Context and background.

A Suitable Alternative Natural Greenspace (SANG) is “a recreational site, created to attract residents of new developments away from designated sites that are protected for their valuable ecology and are sensitive to recreational activities such as dog walking such as Special Protection Areas (SPAs) and Special Areas of Conservation (SACs).”

SANGs were evolved to protect the Thames-Basin Heaths SPA ~10 years ago and now the concept is spreading to protect more sites across the country including Mersey SPA, the Epping Forest SAC and the Chilterns Beechwood SAC.

Obviously, there is a need to protect important natural sites. However, as a statement of fact, the need for SANGs to protect SPAs and SACs are currently holding up many hundreds of homes. It is not clear that this is always reasonable or actually based in fact. It is worth considering one example in detail to understand why and how.

The example of the Chiltern Beechwoods SAC.

This is probably the most prominent example of the need for a SANG holding up many hundreds of homes and preventing the pre-approval of 950 homes within the Chesham Neighbourhood Plan. For example, the Chesham neighbourhood Development Order (NDO) for 950 homes is blocked because there is no alternative SANG in the town, and the Town Council cannot fund one. It would need to be in place before development starts. This is despite the fact that the town has unrivalled access to open countryside (it’s a destination for walkers) and a great park. Other proposals are also held by requirement for SANG to protect the Chiltern Beechwoods.

There appear to be several key problems with the analysis underpinning the requirement to create SANGS to protect the Chiltern Beechwoods.

A system wired for speed:

  • How far will people travel? Firstly, the impact assessment was based on visitor surveys and vehicle counts undertaken between May and August 2021, partly coinciding with the final lockdown period. Is this correct for understanding people’s propensity to travel to the Chiltern Beechwoods? Indeed, what is the measurement or underpinning methodology for understanding how far people will travel to recreate in a specific place. It is currently unclear what is correct or legally necessary. What is the ‘propensity to recreate’?
  • New homes with car parking versus new homes without car parking. New homes with low or no levels of parking (for example within Chesham town centre) are being assumed to have the same propensity to drive to the Chiltern Beechwooods as new homes in greenfield sites with more generous parking. This seems perverse.
  • ­When do visitors affect significant nature? Different elements of nature are defined as significant in different places. Within the Chilterns Beechwood SAC, Stag Beetles are the crucial species of importance. But these are not affected by visitors unless the visitors remove decaying timber (which seems unlikely).
  • Is it better to change management of natural sites rather than prevent new homes? The National Trust manages a café and visitor site within the Chiltern Beechwoods. Would it be better to subsidise changes to the management of the site? How might this reasonably improve the effect of visitors on the site?

The underpinning problem

The scientific and legal requirement that triggers the need for a SANG is unclear and this uncertainty is holding up many homes. Two particular issues are unclear in law:

  • Propensity to recreate. What is the propensity to recreate in a given area at a certain distance for new homes. How far will people drive to walk their dogs in the woods? How does new homes’ access to parking and cars and their location (within towns versus out of town) influence this?
  • ­Actual impact on natural features of importance. If new residents do travel to a particular place to recreate, what level of damage (if any) do they cause to natural feature of importance.

Proposed actions.

  • ­Commission a critical review of the scientific evidence base that underpins (1) the propensity of residents to recreate in the protected areas; and (2) the actual impact (if any) of recreation on the designated features of interest. 
  • Site Management. Review whether site management would be a more appropriate and proportionate response to risk of impact than the pure reliance on SANGs to divert recreation away. Or some combination of the two.
  • Create SANGs up front. Can the government forward fund some new SANGs for towns that want to build housing? This must include upgrades to existing spaces. Spending could be largely recovered through developer contributions over time. 
  • Brownfield vs greenfield. Following on from a rapid review, could there be a direction stating that brownfield and infill sites are exempt or partially exempt from SANG contributions, providing that they have low levels of parking and / or have parks and or walking routes nearby. (Assuming that the critical review mentioned above discovers that people are less likely to drive to make use of a SAC if they do not own a car and cannot park by their homes.)