visited instead. There was a strong match between the reasons interviewees chose to visit Ashdown Forest and the reasons they chose other sites. The three top ranking reasons interviewees chose Ashdown Forest (scenery/variety of views, close to home and good for dog/dog enjoys it) were also the top ranking reasons for choosing alternative sites. There was a highly significant correlation between the number of interviewees who gave each response for Ashdown Forest and for alternative sites. This would suggest that the alternative sites listed provide a similar destination/experience to Ashdown Forest.

The TDC 7km zone is largely rural in nature and there are no residential development allocations currently proposed in the Local Plan within this area. However, in the event of residential development coming forward within 7km of the Ashdown Forest Special Protection Area, the order of priority for provision of SANG will be as follows:

1. On-site or in the immediate vicinity (provided it can accord with Natural England SANG standards) 2. Appropriate contributions to a SANG on a similar impact pathway (i.e. located in the intervening spatial area between the site and the SPA). 3. Contributions towards SANG standard green infrastructure located elsewhere within Tandridge District, subject to the agreement of Natural England. 4. Offset contributions towards another SANG anywhere within 7km of the Ashdown Forest.

Option 1: Where it is required, the feasibility of SANG provision in the nearby vicinity should be considered in the first instance. The physical provision of a SANG is likely only to be suitable for larger development schemes due to the need to meet Natural England guidelines for SANGs.

20 www.wealden.gov.uk/nmsruntime/saveasdialog.aspx?lID=14312&sID=4858

81

Option 2: The option of contributing to a shared SANG on the same impact pathway would be the next priority, subject to capacity being available. In order to be considered on the same impact pathway, a SANG should be located in the intervening spatial area between the site and the SPA. Other than Tandridge DC itself, this means locations with northern areas of either Mid-Sussex DC or Wealden DC. Availability will need to be confirmed by the respective local planning authorities at the relevant time. It is open to prospective applicants to explore securing SANG capacity from these sites with the relevant planning authority and the owners. Where SANG is secured from sites not owned by the Council, planning applications must be accompanied by evidence that the appropriate SANG capacity has been secured. This might be through a legal agreement between the applicant, the relevant local authority, and the third party SANG owner. In the event of more than one SANG option being available to contribute to, options should be prioritised in order of road distance from the application site. Contributions will be required in full to the neighbouring authority, which may potentially entail costs of legal agreements and monitoring, as well as on-site costs.

Option 3: In the event of the above options not being feasible following investigation, contributions towards the provision of ‘SANG standard’ green infrastructure elsewhere within Tandridge District will be considered. This may be alongside the new Garden Community, or at some other location within the District that has not already been considered under option 2. It is recognised that the green infrastructure for the Garden Community is unlikely to be delivered until midway during the plan period, so this option may not be feasible in practice due to timing, given the Natural England requirements for SANG to be in place prior to occupation. However, grampian conditions will be considered as detailed below

Option 4: Finally, in the event of none of the above options being feasible, offsetting in any another location within the vicinity of the Ashdown Forest will be accepted, as agreed by Natural England.

Grampian Conditions: In circumstances and where a specific SANG is identified and confirmed by the body responsible for the administration and management of that SANG as being authorised and available to meet the needs of the development proposed, the Council may use a Grampian Condition to secure SANG.

Detail of mechanisms for collection, as well as availability of potential sites elsewhere will be established by a separate guidance note. Collections may be via CIL, Section 106 or some other mechanism.

Bespoke Mitigation

Bespoke mitigation may also be appropriate in some circumstances. Detailed evidence would be required to assist the District Council in determining if the bespoke mitigation would be sufficient to avoid a recreational pressure impact on Ashdown Forest. Natural

82 England’s advice would also be taken into account. Bespoke options may not be considered reasonable if they are not possible to implement or enforce.

The mitigation will need to be secured in perpetuity; this is taken to mean a minimum of 100 years. Funding to manage and maintain the bespoke mitigation will also have to be secured. Bespoke mitigation will need to be discussed and agreed by the District Council following advice from Natural England.

5.6 Recommended Local Plan Policy

Policy: Ashdown Forest Special Protection Area

All residential development within 7km of the Special Protection Area boundary, will need to put in place adequate measures to avoid and mitigate potential effects on the Special Protection Area. These must be delivered prior to occupation and in perpetuity. To meet these requirements developments will need to meet the following requirements:

 Make a financial contribution towards the Strategic Access Management and Monitoring (SAMM) for the Special Protection Area.

 Contribute to Suitable Alternative Natural Green Space (SANG) provision at a standard of 8 hectares per 1000 residents (minimum after any discounting) and designed to replicate the quality of the international sites visitor experience as far as possible; or the provision of bespoke mitigation.

SANG should incorporate a round walk of at least 2.5km. The priority hierarchy for SANG delivery will be as follows:

I. Provided in the vicinity of the development.

II. Appropriate contributions to a SANG on a similar impact pathway (i.e. located in the intervening spatial area between the site and the SPA), prioritised according to road distance from the site.

III. Contributions towards SANG standard green infrastructure located alongside the new Garden Community, or elsewhere within Tandridge District, subject to the agreement of Natural England.

IV. Offset contributions towards another SANG anywhere within 7km of the Ashdown Forest.

For sites beyond the 7km zone of influence, an Appropriate Assessment may be required under the Habitats Regulations Assessment to determine whether there will be a likely impact on the integrity of the Special Protection Area.

Where bespoke mitigation is provided, these measures will need to be in place before occupation of development and must be managed and maintained in perpetuity. The effectiveness of such mitigation will need to be demonstrated prior to approval of the development. Bespoke mitigation will need to be discussed and agreed by the District Council as the competent authority following advice from Natural England. 83 5.7 Strategic Green Infrastructure at South Godstone

The Garden Community offers considerable scope for biodiversity improvements, mitigations and gains for the District.

The Open Space Study (2017) identifies a pre-existing access deficit to large scale green infrastructure across the whole of the south of the District. Such a deficit will be worsened by the provision of a new settlement. Conversely the new settlement offers the opportunity to address this. Natural England’s ANGsT standard (applied at strategic scale) justifies a single area of 100ha or even 500ha of GI alongside the Garden Community (See Table 11 derived from TDC Open Space Study) and supporting maps below. To address the main accessibility shortfall, this should ideally be located south or west of South Godstone garden community. This would be in addition to the more localised green infrastructure provision spread throughout the settlement.

Table 11 Summary of access issues for natural green space

ANGST Standard Key access Issues

At least one accessible 20 hectare site Access is sporadic, focused mainly in the within two kilometres of home northern half of the district. The majority of parishes have either no or only partial access.

One accessible 100 hectare site within five Access restricted to the north eastern kilometres of home part of the district, with the parishes of Tatsfield, Titsey, Limpsfield and Oxted having good access, and partial access in the parishes of Tandridge and Crowhurst.

One accessible 500 hectare site within ten There are no 500 hectare sites within the kilometres of home district.

A minimum of one hectare of statutory There are 7 Local Nature Reserves within Local Nature Reserves per thousand Tandridge District. population at least 2 hectares in size, no more than 300 metres (5 minutes’ walk) from home

The following maps apply these to Tandridge, illustrating the deficit.

84 Map 14: Access to 20 ha site within 2km (Source: Open Space Study)

Map 15: Access to 100 ha site within 5 km (Source: Open Space Study)

85 Although justified by the ANGsT standard, a single large area of Green Infrastructure located adjacent to the Garden Community would also be beneficial in respect of the protected international sites (Ashdown Forest SPA/SAC and Mole Gap to Reigate Escarpment SAC).

Provision of a strategic scale area of GI would reduce the risk of future recreational impacts occurring upon the two SACs, particularly in light of a significant increase in population who may undertake a pattern of recreational visits that differs from pre- existing populations. Furthermore, The Visitor Survey (albeit from a very small sample size) did show evidence of existing Tandridge residents, including dog-walkers, regularly visiting the Forest from beyond 7km. Based on this, Wealden District Council presented evidence showing that the majority (two-thirds) of visitors to the SPA from Tandridge would be captured by a 20km boundary, whilst all visitors would be captured by a 25km boundary. This can be seen at Appendix 4.

Provision of large scale strategic GI alongside the South Godstone Garden Community would have the benefit in discouraging recreational visits to the international sites by providing a local alternative that could be enjoyed by, and for the benefit of, local people. This would demonstrate a positive approach to the international sites located in neighbouring Districts.

In order to function effectively and bring the benefits associated with a SANG, the strategic GI should incorporate a 2.5km circular walk and adequate parking, in line with relevant SANG guidance.

In line with Draft NPPF review paragraph 172, such an area of GI may also act as a ‘stepping stone’ area habitat between existing designations, and should therefore seek to incorporate priority habitats that facilitate this role. Advice has been sought from Surrey Wildlife Trust in this respect, who have commented that ‘Opportunities for heathland and acid grassland creation are somewhat limited in the Low Weald, and more appropriate to the Tandridge section of the Greensand ridge (where much former open habitat is now secondary woodland, albeit of some standing). Here, the relatively more confined approaches to heathland restoration seen further west in the Leith Hill- Winterfold area would probably be a fair model to emulate if possible. GI for biodiversity in the Low Weald and Eden floodplain ought to largely feature seasonally-damp species- rich meadows, field ponds, hedgerows and pockets of wet woodland. The North Downs are a further matter, where Calcareous (chalk) grassland creation will always be the priority.’

In addition, a strategic scale area of green infrastructure would help the Local Plan deliver a net gain in biodiversity, in accordance with paragraphs 6 and 109 of the NPPF.

Green Infrastructure master-planning for the garden community should be mindful of the constraints and opportunities cited in the supporting evidence paper ‘Ecological Appraisals of Potential Garden Village Locations’

The South Godstone Garden Community site also overlaps with the Eden Biodiversity Opportunity Area (BOA) comprising floodplain grazing marsh, wet woodland and

86 lowland meadows. As cited in background evidence21, development offers an opportunity to create a green infrastructure corridor and increase linkages between the meadows and ancient woodlands, particularly around Cloverhouse Meadows in the south east quadrant. Broadening and enhancing the ancient woodland corridor in the north west quadrant and increasing wildlife linkages in the north east quadrant could be achieved within a holistic masterplan. The Ecological Assessment map at Appendix C of the Ecological Appraisals of Potential Garden Village Locations indicates various areas where new habitats could be created to buffer and enhance existing assets.

The new South Godstone Garden Community should incorporate integral green infrastructure (GI), as part of a site-specific GI masterplan. The NPPF establishes this requirement, supported by the TCPA. Developers will need to avoid, mitigate and if necessary, compensate all the environmental impacts of the Garden Community, some of which could be achieved through the appropriate master-planning of GI.

Specifically master-planning for the South Godstone Garden Community should highlight the pockets of locally important and ancient woodland which impose constraints on access, and will require protection and buffering in the context of major new residential development. The ancient woodland corridor in the NW quadrant running north from the railway line as far as Harts Lane imposes a constraint on east- west road access and drainage infrastructure, including access from the existing settlement of South Godstone. However, this could be overcome if access can be taken from Tilburstow Hill Road and Harts Lane. Residential densities should be reduced near the two ancient woodland/meadow/habitat restoration zones in the SE and NW quadrant.

This should contribute to the delivery of the current national Biodiversity Strategy Biodiversity 2020, which has a high-level target ‘outcome’ to find room, by 2020, for an additional 200k ha of Priority habitats across England. This has been further broken down by habitat and ‘Natural Character Area’.

Therefore, the new South Godstone Garden Community should provide a significant green infrastructure resource for the following purposes:

 to address pre-existing access deficits to larger natural greenspace (100ha+) that exists cross the south of the District,  to meet the aims and objectives of the adjacent Eden Biodiversity Opportunity area, in accordance with the BOAs guidance document here.  to improve and enhance biodiversity and habitat connectivity as components of wildlife corridors in accordance with the NPPF, and focusing on priority habitats  to reduce the risk of recreational pressures emerging or increasing on internationally protected sites outside the District, by dissuading recreational visits and vehicle journeys via the provision of local alternatives. In this respect it may incorporate many of the characteristics expected of a Suitable Alternative Natural Greenspace SANG

21 ‘ Ecological Appraisals of Potential Garden Village Locations’

87  as a climate change adaptation measure incorporating carbon sequestration and air quality buffering.  as recreational space for community health & well-being  as flood alleviation and/or part of a multi-functional area designed primarily for SuDS;  to meet national Biodiversity targets, including where expressed by priority habitat and/or ‘Natural Character Area’.

This should be appropriately designed so as to respond to the prevailing geophysical character of the area. GI for biodiversity in the Low Weald and Eden floodplain will be primarily focused upon seasonally-damp species-rich meadows, field ponds, hedgerows and pockets of wet woodland, but other stepping stone priority habitats should be investigated within a masterplan.

88 Map 16: Biodiversity Opportunity Areas – South Godstone area.

89 The following recommended policy may be more appropriately considered in the forthcoming Garden Community AAP, given its detail.

Recommended Policy: Garden Community Green Infrastructure

The South Godstone Garden Community will provide a significant area of green infrastructure (at least 100 hectares on a single site) that will:

 Address pre-existing access deficits to larger natural greenspace (100ha+) that exists cross the south of the District;  Meet the aims and objectives of the adjacent Eden Biodiversity Opportunity area, or to assist reducing the risk of recreational pressure on protected international sites;  Improve and enhance biodiversity and habitat connectivity as components of wildlife corridors in accordance with the NPPF;  Incorporate circular walks of at least 2.5ha to reduce the risk of recreational pressures emerging or increasing on internationally protected sites outside the District;  Have a role as a climate change adaptation measure incorporating carbon sequestration and air quality buffering;  Serve as recreational space promoting community health & well-being;  Serve as flood alleviation and/or part of a multi-functional area designed primarily for SuDS.

90 5.8 Partnership Working and Monitoring

5.8.1 Partnership Working

Matters related recreational pressure on the Ashdown Forest have been considered in partnership and in regular meetings with other planning authorities that potentially impact upon the Ashdown Forest (Wealden, Mid Sussex, Lewes, Tunbridge Wells, Tandridge and Sevenoaks) and Natural England. Matters discussed include Strategic Access Management and Monitoring (SAMM), SPA Monitoring Strategy and Legal Agreement, the implications of the updated Visitor Survey published in March 2017, and appropriate mitigation zones.

A proposed ‘Statement of Common Ground’ between the Ashdown Forest: SAMMS Partnership is at the very early stages of formulation between Lewes District Council, Mid Sussex District Council, Sevenoaks District Council, Tandridge District Council, Tunbridge Wells Borough Council, Wealden District Council and Natural England. This Statement of Common Ground will relate to Visitor pressure and will assist the members of the SAMMS Partnership in determining planning applications and in Local Plan preparation and ensure, so far as practicable, a consistent approach across the relevant areas.

5.8.2 Monitoring

An Ashdown Forest SPA Monitoring Strategy, by Footprint Ecology, was published in March 2018. This strategy was commissioned by Wealden District Council on behalf of six local authorities (Wealden, Mid Sussex, Lewes, Tunbridge Wells, Tandridge and Sevenoaks) and sets out monitoring requirements that relate to strategic mitigation at Ashdown Forest SPA.

Monitoring is integral to the strategic mitigation 'package'; ensuring the successful delivery of the mitigation work, acting as an early warning system and providing the feedback to hone mitigation. Monitoring will be necessary to ensure approaches are working as anticipated and whether further refinements or adjustments are necessary.

The strategy contains the following key components; which would mostly continue indefinitely, apart from the grey shaded rows that are focussed on the effectiveness of particular mitigation elements and these would only be necessary within a fixed time period.

91 Table 12: Key components of the SPA Monitoring Strategy

92 6. Conclusions

The Appropriate Assessment has considered a number of potential impacts upon the protected international sites, in combination with other projects or plans, as follows:

Ashdown Forest SPA and SAC

 Recreational Disturbance  Air Quality

Mole Gap to Reigate Escarpment SAC

 Recreational Disturbance  Hydrology  Air Quality

The Appropriate Assessment has investigated all the above and demonstrated how they can be screened out as non-significant, mitigated or impacts avoided. The AA has also identified a number of Local Plan measures and policies that will have positive ecological and sustainability outcomes as part of good planning, as well as reducing the likelihood of effects occurring in future.

As a consequence, provided the AA recommendations are followed through, it can be concluded that impacts of the Local Plan 2033 upon the international sites will be acceptable/non-significant.

Relevant Sections of the report containing further detail are as follows:

Ashdown Forest SPA and SAC

Recreational Disturbance: Section 5.5 -5.8.

Air Quality: Section 4.5

Mole Gap to Reigate Escarpment SAC:

Recreational Disturbance: Sections 3.4.5, 3.4.6

Hydrology: Sections 3.5.6, 3.5.7

Air Quality: Section 3.6.4

93 Appendix 1: Site Citations Appendix 1a – Citation for Ashdown Forest SAC

94 Appendix 1b – Citation for Ashdown Forest SPA

95 Appendix 1c – Citation for Mole Gap to Reigate Escarpment SAC

96 Appendix 2: Site of Special Scientific Condition Analysis

Appendix 2a – Ashdown Forest SSSI

97 Appendix 2b – Mole Gap to Reigate Escarpment SSSI

98 Appendix 3: Natural England Comments on Stage 1 Screening

99 Appendix 4: Exerts from Wealden DC Draft Background Paper – Ashdown Forest SPA Mitigation Zone

o The majority (96.23%) of visitors from Mid Sussex would be captured by a 10km boundary, whilst all visitors from Mid Sussex would be captured by a 15km boundary; o The majority (86.96%) of visitors from Tunbridge Wells would be captured by a 13km boundary, whilst all visitors would be captured by a 26km boundary; o The majority (75.00%) of visitors to the SPA from Lewes would be captured by a 17km boundary, whilst all visitors would be captured by a 28km boundary; o The majority (66.67%) of visitors to the SPA from Tandridge would be captured by a 20km boundary, whilst all visitors would be captured by a 25km boundary; o The majority (80.00%) of visitors to the SPA from Sevenoaks would be captured by a 21km boundary, whilst all visitors would be captured by a 26km boundary.

Tandridge

A total of 6 visitors who were interviewed were found to originate from Tandridge District. Of these, none visited daily or most days, 2 visited 1-3 times per week, none visited 2-3 times per month, 2 visited once per month and none visited less than once per month. See Figure 8.1 in Appendix 28 in relation to this data. Of those visitors interviewed, none lived within 7km of the SPA, 50% lived within 15km of the SPA, 66.67% lived within 20km of the SPA and 100% lived within 25km of the SPA; There were no visitors who visited daily or most days; Of those visitors who visited at least 1-3 times per week, none lived within 7km of the SPA, 50% lived within 9km of the SPA and 100% lived within 10km of the SPA; Of those visitors who visited at least 2-3 times per month, none lived within 7km of the SPA, 50% lived within 9km of the SPA and 100% lived within 10km of the SPA; Of those visitors who visited at least once per month, none lived within 7km of the SPA, 50% lived within 10km of the SPA, 75% lived within 15km of the SPA and 100% lived within 25km of the SPA; Of those visitors who visited at least once per month or less than once per month, none lived within 7km of the SPA, 75% lived within 13km of the SPA and 100% lived within 25km of the SPA.

Council Offices, 8 Station Road East, Oxted, Surrey RH8 0BT [email protected] www.tandridge.gov.uk Tel: 01883 722000