Planning Policy Manager
Woking Borough Council
Woking GU21 6YL
23 January 2017
Land East of Martyrs Lane
Thank you for your letter dated 13 January 2017 regarding consultation on the inclusion of the above site in the Site Allocations Development Plan Document (DPD). The Horsell Common Preservation Society (HCPS) owns part of the land within the proposed site and strongly objects to its inclusion in the scheme. Furthermore, HCPS objects overall to the proposal of a housing development at this location for the reasons described below.
1. 150ha of Horsell Common, which adjoins the proposed site, is designated as a Site of Special Scientific Interest (SSSI). It also forms part of the internationally important, Thames Basin Heaths Special Protection Area (TBH SPA) which was designated on 9th March 2005. This in turn forms part of Natura 2000, a European-wide network of sites of international importance for nature conservation established under the European Community Wild Birds and Habitat directive 79/409/EEC. The TBH SPA is one of the South East’s most important natural assets with the lowland heath supporting important populations of Dartford Warbler, Nightjar and Woodlark – vulnerable ground-nesting birds. The SPA covers much of the heathland areas of Horsell Common and together with small areas of Brookwood Heath and Sheets Heath, carries the highest level of environmental protection in UK and European terms within the Borough of Woking.
2. The UK government abolished the South East Regional Plan in 2013 to free up restrictive development plans and to devolve more planning strategy to local authorities. Yet one key element from the South East Regional Plan was retained due to its high ecological value, namely, Natural Resource Management Policy NRM6.
In a press statement in 2013, the Rt Hon Sir Eric Pickles MP – Minister for the Department for Communities and Local Government said:
“The coalition government is determined to protect and safeguard our natural and cultural heritage and has decided not to revoke the policy on the Thames Basin Heaths Special Protection Area or the structure plan policy covering the former Upper Heyford RAF base”.
Policy NRM6 states:
New residential development which is likely to have a significant effect on the ecological integrity of Thames Basin Heaths Special Protection Area (SPA) will be required to demonstrate that adequate measures are put in place to avoid or mitigate any potential adverse effects. Such measures must be agreed with Natural England. Priority should be given to directing development to those areas where potential adverse effects can be avoided without the need for mitigation measures…..
3. Natural England has demonstrated that increased population arising from housing developments at a distance of up to 5km from this SPA can cause significant disturbance to the breeding success of these rare bird populations. This is largely due to the impact of residents’ recreational activities, particularly walking and walking with dogs. Thus, all housing developments within 5km of the SPA are now subject to stringent tests and impact assessments resulting in the provision of SANGs to mitigate harm. Nevertheless, it is our view that a development of this magnitude, particularly when assessed with other proposed housing developments in the locality, could not possibly receive protection from harm by mitigation measures alone. It is therefore essential that avoidance measures be implemented and special consideration be given to the nearby enlargement of Sheerwater housing scheme by a further 350 new homes, plus the proposed Fairoaks Garden Village development of an additional 1500 homes just a few hundred metres to the north. Whilst we accept that the entire Borough of Woking falls within the 5km mitigation protection zone, and therefore total avoidance is an unlikely option, it must surely be obvious that a large housing development just outside the 400 metre exclusion zone will still attract additional visitors to the SPA, regardless of there being a SANG included within the development scheme.
4. According to the 2012 TBH SPA visitor survey commissioned by Natural England and conducted by Footprint Ecology, the close proximity to existing urban development and the unique features of Horsell Common rates it as and is one of the most frequently visited sites across the entire TBH SPA. Thus, Horsell Common SSSI Unit 4, which is closest to the proposed development, fails to meet “Favourable Condition” status, partly due to existing high visitor numbers. The latest condition report for Unit 4 from Natural England concludes:
Mosaic of woodland and dry heath with wet areas and sandpit. Heavy recreational use and dog fouling creates pressure on the tracks and sandpit habitats. Ponds are overused by dogs. Maintenance of the heathland and woodland to establish greater age ranges and open tracks is underway establishing good habitat for invertebrates.
HCPS and WBC are making good progress in addressing the problem of excessive footfall on the SPA by the introduction of new SANGs, but additional pressure from schemes such as this proposal and the neighbouring Fairoaks development can only serve to undo the good work achieved to date.
5. The proposed Martyrs Lane scheme includes a substantial and strategic area of Registered Common Land in the ownership of HCPS abounding Chertsey Road and Martyrs Lane. (Commons registration No.CL100). Should this scheme proceed, HCPS would not be willing to dispose of the land in its ownership and, in any event, it may require an application for deregistration under s.16 of the Commons Act 2006 where only the landowner can submit the application to deregister.
Horsell Common Preservation Society