Habitats Regulations Assessment of the Chiltern and South Bucks Local Plan

HRA Screening Document

January 2017

Habitats Regulations Assessment of the Chiltern and South Bucks Local Plan

Screening Report

LC-260 Document Control Box

Client Chiltern District Council & South Bucks District Council

Habitats Regulations Assessment of the Chiltern and South Bucks Local Report Title Plan: Screening Report

Status Draft

Filename LC-260_SBDC&CDC_HRA_Screening_8_030117JE.docx

Date January, 2017

Author JE

Reviewed RB

Approved ND

Photo: Aston Rowant Nature Reserve

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Contents 1 Introduction ...... 5 1.1 Background ...... 5

1.2 Approach to report preparation ...... 6

1.3 The HRA process ...... 7

1.4 About the Local Plan Green Belt Preferred Options Public Consultation ...... 8

1.5 HRA process to date ...... 9

2 Methodology ...... 10 2.1 Habitats Regulations Assessment methodology ...... 10

2.2 Dealing with uncertainty ...... 11

2.3 Likely significant effect ...... 13

2.4 Limitations ...... 14

3 European sites ...... 15 3.1 About European sites ...... 15

3.2 Identification of relevant European sites ...... 15

3.3 Ecological information ...... 16

4 Potential Effects ...... 17 4.1 Introduction ...... 17

4.2 Screening out sites ...... 21

4.3 Conservation objectives ...... 21

4.4 Site pressures and threats ...... 22

4.5 Scoping out pressures and threats ...... 24

4.6 Air pollution ...... 25

4.7 Wildfire/arson ...... 30

4.8 Public access/disturbance ...... 31

4.9 Hydrological changes ...... 39

5 Conclusions and Recommendations ...... 41 5.1 Assessment findings ...... 41

5.2 Next steps ...... 42

Appendix A: Conservation objectives for European Sites

Appendix B: Summary of all relevant European sites and current threats and pressures identified in Site Improvement Plans and Joint Nature Conservation Committee (JNCC) Natura 2000 data forms

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Figures

Figure 2.1 Summary flow chart of HRA process

Figure 4.1 Map illustrating location of European sites within 15km of the borders of the Chiltern and South Bucks districts

Tables

Table 4.1 European sites, SSSIs and conservation status

Table 4.2 Summary screening of GBPOPC

Threats and pressures for each European site identified as Table 4.3 potentially being affected by the Local Plan GBPOPC

Table A.1 Qualifying features and conservation objectives of European sites (Appendix A)

Table B.1 All threats and pressures of all European sites within 15km of the (Appendix B) Chiltern district and South Bucks district borders

Acronyms

AA Appropriate Assessment

AQMA Air Quality Management Area

DEFRA Department for Environment, Food, and Rural Affairs

EU European Union

GBPOPC Green Belt Preferred Options Public Consultation

GIS Geographic Information Systems

HRA Habitats Regulations Assessment / Appraisal

IPENS Improvement Programme for England’s Natura 2000 sites

IROPI Imperative Reasons of Overriding Public Interest

JNCC Joint Nature Conservation Committee

LPA Local Planning Authority

LSE Likely Significant Effect

N2K Natura 2000 Network

NE Natural England

NPPF National Planning Policy Framework

RIS Information Sheet on Ramsar Wetlands

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SAC Special Area of Conservation

SANG Suitable Alternative Natural Greenspace

SIP Site Improvement Plan

SNH Scottish Natural Heritage

SPA Special Protection Area

SSSI Site of Special Scientific Interest

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Executive Summary

E1 This HRA report has carefully considered the conservation objectives of European sites that might be associated with activities and projects as part of the Chiltern District and South Bucks District ‘Local Plan Green Belt Preferred Options Public Consultation October – December 2016’ (GBPOPC).

E2 Lepus identified nine European sites that lie within 15km of the boundaries of both districts.

E3 The following nine sites feature in this HRA report:

• Aston Rowant SAC

• Burnham Beeches SAC;

• Chilterns Beechwoods SAC;

• Richmond Park SAC;

• South West London Waterbodies SPA;

• South West London Waterbodies Ramsar;

• Thames Basin Heaths SPA;

• Thursley, Ash, Pirbright & Chobham SAC; and

• Windsor Forest & Great Park SAC.

E4 A number of recognised threats and pressures are associated with these sites as identified by Natural England. This HRA screening report explores the extent to which, if any, the proposals associated with the release of Green Belt for the purposes of residential and employment development will exacerbate or alleviate these threats and pressures.

E5 It is considered that proposed development in the GBPOPC will have a likely significant effect on Burnham Beeches SAC due to potential recreational disturbance impacts associated with public access, and potential impacts associated with air quality.

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1 Introduction

1.1 Background

1.1.1 Lepus Consulting has prepared this Habitats Regulations Assessment (HRA) report of the Chiltern and South Bucks Local Plan Green Belt Preferred Options Consultation October – December 2016 (GBPOPC) on behalf of Chiltern District Council and South Bucks District Council. This is a requirement of Regulation 102 of the Conservation of Habitats and Species Regulations 20101 (the Habitats Regulations).

1.1.2 The following European sites were identified using a 15km area of search around the Chiltern and South Bucks districts, as well as including sites which are potentially connected (e.g. hydrologically) beyond this distance:

• Aston Rowant SAC;

• Burnham Beeches SAC;

• Chilterns Beechwoods SAC;

• Richmond Park SAC;

• South West London Waterbodies SPA;

• South West London Waterbodies Ramsar;

• Thames Basin Heaths SPA;

• Thursley, Ash, Pirbright & Chobham SAC; and

• Windsor Forest & Great Park SAC.

1.1.3 Whilst Ramsar sites are not European sites, NPPF paragraph 118 states that Ramsar sites should be given the same protection as European sites. For the purpose of this report, the phrase ‘European site’ includes Ramsar sites, along with Special Protection Areas (SPAs) and Special Areas of Conservation (SACs) unless otherwise stated.

1 UK Government, (2010), The Conservation of Habitats and Species Regulations 2010

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1.1.4 The full list of the nature of, and conservation objectives of, each site can be found in Table A.1 and they are explored further in this report. Common qualifying features of the sites include beetle species such as the stag beetle (Lucanus cervus) and the violet click beetle (Limoniscus violaceus), beech forests on acid soils and wet heathland with cross- leaved heath.

1.1.5 The full list of threats and pressures each site is currently facing can be found in Table B.1. In Section 4.2 some sites are screened out of the assessment. In Section 4.5 some threats and pressures are scoped out of the assessment. The remaining threats and pressures, which represent a focus of this assessment, include ‘Public access and disturbance’, ‘Air pollution’, ‘Wildfire/arson’ and ‘Hydrological changes’.

1.2 Approach to report preparation

1.2.1 The outputs of this report include information in relation to:

• The HRA process;

• Methodology for HRA;

• Evidence gathering in relation to European sites;

• Conservation objectives of sites;

• Understanding threats and pressures relevant to each site; and

• Conclusions and recommendations.

1.2.2 This report comprises a screening assessment under the Habitats Regulations, which is the first step in assessing any likely significant effects of development proposals in the GBPOPC. This report sets the baseline with regards to European sites and determines whether the GBPOPC is likely to have any significant effects on these sites.

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1.3 The HRA process

1.3.1 The application of HRA to land-use plans is a requirement of the Conservation of Habitats and Species Regulations 2010, the UK’s transposition of European Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (the Habitats Directive). HRA applies to plans and projects, including all Local Development Documents in England and Wales.

1.3.2 The HRA process assesses the potential effects of a plan or project against the conservation objectives of any European sites designated for their importance to nature conservation. These sites form a system of internationally important sites throughout Europe and are known collectively as the ‘Natura 2000 network’.

1.3.3 European sites provide valuable ecological infrastructure for the protection of rare, endangered or vulnerable natural habitats and species of exceptional importance within the EU. These sites consist of SACs, designated under the Habitats Directive, and SPAs, designated under European Directive 2009/147/EC on the conservation of wild birds (the Birds Directive). Additionally, Government policy requires that sites designated under the Ramsar Convention (The Convention on Wetlands of International Importance, especially as Waterfowl Habitat) are to be treated as if they are fully designated European sites for the purpose of considering development proposals that may affect them.

1.3.4 Under Regulation 102 of the Habitats Regulations, the assessment must determine whether or not a plan will adversely affect the integrity of the European sites concerned. The process is characterised by the precautionary principle. The European Commission describes the precautionary principle as follows:

1.3.5 “If a preliminary scientific evaluation shows that there are reasonable grounds for concern that a particular activity might lead to damaging effects on the environment, or on human, animal or plant health, which would be inconsistent with protection normally afforded to these within the European Community, the Precautionary Principle is triggered.”

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1.3.6 Decision-makers then have to determine what action/s to take. They should take account of the potential consequences of no action, the uncertainties inherent in scientific evaluation, and should consult interested parties on the possible ways of managing the risk. Measures should be proportionate to the level of risk, and to the desired level of protection. They should be provisional in nature pending the availability of more reliable scientific data.

1.3.7 Action is then undertaken to obtain further information, enabling a more objective assessment of the risk. The measures taken to manage the risk should be maintained so long as scientific information remains inconclusive and the risk is unacceptable.

1.3.8 The hierarchy of intervention is important: where significant effects are likely or uncertain, plan makers must firstly seek to avoid the effect through, for example, a change of policy. If this is not possible, mitigation measures should be explored to remove or reduce the significant effect. If neither avoidance, nor subsequently, mitigation is possible, alternatives to the plan should be considered. Such alternatives should explore ways of achieving the plan’s objectives that do not adversely affect European sites.

1.3.9 If no suitable alternatives exist, plan-makers must demonstrate under the conditions of Regulation 103 of the Habitats Regulations, that there are Imperative Reasons of Overriding Public Interest (IROPI) in order to continue with the proposal.

1.4 About the Local Plan Green Belt Preferred Options Public Consultation

1.4.1 The outcome of the GBPOPC will help scope the 2014 – 2036 joint Local Plan for Chiltern District Council and South Bucks District Council. Key issues that will be addressed include:

• The level of development that should be planned for;

• A review of the Green Belt;

• A Green Belt Development Options Appraisal; and

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• The necessary infrastructure requirements for supporting planned development.

1.4.2 The proposed options for development and release from the Green Belt have been considered in the preparation of this HRA. These are presented in Table 4.2.

1.5 HRA process to date

1.5.1 The HRA process is iterative and assesses different stages of the plan making process. The HRA process of this report draws on the updated methodology prepared by David Tyldesley Associates for the Habitat Assessment Handbook (2016), as explained in Section 2.1.

1.5.2 Chiltern District Council and South Bucks District Council have determined the need for a HRA and have commissioned Lepus Consulting to undertake the scoping and screening stages for the GBPOPC. This report constitutes a screening report, which includes the screening stages of Figure 2.1.

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2 Methodology

2.1 Habitats Regulations Assessment methodology

2.1.1 HRA is a rigorous precautionary process centered on the conservation objectives of a site's qualifying interests. It is intended to ensure that designated European sites are protected from impacts that could adversely affect their integrity, as required by the Birds and Habitats Directives.

2.1.2 There is no set methodology or specification for carrying out and recording the outcomes of the assessment process. Government guidance on the HRA process was published by Defra in 2013 as a consultation draft. In the absence of a finalised or alternative version since then, the 2013 consultation draft represents the government’s most recent thinking.

2.1.3 The 2013 consultation draft helped inform the Habitats Regulations Assessment Handbook, produced by David Tyldesley Associates. The handbook, in particular ‘Practical Guidance for the Assessment of Plans under the Regulations (September, 2013)’, which forms part F, was used to prepare this report. This is widely considered to be an appropriate basis for the HRA of plans, as the Handbook is also used by Natural England, the Government’s statutory nature conservation organisation.

2.1.4 Screening of a plan for the likelihood of significant effects should be undertaken as soon as is practical. Most plans cannot be excluded, exempted or eliminated from assessment. If not, it is important to gather information on the European sites that may be affected by the plan. Each European site has conservation objectives, the integrity of which are currently under various pressures and facing various threats.

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2.1.5 If a significant effect on a site because of a plan is considered likely, mitigation efforts may be incorporated in to the plan before it is rescreened in an iterative process. If a significant effect remains likely, an Appropriate Assessment on the plan may be required. This provides a better understanding of potential effects and therefore assists in the identification of suitable mitigation measures. Mitigation measures are then applied until no adverse effect on the site’s integrity is predicted. Natural England, or the relevant statutory body, is also consulted over the findings of the draft HRA. A step-by-step guide to this methodology is outlined in the Practical Guidance and has been reproduced in Figure 2.1.

2.2 Dealing with uncertainty

2.2.1 The assessment of effects can be affected by uncertainty in a number of ways; some of these are addressed below.

Regulatory Uncertainty

2.2.2 Some plans will include references to proposals that are planned and implemented through other planning and regulatory regimes, for example, trunk road or motorway improvements. These will be included because they have important implications for spatial planning, but they are not proposals of the Local Planning Authority (LPA), nor are they proposals brought forward by the plan itself. Their potential effects will be assessed through other procedures. The LPA may not be able to assess the effects of these proposals. Indeed, it may be inappropriate for them to do so, and would also result in unnecessary duplication.

2.2.3 There is a need to focus the Habitats Regulations Assessment on the proposals directly promoted by the plan, and not on all and every proposal for development and change, especially where these are planned and regulated through other statutory procedures, which will be subject to HRA.

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Planning Hierarchy Uncertainty

2.2.4 The higher the level of a plan in the hierarchy the more general and strategic its provisions will be and therefore the more uncertain its effects will be. The protective regime of the Directive is intended to operate at differing levels. In some circumstances assessment ‘down the line’ will be more effective in assessing the potential effects of a proposal on a particular site and protecting its integrity. However, three tests should be applied (see A, B and C below).

2.2.5 It will be appropriate to consider relying on the HRA of lower tier plans, in order for an LPA to ascertain a higher tier plan would not have an adverse effect on the integrity of a European site, only where:

A] The higher tier plan assessment cannot reasonably assess the effects on a European site in a meaningful way; whereas

B] The HRA of the lower tier plan, which will identify more precisely the nature, scale or location of development, and thus its potential effects, is able to change the proposal if an adverse effect on site integrity cannot be ruled out. This is because the lower tier plan is free to change the nature and/or scale and/or location of the proposal in order to avoid adverse effects on the integrity of any European site (e.g. it is not constrained by location specific policies in a higher tier plan); and

C] The HRA of the plan or project at the lower tier is required as a matter of law or Government policy.

2.2.6 It may be helpful for the HRA of the higher tier plan to indicate what further assessment may be necessary in the lower tier plan.

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Implementation Uncertainty

2.2.7 In order to clarify the approach where there is uncertainty because effects depend on how the plan is implemented, and to ensure compliance with the Regulations, it may be appropriate to impose a caveat in relevant policies, or introduce a free-standing policy, which says that any development project that could have an adverse effect on the integrity of a European site will not be in accordance with the plan.

2.2.8 This would help to enable the assessors to reasonably conclude, on the basis of objective information, that even where there are different ways of implementing a plan, and even applying the precautionary principle, no element of the plan can argue that it draws support from the plan, if it could adversely affect the integrity of a European site.

2.3 Likely significant effect

2.3.1 The plan and its component policies are assessed to determine and identify any potential for ‘likely significant effect’ (LSE) upon European sites. The guidance (DTA, 2013) provides the following interpretation.

2.3.2 “In this context, ‘likely’ means risk or possibility of effects occurring that cannot be ruled out on the basis of objective information. ‘Significant’ effects are those that would undermine the conservation objectives for the qualifying features potentially affected, either alone or in combination with other plans or projects… even a possibility of a significant effect occurring is sufficient to trigger an ‘appropriate assessment’.”

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Figure 2.1: Relationship of steps in the Habitats Regulations Assessment with a typical plan-making process (reproduced from DTA, 2013)

2.4 Limitations

2.4.1 This report has been prepared using the best available data. References are cited in the text where appropriate. Lepus Consulting has collected no primary data in the preparation of this report.

2.4.2 In order to prepare this HRA, Lepus has been supplied with the Local Plan Green Belt Preferred Options Consultation by Chiltern District and South Bucks district. The Local Plan is still undergoing preparation.

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3 European sites

3.1 About European sites

3.1.1 Each site of European importance has its own intrinsic qualities, besides the habitats or species for which it has been designated, that enables the site to support the ecosystems that it does. An important aspect of this is that the ecological integrity of each site can be vulnerable to change from natural and human induced activities in the surrounding environment (pressures and threats). For example, sites can be affected by land use plans in a number of different ways, including the direct land take of new development, the type of use the land will be put to (for example, an extractive or noise-emitting use), the pollution a development generates and the resources used (during construction and operation for instance).

3.1.2 An intrinsic quality of any European site is its functionality at the landscape ecology scale. This refers to how the site interacts with the zone of influence of its immediate surroundings, as well as the wider area. This is particularly the case where there is potential for developments resulting from the plan to generate water or air-borne pollutants, use water resources or otherwise affect water levels. Adverse effects may also occur via impacts to mobile species occurring outside of a designated site but which are qualifying features of the site. For example, there may be effects on protected birds that use land outside the designated site for foraging, feeding, roosting or other activities.

3.2 Identification of relevant European sites

3.2.1 The guidance (DTA, 2013) specifies no specific size of search area. During the screening process, as a starting point to explore and identify which European sites might be affected by the GBPOPC, a 15km area of search was applied from the boundaries of the Chiltern and South Bucks districts. A total of nine EU sites were identified.

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3.3 Ecological information

3.3.1 Table A.1 identifies the qualifying features of each site and presents details of conservation objectives for each of the sites identified as potentially being affected by the GBPOPC. This information is drawn from the Joint Nature Conservancy Council (JNCC) and Natural England (NE).

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4 Potential Effects

4.1 Introduction

4.1.1 The nine European sites identified for assessment during baseline research are illustrated in Figure 4.1 and listed in Table 4.1. Each site is within 15km of the border of the Chiltern and South Bucks districts.

4.1.2 Sites of Special Scientific Interest (SSSI) are protected areas in the United Kingdom designated for conservation. SSSIs located either entirely or partially within the European sites considered in this report are listed in Table 4.1 along with their current conservation status. The conservation status of each SSSI highlights any SAC/SPA that is currently particularly vulnerable to threats/pressures.

Table 4.1: European sites within 15km of the Chiltern and South Bucks districts border and the conservation status of corresponding SSSIs. Note: 8 of the 98 SSSIs intersecting with Thames Basin Heaths SPA are currently in an ‘Unfavourable – declining’ state of conservation.

European Site No. of SSSIs Conservation Status of SSSIs

Aston Rowant SAC 6 6/6 Favourable

3/4 Favourable Burnham Beeches SAC 4 1/4 Unfavourable – recovering 20/29 Favourable Chilterns Beechwood SAC 29 9/29 Unfavourable – recovering Richmond Park SAC 13 13/13 Unfavourable – recovering 4/7 Favourable South West London Waterbodies SPA 7 3/7 Unfavourable - recovering 4/7 Favourable South West London Waterbodies Ramsar 8 3/7 Unfavourable - recovering 23/98 Favourable 64/98 Unfavourable – recovering Thames Basin Heaths SPA 98 3/98 Unfavourable – no change 8/98 Unfavourable – declining 6/20 Favourable Thursely, Ash, Pirbright & Chobham SAC 20 14/20 Unfavourable – recovering 11/21 Favourable Windsor Forest & Great Park SAC 21 10/21 Unfavourable – recovering

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Figure 4.1: Map illustrating location of European Sites (SPAs, SACs and Ramsar sites) and a 15km buffer zone measured from the Chiltern and South Bucks district borders.

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Table 4.2: Summary screening of the Local Plan Green Belt Preferred Options Public Consultation, October – December 2016.

Land Land to be Assessment considered Proposed Screening Element of plan released and reasoning developable developments conclusion (ha) (ha) Administrative Chapter 1 - - - Screened out text General Chapter 2 statement on - - - Screened out overall goals

Preferred option 1: 1, 2, 3, 4 North east of Category H 57.26 26.1 (considered), 5 Screened out Chesham 900 dwellings

Preferred option 1, 2, 3, 6 2: Area south of Category H 17.63 12.2 Screened out Holmer Green 300 dwellings

Preferred option 1, 2, 3 3: Land east of Category I 9.22 6.67 Screened in Hazlemere 200 dwellings Preferred option 4: Area South of 1, 3, 7 (retained) London Road Category I 9.66 1.8 Screened in West, Amersham 50 dwellings Old Town Preferred option 5: Area South 1, 3 East of Whielden Category I 5.99 2.2 70 - 80 Screened in Street, Amersham dwellings Old Town 1, 9, 4, 5 Preferred option (considered), 10 Research 6: South East of Category H 51.22 (considered), 13 Screened out required Little Chalfont 850 – 1,000 dwellings

Preferred option 1 (considered), 7: National 2, 3, 9 Category I 27.97 3.71 Screened in epilepsy centre, Housing will be Chalfont St Peter considered Preferred option 8: Area South 1, 2, 3 Category I 13.71 12 Screened in East of Chalfont 420 dwellings St Peter 1, 2, 3, 5 (considered), 10 Preferred option (considered), 11, Research 9: Area East of Category I 117.39 13 Screened in required Beaconsfield 1,500 – 1,700 dwellings

Preferred option Category I 4.65 Research 15 Screened in 10: Land North of

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Denham required Roundabout Preferred option 11: Land North of Category I 19.41 16.01 1, 2, 3, 7, 8 Screened in Iver Heath, South East of Pinewood

Preferred option 1, 2, 3 12: Area West of Category I 31.65 10.27 Screened in Iver Heath 360 dwellings 1, 2, 3, 4, 5 (considered), 9 Preferred option (considered), 10 13: Area North of Category I 33.86 24 (considered), 11, Screened in Iver Station 16 800 dwellings Preferred option 14: Area to the 1, 7 East of Ridgeway Category I 6.2 1.2 (considered), 8, Screened in Business Park, 15 Iver Preferred option 15: Area Adjacent Category I 4.41 3.7 15 Screened in to Taplow Station

Total dwellings: Summary 410.23 ha 119.86 ha 5,450 – 5,810+

Legend of proposed developments: Legend of assessment and reasoning categories:

1: Residential A: General statements of policy / general 2: Associated infrastructure aspirations 3: Open space B: Policies listing general criteria for testing the 4: Local centre acceptability / sustainability of proposals 5: Gypsy and Traveller accommodation C: Proposal referred to but not proposed by the 6: Travelling and show people plan accommodation D: Environmental protection / site safeguarding 7: Commercial use policies 8: Industrial use E: Policies or proposals that steer change in such 9: Specialist elderly accommodation a way as to protect European sites from adverse 10: Self-build houses effects 11: Local shopping services F: Policies or proposals that cannot lead to 12: Community facilities development or other change 13: Employment G: Policies or proposals that could not have any 14: Sports facilities conceivable or adverse effect on a site H: Policies or proposals the (actual or theoretical) effects of which cannot undermine the conservation objectives (either alone or in combination with other aspects of this or other plans or projects) I: Policies or proposals with a likely significant effect on a site alone J: Policies or proposals not likely to have a significant effect alone

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4.2 Screening out sites

4.2.1 No current threats or pressures were identified in the Site Improvement Plan for Richmond Park SAC. There were also no threats or pressures identified in its Natura 2000 data form and this site has therefore been screened out of assessment.

4.2.2 Thames Basin Heaths SPA is 15km south from preferred option 15 ‘Area Adjacent to Taplow Station’ but more than 20km from all other preferred options. The majority of Option 15 lies within Flood Zone 2 and the proposed development is 3.7 hectares of offices for employment purposes. None of the proposed development within the GBPOPC will result in a likely significant effect on Thames Basin Heaths SPA and this European site has therefore been screened out of assessment.

4.2.3 The only threat identified for Aston Rowant SAC that has not been scoped out is the threat of air pollution. Preferred option 2 (Area south of Holmer Green) and preferred option 3 (Land east of Hazlemere) are both 14km east of Aston Rowant SAC whilst all other options are at least 19km away. The integrity of Aston Rowant SAC will therefore not be undermined as a result of air pollution due to its distant proximity from proposed development in the GBPOPC. This European site has therefore been screened out of assessment.

4.2.4 The remaining six European sites are included in this assessment.

4.3 Conservation objectives

4.3.1 The Waddenzee case2 demonstrates that the effect of a plan or project on a European site cannot be considered to be significant if it ‘is not likely to undermine its conservation objectives’. The conservation objectives and qualifying features of each European site are presented in Table A.1. To help determine whether these conservation objectives will be undermined, this report considers whether any existing pressures on, or threats to, the site will be exacerbated.

2 European Commission Case C-127/02 Reference for a Preliminary Ruling ‘Waddenzee’ 07/9/2004 (para 45)

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4.4 Site pressures and threats

4.4.1 Site pressures and threats have been derived from data held by the JNCC on Natura 2000 Data Forms and Ramsar Information Sheets. These forms detail threats and pressures that would have a negative impact on the European sites. Site Improvement Plans (SIPs) have been developed for each European site as part of the Improvement Programme for England’s Natura 2000 sites (IPENS). These set out an overview of current and predicted issues at the site. Information regarding pressures and threats from Natura 2000 Data Forms and SIPs are summarised in Table B.1. Table 4.3 shows the filtered down list of issues that are discussed further in the following sections.

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Table 4.3: Filtered pressures and threats for European sites that may be affected by the GBPOPC. Scoped out pressures and threats (section 4.5), and screened out sites (Section 4.2), have been removed (SIP indicates data sourced from Site Improvement Plan, N2K indicates data also sourced from the JNCC Natura 2000 data forms and RIS indicates data from Information Sheet on Ramsar Wetlands).

Pressures/ threats European sites within Wildfire/ Public Access/ Hydrological Air Pollution 15km arson Disturbance changes All qualifying All qualifying Burnham Beeches SAC3 features (SIP features (SIP) + N2K)

Chilterns Beechwoods All qualifying S1083 Stag

SAC4 features (SIP) beetle (SIP)

South West London All qualifying

Waterbodies SPA5 features (SIP)

South West London All qualifying Waterbodies features (SIP + Ramsar6 RIS) H4010 Wet heathland with All qualifying cross-leaved Thursley, Ash, Pirbright All qualifying features (SIP + heath, H7150 & Chobham SAC7 features (SIP) N2K) Depressions on peat substrates (SIP) H9120 Beech forests on acid soils, H9190 Windsor Forest & Great Dry oak- Park SAC8 dominated woodland (SIP + N2K)

3 JNCC (2015), Natura 2000 Standard Data Form: Burnham Beeches Natural England (2015) Site Improvement Plan: Burnham Beeches 4 JNCC (2015), Natura 2000 Standard Data Form: Chilterns Beechwoods Natural England (2015) Site Improvement Plan: Chilterns Beechwoods 5 JNCC (2015), Natura 2000 Standard Data Form: Richmond Park Natural England (2014) Site Improvement Plan: Richmond Park 6 JNCC (2015), Natura 2000 Standard Data Form: South West London Waterbodies Natural England (2014) Site Improvement Plan: South West London Waterbodies 7 JNCC (2015), Natura 2000 Standard Data Form: Thursley, Ash, Pirbright & Chobham Natural England (2014) Site Improvement Plan: Thursley, Ash, Pirbright & Chobham 8 JNCC (2015), Natura 2000 Standard Data Form: Windsor Forest & Great Park Natural England (2014) Site Improvement Plan: Windsor Forest & Great Park

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4.5 Scoping out pressures and threats

4.5.1 Each site in this assessment was identified as being under various threats and pressures, some of which are considered to be beyond the scope of the influence of the GBPOPC. The following threats and pressures are therefore not considered in this assessment:

• Conflicting conservation objectives;

• Deer;

• Disease;

• Biocenotic evolution succession;

• Feature location/ extent/ condition unknown;

• Fisheries: Fish stocking;

• Forestry and woodland management;

• Habitat fragmentation;

• Inappropriate scrub control;

• Inappropriate weed control;

• Species decline;

• Undergrazing;

• Unsustainable on-site population or habitat;

• Abiotic (slow) natural processes;

• Changes in biotic conditions;

• Grazing;

• Interspecific floral conditions;

• Outdoor sports and leisure activities;

• Other human intrusions and disturbances;

• Recreational activities;

• Problematic native species; and

• Other ecosystem modifications.

4.5.2 The remaining threats and pressures that are considered to be within the scope of the influence of the GBPOPC can be seen in Table 4.3 and include:

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• Air pollution;

• Wildfires and arson;

• Public access and associated disturbances; and

• Hydrological changes.

4.5.3 The European sites included in this assessment, and the threats and pressures to which they are vulnerable, are listed in Table 4.3.

4.5.4 The threats and pressures listed in Table 4.3 will now be assessed in further detail for each European site, beginning with air pollution.

4.6 Air pollution

Vulnerability of European sites

4.6.1 Air pollution, in particular, atmospheric nitrogen deposition, has been identified as a pressure for all qualifying features of Burnham Beeches SAC, Chilterns Beechwoods SAC and Windsor Forest & Great Park SAC.

4.6.2 The qualifying feature of Burnham Beeches SAC under pressure from air pollution is the Atlantic acidophilous beech forests with Ilex and Taxus in the shrub layer. In Chilterns Beechwoods SAC the relevant qualifying features are the semi-natural dry grasslands and scrubland facies: on calcareous substrates, the beech forests on neutral to rich soils and populations of the stag beetle (Lucanus cervus). In Windsor Forest & Great Park SAC the relevant qualifying features are the Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer and old acidophilous oak woods with Quercus robur on sandy plains providing natural habitat for the violet beetle (Limoniscus violaceus). All qualifying features of Thursley, Ash Pirbright & Chobham SAC are also under threat from low air quality.

4.6.3 All SSSIs that intersect with these three EU sites are in either a ‘Favourable’ or ‘Unfavourable – recovering’ state of conservation.

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4.6.4 The critical loads of pollutants are defined as “quantitative estimates of exposure to one or more pollutants below which significant harmful effects on specified sensitive elements of the environment do not occur according to present knowledge”9.

4.6.5 Some areas of Windsor Forest & Great Park SAC are in the Critical Load Class of Acidophilous Quercus-dominated woodland, with a critical load of 10 – 15 kg N/ha/year. Some areas are in the Critical Load Class of Broadleaved deciduous woodland and others are in the Class of Fagus woodland, each of which has a critical load of 10 – 20 kg N/ha/year. Current levels of deposition at Windsor Forest & Great Park SAC exceed each of these critical loads and are, on average, 24.2 kg N/ha/year 10.

4.6.6 Burnham Beeches SAC is in the Critical Load Class of Fagus woodland with a critical load of 10 – 20 kg N/ha/year. The current levels of nitrogen deposition in Burnham Beeches SAC exceed this and are, on average, 25.6 kg N/ha/year11. Local environmental health officers manage a network of diffusion tubes at Farnham Common, three metres from the A335 and several hundred metres from the SAC. They recorded an 3 annual mean NO2 concentration of 33 μg/m in 2012. This figure fell to 30 μg/m3 in 2013, 29 μg/m3 in 2014 and 26 μg/m3 in 2015. Overall, this suggests that nitrogen deposition in the immediate vicinity of Burnham Beeches SAC has been declining in recent years.

4.6.7 The depressions on peat substrates of Thursley, Ash, Pirbright & Chobham SAC have a critical load of 10 - 15 kg/N/ha/year, whilst the Northern Atlantic wet heaths and European dry heaths have a critical load of 10 – 20 kg/N/ha/year. Current average levels of deposition at this site are 13.9 kg/N/ha/year.

9 UNECE (date unavailable) ICP Modelling and Mapping Critical loads and levels approach, available at: http://www.unece.org/env/lrtap/WorkingGroups/wge/definitions.html, accessed 20/09/16 10 Air Pollution Information System APIS (2016) Site relevant critical loads, available at: http://www.apis.ac.uk/srcl 11 Ibid

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4.6.8 Some areas of the Chilterns Beechwoods SAC are in the Critical Load Classes of Fagus woodland and broadleaved deciduous woodland, each with a critical load of 10 – 20 kg N/ha/year. Current levels of nitrogen deposition in these areas exceed this and are, on average, 31.1 kg N/ha/year. Other areas of the Chilterns Beechwoods are in the Critical Load Class of Sub-Atlantic semi-dry calcareous grassland with a critical load of 15 – 25 kg N/ha/year. Current levels of deposition in these areas are lower than the critical load and are, on average, 18.6 kg N/ha/year12.

Effect of the GBPOPC development proposals

4.6.9 The Design Manual for Roads and Bridges (DMRB) suggests that air quality impacts from vehicles are most likely to occur within 200m of a road13. None of the preferred options for development and release from the Green Belt lie within 200m of a European site.

4.6.10 The European sites may be exposed to increased levels of air pollution as a result of increased traffic on nearby roads.

4.6.11 Air pollution has been identified as a threat for Thursley, Ash, Pirbright & Chobham SAC. However, all preferred options for development are at least 15km from this SAC. Chilterns Beechwoods SAC, Windsor Forest & Great Park SAC, South West London Waterbodies SPA & Ramsar and Burnham Beeches SAC offer alternative, and closer, green spaces to all sites within 15km of Thursley, Ash, Pirbright & Chobham SAC. Increases in traffic within the immediate vicinity of Thursley, Ash, Pirbright & Chobham SAC will therefore be insignificant. It is considered unlikely the integrity of Thursley, Ash, Pirbright & Chobham SAC will be undermined due to a reduction in air quality caused by the GBPOPC.

12 Air Pollution Information System APIS (2016) Site relevant critical loads, available at: http://www.apis.ac.uk/srcl 13 The Highways Agency, Transport Scotland, Welsh Assembly Government, The Department for Regional Development Northern Ireland (2007) Design Manual for Roads and Bridges, Volume 11, Section 3, Part 1: Air Quality

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4.6.12 The A332 and B3022 run directly through Windsor Forest & Great Park SAC. Access to both roads is more than 5km from any preferred option for development and increases in traffic on these roads as a result of the proposed development in the GBPOPC is considered unlikely.

4.6.13 The Chilterns Beechwoods SAC sites are scattered throughout the Chilterns Area of Outstanding Natural Beauty (AONB). At a number of locations they lie within 200m of a major road, including the A4010 and A308. Both roads are more than 5km from all preferred options for development and therefore increases in levels of traffic on these roads as a result of the proposed development in the GBPOPC is considered unlikely.

4.6.14 An Air Quality Management Area (AQMA) is located along the A416 in the centre of Chesham. 900 dwellings are proposed for preferred option 1 (North East of Chesham), along with associated infrastructure, open space and possibly a local centre and potentially Gypsy and Traveller accommodation. With an average of 2.3 people per dwelling in the UK, the proposed developments would lead to an increase of around 2,100 people in the local area of Chesham14. The increase in the number of frequent users of the A416 in the centre of Chesham will result in increased air pollution within the AQMA.

4.6.15 The closest European site to the AQMA in Chesham, and preferred option 1, is an area of the Chilterns Beechwoods SAC. It sits 7km north and is a twelve-minute drive by car. This area of the Chilterns Beechwoods is within 200m of the B4506 road at numerous locations. The B4506 connects the B489 and A4251 and is not considered a major route of commute in the local area. As such, the proposed developments at preferred option 1 would have an insignificant effect on traffic on the B4506. It is therefore considered unlikely that the developments at preferred option 1 would undermine the integrity of Chilterns Beechwoods SAC through a reduction in air quality.

14 Office for National Statistics, ONS, 2011 Census: Population and Household estimate for the United Kingdom, March 2011.

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4.6.16 Adverse effects of air pollution on the integrity of the qualifying features of Chilterns Beechwoods SAC and Windsor Forest & Great Park SAC as a result of the proposed developments in the GBPOPC are unlikely.

4.6.17 Burnham Beeches SAC is within 200m of the A355 at multiple locations of the site. The A355 provides a major route of access for the residents of South Bucks, running from the M4 and Slough in the south to the M40 and the town of Amersham in the north. Preferred options 4 (Area South of London Road West, Amersham Old Town) and 5 (Area South East of Whielden Street, Amersham Old Town) sit at the junction between the A355 and A413 near Amersham and include proposals for a total of 120 - 130 dwellings. Preferred option 9 (Area East of Beaconsfield) sits at the roundabout between the A355 and the A40 with proposals for a total of 1,500 – 1,700 dwellings, associated infrastructure, open space, local shopping services and community facilities. Increases in traffic on the A355 are therefore considered likely.

4.6.18 Roads in and around Burnham Beeches SAC have not undergone an increase in traffic in recent years15. According to a 2009 study, traffic on three roads near Burnham Beeches SAC, namely Hawthorn Lane, Pumpkin Hill and Stewarts Drive, were found to increase by a total of 9.9%, or 0.73% compounded per annum, between 1995 and 200716. In the same time, traffic on the A355 fell by 6.7% overall, an equivalent of around 0.53% compounded per annum. This suggests road users were increasingly using the smaller roads around the site as opposed to the major A355 road, which may be related to recent roadworks on the A355. In 2008 the combined northbound and southbound traffic flow on the A355 between 7am and 7pm was 12,101, down from the traffic flow figure of 14,283 recorded in 1995. The trend of reducing traffic in recent years

may be part of the cause of the trend of the falling NO2 concentration at Farnham Common.

15 Jacobs (2009): Burnham Beeches Traffic Monitoring: Annual Report for 2009 16 Ibid

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4.6.19 Atlantic acidophilous beech forest is particularly sensitive to atmospheric pollution, with eutrophication by nitrogen deposition a significant threat. The primary source of nitrogen deposition in the UK, significantly so in

residential developments, is road traffic. Whilst NO2 concentration in the region of the SAC appears to be declining, levels of atmospheric nitrogen deposition are still considered to be significantly higher than the critical load and any increases in road traffic will exacerbate this. The proposals for 1,500 – 1,700 dwellings on the A355 and A40 roundabout are considered likely to cause a significant increase in traffic on the A355. It is likely that this will result in a reduction in air quality at the site due to increased atmospheric nitrogen deposition. A likely significant effect on Burnham Beeches SAC, caused by air pollution associated with the GBPOPC, cannot be objectively ruled out based on the currently available information.

4.7 Wildfire/arson

Vulnerability of European site

4.7.1 Wildfire/arson has been identified as a threat for all qualifying features (wet heathland with cross leaved heath, European dry heaths and depressions on peat substrates of the Rhynchosporion) of Thursley, Ash, Pirbright & Chobham SAC.

4.7.2 Uncontrolled fires have profound impacts on plant diversity and can result in significant habitat loss.

Effect of the GBPOPC development proposals

4.7.3 Thursley, Ash, Pirbright & Chobham SAC is 15km south of option 13 (Area North of Iver Station) and option 14 (Area to the East of Ridgeway Business Park, Iver) and is easily accessed via the M25 and M3. The proposed developments will include 800 dwellings at option 13. Because Windsor Forest & Great Park SAC and South West London Waterbodies SPA are only 8.5km and 4.5km south of options 13 and 14, increases in the number of visitors to Thursley, Ash, Pirbright & Chobham SAC as a result of the developments at options 13 and 14 are thought to be insignificant.

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4.7.4 Adverse effects of wildfire and/or arson at Thursley, Ash, Pirbright & Chobham SAC as a result of the proposed developments in the GBPOPC are therefore considered unlikely to occur.

4.8 Public access/disturbance

4.8.1 Public access and disturbance has been identified as a pressure/threat for all qualifying features of South West London Waterbodies SPA & Ramsar, Chilterns Beechwoods SAC for the stag beetle and Burnham Beeches SAC for all qualifying features.

4.8.2 All SSSIs that intersect with these three European sites are in either a ‘Favourable’ or ‘Unfavourable – recovering’ state of conservation.

Vulnerability of South West London Waterbodies SPA & Ramsar

4.8.3 The South West London Waterbodies SPA & Ramsar is comprised of eight SSSIs, each of which is in either a ‘Favourable’ or ‘Unfavourable – recovering’ state of conservation:

• Kempton Park Reservoirs;

• Knight and Bessborough Reservoirs;

• Staines Moor Staines Reservoirs;

• Staines Moor King George VI Reservoir;

• Thorpe Park no. 1 Gravel Pit;

• Wraysbury Reservoir;

• Wraysbury and Hythe End Gravel Pits; and

• Wraysbury no. 1 Gravel Pit.

4.8.4 Two species of duck represent the qualifying features of South West London Waterbodies SPA & Ramsar under threat from public access and disturbance. Northern shoveler (Anas clypeata) and Gadwall (Anas strepera) can be found there over winter. The reservoirs and gravel pits in this site that function as important feeding and roosting sites are under pressure from public access and disturbances such as water sports.

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4.8.5 A key environmental condition of the SPA and Ramsar site is a lack of disturbance during the winter months of October to March. Disturbances of sufficient extent, duration or magnitude may result in Gadwall and Northern shoveler populations abandoning the South West London Waterbodies SPA & Ramsar. Five year mean peak counts for populations of Gadwall and Northern shoveler at each water body show a trend of decline. For example, between 1993/4 and 1997/8 the five-year mean peak count at Sunnymede Gravel Pits (one of the gravel pit components of the SPA) was 83 for Gadwall and 35 for the Northern shoveler. Between 2002/3 and 2006/7 these figures were 15 and 117.

4.8.6 Different waterbodies of the site offer various recreational opportunities for the public, including fishing, water-skiing, tow-water-skiing, boating, sailing, walking, dog-walking, diving and bird-watching. Recreational activities have been taking place on a number of component water bodies and in some cases have done so since before SSSI and SPA designations were in place. Other disturbances include reservoir maintenance work, pollution events and gravel extraction.

4.8.7 Evidence that recreational disturbances at this site have been increasing is scarce and there are suggestions that recreational pressure has actually declined at some locations of the site. Evidence of a causal relationship between human disturbance and the declining populations is also scarce. For example, populations have declined at the Wraysbury Reservoir despite birdwatchers being the only form of disturbance18.

17Briggs, B., (2007) The use of waterbodies in South-West London by Gadwall and Shoveler; implications for nature conservation. Doctorate thesis, Department of Zoology, University of Oxford 18Banks, A. N., Austin, G. E., Rehfisch, M. M., (2004) South West London Waterbodies SPA Wildfowl Population Analysis. British Trust for Ornithology.

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Effect of the GBPOPC development proposals on South West London Waterbodies SPA & Ramsar

4.8.8 Preferred options 13 and 14 of the GBPOPC are 5 - 8km north of this site, with good access via the M25. The development proposals include 800 dwellings, offices, commercial land and industrial land. Preferred option 12, with proposals for 360 dwellings, is 7 - 10km north of this site with good access via the A4007 and M25. Preferred options 10 and 11 are 10km to 15km north of the site with good access via the A412 and the M25. Proposed developments for these sites include residential, commercial and industrial uses. Overall, the GBPOPC includes proposals for at least 1,160 dwellings, land for offices, land for commercial uses and land for industrial purposes within 15km of South West London Waterbodies SPA & Ramsar. This site would also represent the closest site to, and the easiest site to access for, these developments.

4.8.9 Different water bodies of the site offer different levels of access to the public, with some more restricted than others. Whilst the minority of sites that have unrestricted access to the public will be most affected by the proposed developments, recreational use of the site is managed through the Potentially Damaging Operation scheme. Any operations that may undermine the integrity of the SSSIs therefore require consent from Natural England.

4.8.10 Knight and Bessborough Reservoirs and Wraysbury Reservoir are operational sites belonging to Thames Water and public access is limited. At Knight and Bessborough Reservoirs, a total of ten permits are available to bird-watchers from recognised clubs.

4.8.11 Thorpe Park no.1 Gravel Pit is in the immediate vicinity of Thorpe Park Resort. Public access is limited and thus recreational pressure is thought unlikely to increase as a result of the developments in the GBPOPC.

4.8.12 Kempton Park Reservoirs are not open to the public and locked fencing surrounds the site.

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4.8.13 Staines Moor is a part of the Colne Valley Regional Park, a 27,000-acre park managed by the Community Interest Company (CIC). The objectives of the CIC include safeguarding, conserving and enhancing the local landscape, countryside and biodiversity of The Park.

4.8.14 Adverse effects of the proposed developments in the GBPOPC on the integrity of the South West London Waterbodies SPA & Ramsar are therefore considered unlikely.

Vulnerability of Chilterns Beechwoods SAC

4.8.15 At Chilterns Beechwoods SAC, the qualifying feature recognised as being under threat from public access and disturbance is the stag beetle. Dead and decaying wood forms an important part of the stag beetle’s habitat. The removal of dead wood, either by the public or in the interest of health and safety, is an issue in some parts of the SAC.

4.8.16 Seven different areas allocated as part of the Chilterns Beechwoods SAC lie within 15km of multiple preferred options of the GBPOPC. Preferred option 1 sits 7km south of Chilterns Beechwoods SAC regions north of the districts with good access to the site via the A416. Preferred options 2 and 3 are 6km east and a 15-minute drive by road from Chilterns Beechwoods regions to the west of the districts. For preferred options 1, 2 and 3 Chilterns Beechwoods SAC represents the closest EU site.

Effect of the GBPOPC development proposals on Chilterns Beechwoods SAC

4.8.17 Overall, Chilterns Beechwoods SAC regions to the north and west of the districts are within 15km of preferred options 1, 2, 3, 4, 5 and 6, for which the proposed dwellings total 1,720 - 1,730. Associated infrastructure, open spaces, local centres and commercial uses are also proposed whilst travelling and show people accommodation, Gypsy and Traveller accommodation and self-build houses will also be considered. Chilterns Beechwoods SAC represents the closest European site to options 1, 2 and 3.

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4.8.18 Chilterns Beechwoods SAC comprises nine separate sites scattered throughout the Chilterns AONB, to which it is estimated there were over 55 million visits in 200719.

4.8.19 Despite high visitor numbers, of the 29 SSSIs that intersect with the Chilterns Beechwoods SAC, 20 are in a ‘Favourable’ state of conservation whilst the remaining nine are in a state of ‘Unfavourable – recovering’.

4.8.20 Increases in visitor numbers to the Chilterns Beechwoods SAC as a result of the GBPOPC would be distributed amongst a number of sites and would represent an insignificant increase on current visitor numbers.

4.8.21 Any operations that may damage the special interest of the SSSIs intersecting with the Chiltern’s Beechwoods will also require consent from Natural England.

4.8.22 The GBPOPC will result in an insignificant increase in visitor numbers to Chilterns Beechwoods. An adverse effect on the integrity of the habitat and populations of the stag beetle at Chilterns Beechwoods SAC, as a result of this, is considered unlikely.

Vulnerability of Burnham Beeches SAC

4.8.23 The qualifying feature of Burnham Beeches SAC recognised as being under threat due to public access and disturbance is Atlantic acidophilous beech forest.

4.8.24 Of the four SSSIs intersecting Burnham Beeches SAC, three have a conservation status of ‘Favourable’ whilst one has a conservation status of ‘Unfavourable – Recovering’.

19 Chilterns Area of Outstanding Beauty (2007) Available at: http://www.chilternsaonb.org/

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4.8.25 A previous study by Footprint Ecology on the Burnham Beeches SAC and urban development, as well as consultation with a local ecologist, confirmed that Burnham Beeches is already under significant pressure as a result of public access and associated disturbances20.

4.8.26 Burnham Beeches SAC is 380ha, 220ha of which is open public space. In 2010/11 it received 585,000 visitors, along with 215,000 dogs. In Footprint Ecology’s 2014 Burnham Beeches Visitor Survey report, 56% of respondents had named dog walking as their main activity during their visit.

4.8.27 43% of respondents cited the fact that Burnham Beeches SAC was close to home as being the most influential reason behind their decision to visit21. When excluding those on holiday or staying with friends, the mean distance travelled to visit Burnham Beeches SAC was 6km whilst the median distance travelled was 3.1km.

4.8.28 Trees are generally of an ill health; the number of old trees has declined markedly in recent years and there could potentially be a major break in the succession from young to old trees.

4.8.29 Visitors trample young vegetation and compact the soil. Veteran trees are the most popular with visitors and thus suffer the most frequently from disturbances such as compaction and tree climbing. Veteran trees are also the most susceptible to negative effects as a result of such disturbances.

20 Liley, D., Hoskin, R., Fearnley, H., White, J. & Underhill-Day, J. (2012) Urban Development and Burnham Beeches SAC. Unpublished report for Corporation of London 21 Liley, D., Floyd, L. and Fearnley, H. (2014). Burnham Beeches Visitor Survey. Footprint Ecology. Unpublished report for Corporation of London

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4.8.30 Barnard (2003) estimated that 33 – 48 tonnes of dog faeces and 1,650 litres of urine are left on Burnham Beeches SAC every year, with significantly negative impacts on an ecosystem that has a naturally low nutrient status22.

4.8.31 It is thought that the habitat of Burnham Beeches SAC could potentially support populations of rare species of birds if the levels of disturbance from visitors and dogs were not so high23.

4.8.32 Urbanisation in the immediate vicinity of Burnham Beeches SAC has resulted in cat predation being a significant threat for wildlife in the site. It has also resulted in the deterioration of large swathes of surrounding wildlife and green spaces. The surrounding landscape now provides less support to the ecosystem of Burnham Beeches SAC, rendering the site more fragile and more vulnerable to negative effects of development.

4.8.33 Significant progress has been made in protecting the integrity of Burnham Beeches SAC through on-site measures, including better management of cars and parking, relocating the visitor centre, fencing around key trees, promoting particular walking paths and creating a code of conduct for dog owners.

4.8.34 The scope for further onsite management efforts is therefore severely limited and offsite measures such as Suitable Alternative Natural Green Spaces (SANGs) and limiting urbanisation and housing intensification in the immediate vicinity of the site are being considered.

Effect of the GBPOPC development proposals on Burnham Beeches SAC

4.8.35 Burnham Beeches SAC is the only European site to lie entirely within the South Bucks district, to which the A355 provides a convenient route of access for residents via both the M4 and M40.

22 Barnard, A. (2003) Getting the facts – dog walking and visitor number surveys at Burnham Beeches and their implications for the management process. Countryside Recreation, 11, 16-19 23 Liley, D., Hoskin, R., Fearnley, H., White, J. & Underhill-Day, J. (2012) Urban Development and Burnham Beeches SAC. Unpublished report for Corporation of London

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4.8.36 There are currently 1,200 dwellings within 500m of Burnham Beeches SAC and 1,150,000 dwellings within 25km24. The proposed developments in the GBPOPC would see no new dwellings within 500m, but an additional 5,450 – 5,810 within 25km of the site.

4.8.37 The further away from the Burnham Beeches SAC developments are, the less number of visits to Burnham Beeches SAC, per property, that can be expected. The recent visitor survey conducted by Footprint Ecology calculated the annual visits to the site you can expect per property, as determined by distance from the site25. Based on these findings, 1.3 visits per dwelling per year can be expected for developments proposed at preferred option 9. For all other preferred options in the GBPOPC, 0.9 visits per property can be expected. 1,500 – 1,700 dwellings are proposed for option 9 and at least 3,950 – 4,110 dwellings proposed at all other options. If all proposed developments in the GBPOPC were to go ahead, an extra 5,505 – 5,909 visits per year could therefore be expected at Burnham Beeches SAC.

4.8.38 The integrity of Burnham Beeches SAC is already under significant pressure as a result of public access and disturbance. The proposed developments conflict with the offsite management measures of limiting urbanisation and housing intensification in the immediate vicinity to reduce the pressure of public access on Burnham Beeches SAC.

4.8.39 A likely significant effect on the qualifying features of Burnham Beeches SAC, due to public access and disturbances associated with developments in the GBPOPC, cannot be objectively ruled out based on the currently available information.

24 Liley, D., Hoskin, R., Fearnley, H., White, J. & Underhill-Day, J. (2012) Urban Development and Burnham Beeches SAC. Unpublished report for Corporation of London 25 Liley, D., Floyd, L. and Fearnley, H. (2014). Burnham Beeches Visitor Survey. Footprint Ecology. Unpublished report for Corporation of London

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4.9 Hydrological changes

Vulnerability of European site

4.9.1 Hydrological changes have been identified as a threat to the ‘wet heathland with cross-leaved heath’ and ‘depressions on peat substrates’ qualifying features of Thursley, Ash, Pirbright & Chobham SAC. Of particular concern are the effects of drains on natural drainage.

Effect of the GBPOPC development proposals

4.9.2 All development proposals of the GBPOPC are at least 15km north of Thursley, Ash, Pirbright & Chobham SAC, although the M25 and M3 provide convenient routes of access.

4.9.3 No proposed developments will impact the drainage at Thursley, Ash, Pirbright & Chobham SAC. Significant effects of the GBPOPC on the integrity of Thursley, Ash, Pirbright & Chobham SAC due to hydrological changes are considered unlikely to occur.

Hydrology at Burnham Beeches SAC

4.9.4 Hydrological changes have not been identified as a threat or pressure for Burnham Beeches SAC by Natural England in either the Site Improvement Plan or Natura 2000 Standard Data Form. However, one of the reasons for the designation of East Burnham Common of the site as an SSSI is its extensive mire system and the ecosystem this supports.

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4.9.5 Surface water reaches Burnham Beeches and feeds the mire from the Withy stream, the Nile stream, the Portman Estate stream and an unnamed stream26. Urban development in the catchment areas of these streams may impact water levels and/ or water quality at the mire, such as by increasing sedimentation. In recent years, the mire at the SAC has dried out due to reduced water levels, leading to Natural England and the Environment Agency spearing a drive for more sustainably managed local hydrology. To this end, urban development in the catchment area of the Withy stream must be accompanied by a hydrology report that assesses the impact of development and includes measures for mitigation.

4.9.6 No developments proposed in the GBPOPC are within the catchment areas of the Withy, Nile, Portman Estate or unnamed streams27. It is therefore considered unlikely that the GBPOPC will result in hydrological changes at Burnham Beeches SAC.

26 South Bucks District Council (2014) Development Management Guidance Note: Hydrology in Burnham Beeches SAC. Available at: http://www.southbucks.gov.uk/article/3971/Guidance-Notes- and-other-Key-Considerations 27 South Bucks District Council (2013) Burnham Beeches Hydrology Study, October 2013. Available at: http://www.southbucks.gov.uk/article/3971/Guidance-Notes-and-other-Key-Considerations

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5 Conclusions and Recommendations

5.1 Assessment findings

5.1.1 Nine SACs, SPAs and Ramsar sites within 15km of the borders of the South Bucks and Chiltern districts were considered in this assessment.

5.1.2 This HRA report has outlined the threats and pressures that have the potential to undermine the conservation objectives of each European site included.

5.1.3 It is considered that the only European site GBPOPC will have likely significant effects on is Burnham Beeches SAC, for the following reasons:

• Increasing the threat of air pollution;

5.1.4 Current levels of nitrogen deposition at Burnham Beeches SAC significantly exceed the critical load for Fagus woodland. Proposed developments at preferred options 4, 5 and 9 are expected to result in elevated levels of traffic on the A355, a major road within 200m of multiple points of Burnham Beeches SAC. Likely significant effects of air pollution on Burnham Beeches SAC, in relation to the GBPOPC, cannot be excluded on the basis of objective information (see Section 4.6).

• Increasing the pressure of public access and disturbance;

5.1.5 Burnham Beeches SAC is already under significant pressure from public access and associated disturbances. The scope for onsite management is severely limited with most avenues already explored. Offsite measures, including SANGs and limiting housing intensification in the immediate vicinity, are being considered. The GBPOPC would increase housing intensity and is predicted to result in an additional 5,505 – 5,909 visits per year. Likely significant effects of public access and disturbance, in relation to the GBPOPC, cannot be excluded on the basis of objective information (see Section 4.8).

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5.2 Next steps

5.2.1 This report is subject to comments and review by the client team and will then be subject to consultation with Natural England. Any responses from Natural England will be taken into account and this report will be reviewed and amended if possible.

5.2.2 If, after consultation, it is still considered that GBPOPC would have likely significant effects on the integrity of Burnham Beeches SAC, mitigation efforts may be incorporated in to the plan. If likely significant effects can still not be ruled out after additional screening of the plan, an Appropriate Assessment may be required to identify suitable mitigation measures.

5.2.3 Any further work to address the Likely Significant Effects confirmed at this screening stage of the HRA process will be subject to the mitigation hierarchy of avoid, mitigate and compensate.

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APPENDIX A

Table A.1: European sites and their conservation objectives (where available from Natural England)

Aston Rowant SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of qualifying natural habitats; • The structure and function (including typical species) of qualifying natural habitats; and • The supporting processes on which qualifying natural habitats rely.

Qualifying Features: • H5130. Juniperus communis formations on heaths or calcareous grasslands; Juniper on heaths or calcareous grasslands • H9130 Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils

Burnham Beeches SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of the qualifying natural habitats; • The structure and function (including typical species) of qualifying natural habitats; and • The supporting processes on which qualifying natural habitats rely.

Qualifying Features: • H9120: Atlantic acidophilous beech forests with Ilex also Taxus in the shrublayer (Quericon robori-petraeae or Ilici-Fagenion); Beech forests on acid soils

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Chilterns Beechwoods SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of the qualifying natural habitats and habitats of qualifying natural species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and the function of the habitats of the qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site.

Qualifying Features: • H6120: Semi-natural dry grasslands and scrubland facies: on calcareous substrates (Festuco-Brometalia); Dry grasslands and scrublands on chalk or limestone; • H9130: Asperulo-Fagetum beech forests; Beech forests on neutral to rich soils; and • S1083: Lucanus cervus; Stag beetle.

Richmond Park SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of the habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The population of qualifying species; and • The distribution of qualifying species within the site.

Qualifying Features: • S1083: Lucanus cervus; Stag beetle.

South West London Waterbodies SPA

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of the habitats of qualifying species; • The structure and function of the habitats of qualifying species; • The supporting processes on which the habitats of qualifying species rely; • The population of each of the qualifying features; and • The distribution of the qualifying features within the site.

Qualifying Features:

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• A051: Anas strepera; Gadwall (Non-breeding); and • A056: Anas clypeata; Northern shoveler (Non-breeding). •

South West London Waterbodies Ramsar

Conservation objectives: Ramsar sites do not have the Conservation Objectives in the same way as SPAs and SACs. Information regarding the designation of Ramsar sites is contained in INCC Ramsar Information Sheets. Ramsar Criteria are the criteria for identifying Wetlands of International Importance. The relevant criteria and ways in which this site meets the criteria are presented in the table below. Ramsar Justification for the application of each Criterion Criterion

6 Ramsar criterion 6 – species/populations occurring at levels of international importance.

Qualifying Species/populations (as identified at designation) (species with peak counts in spring/autumn):

• Northern shoveler, Anas clypeata, NW & C Europe.

Qualifying Species/populations (as identified at designation) (species with peak counts in winter):

• Gadwall, Anas strepera strepera, NW Europe.

Species currently occurring at levels of national importance in spring/autumn: • Great crested grebe, Podiceps cristatus cristatus, NW Europe; • Great cormorant, Phalacrocorax carbo carbo, NW Europe; and • Tufted duck, Aythya fuligula, NW Europe. Species currently occurring at levels of national importance in winter: • Black-necked grebe, Podiceps nigricollis nigricollis, Europe, N Africa.

Thames Basin Heaths SPA

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring; • The extent and distribution of the habitats of the qualifying features; • The structure and function of the habitats of the qualifying features; • The supporting processes on which the habitats of the qualifying features rely; • The population of each of the qualifying features; and • The distribution of the qualifying features within the site.

Qualifying Features: • A224: Caprimulgus europaeus, European nightjar (Breeding); • A246: Lullula arborea; Woodlark (Breeding); and • A302: Sylvia undata; Dartford warbler (Breeding).

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Thursley, Ash, Pirbright & Chobham SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying features, by maintaining or restoring; • The extent and distribution of qualifying natural habitats; • The structure and function (including typical species) of qualifying natural habitats; and • The supporting processes on which qualifying natural habitats rely.

Qualifying Features: • H4010: Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath; • H4030: European dry heaths; and • H7150: Depressions on peat substrates of the Rhynchosporion.

Wimbledon Common SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of qualifying natural habitats and habitats of qualifying species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and function of the habitats of qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site.

Qualifying Features: • H4010: Northern Atlantic wet heaths with Erica tetralix; Wet heathland with cross-leaved heath; • H4030: European dry heaths; and • S1083: Lucanus cervus; Stag beetle.

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Windsor Forest & Great Park SAC

Conservation objectives: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; • The extent and distribution of qualifying natural habitats and habitats of qualifying species; • The structure and function (including typical species) of qualifying natural habitats; • The structure and function of the habitats of qualifying species; • The supporting processes on which qualifying natural habitats and the habitats of qualifying species rely; • The populations of qualifying species; and • The distribution of qualifying species within the site.

Qualifying Features: • H9120: Atlantic acidophilous beech forests with Ilex and sometimes also Taxus in the shrublayer (Quercion robori-petraeae or Ilici-Fagenion); Beech forests on acid soils; • H9190: Old acidophilous oak woods with Quercus robur on sandy plains; Dry oak- dominated woodland; and • S1079: Limoniscus violaceus; Violet click beetle.

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APPENDIX B Table B.1: Pressures and threats for European sites that may be affected by the GBPOPC. Boxes with a cross indicate the site is vulnerable to that particular threat/pressure, but the individual qualifying features under threat/pressure have not been identified (applicable to data provided by Natura 2000 data forms).

EU sites within 20km

South West Thursley, Thames Aston Burnham Chilterns London Ash, Windsor Forest Richmond Basin Rowant Beeches Beechwoods Waterbodies Pirbright & & Great Park Park SAC Heaths (SAC) (SAC) (SPA & Chobham (SAC) (SAC) (SPA) Ramsar) (SAC)

All All H9120 Beech forests All qualifying All qualifying qualifying All qualifying on acid soils, H9190 qualifying Air Pollution features features features features (SIP Dry oak-dominated features (SIP + (SIP) (SIP + + N2K) woodland (SIP + (SIP) N2K) No N2K) N2K) Data H5130 threats/ from Juniper on pressures SIPs All qualifying Changes in species heaths or S1083 Stag identified and features distributions calcareous beetle (SIP) on SIPs or Natura (SIP) grasslands Natura 2000 (SIP) 2000 data H5130 data forms Juniper on forms Conflicting heaths or conservation calcareous objectives grasslands (SIP)

H9130 H9130 Beech Beech All forests on forests on qualifying Deer neutral to neutral to features rich soils rich soils (SIP) (SIP) (SIP) H5130 H9130 Beech Juniper on forests on H9190 Dry oak- heaths or Disease neutral to dominated calcareous rich soils woodland (SIP) grasslands (SIP) (SIP) All Feature location/ qualifying extent/ condition features unknown (SIP) All qualifying Fisheries: Fish features (SIP stocking + N2K) H4010 Wet heathland H9130 Beech All with cross- Forestry and forests on qualifying leaved heath, All qualifying woodland neutral to features H4030 features (SIP + N2K) management rich soils (SIP + European (SIP + N2K) N2K) dry heaths (SIP) All All All qualifying qualifying qualifying Habitat fragmentation features features features (SIP) (SIP) (SIP) H4010 Wet heathland with cross- leaved heath, Hydrological changes H7150 Depressions on peat substrates

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(SIP)

H4010 Wet heathland All with cross- Inappropriate scrub qualifying leaved heath,

control features H4030 (SIP) European dry heaths (SIP) All qualifying Inappropriate weed features control (SIP) H4010 Wet heathland H9130 Beech H9190 Dry oak- All with cross- forests on All qualifying dominated qualifying leaved heath, Invasive species neutral to features (SIP woodland, S1079 features H4030 rich soils + N2K) Violet click beetle (SIP) European (SIP + N2K) (SIP + N2K) dry heaths (SIP) All All qualifying qualifying Military features features (SIP) (SIP) All qualifying Natural changes to features site conditions (SIP) All All All qualifying Public access/ qualifying S1083 Stag qualifying features disturbance features beetle (SIP) features (SIP) (SIP) (SIP)

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All qualifying Species decline features (SIP) H4010 Wet heathland All with cross- qualifying leaved heath, Undergrazing features H4030 (SIP) European dry heaths (SIP) H5130 Juniper on Unsustainable on-site heaths or

population or habitat calcareous grasslands (SIP) All All qualifying qualifying Wildfire/ arson features features (SIP) (SIP) Abiotic (slow) natural x processes

Biocenoitic evolution x x succession

Changes in biotic x x x conditions

Grazing x

Human induced

Data changes in hydraulic x from conditions Natura Interspecific floral 2000 x x data relations x

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forms only Other ecosystem x modifications

Other human

intrusions and x x

disturbances Outdoor sports and

leisure activities, x x x

recreational activities

Problematic native x x x species

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