Our clients in the southern home counties may have noted that August saw the first revision to Natural England’s ‘Guidelines for the Creation of Suitable Alternative Natural Greenspace (SANG)’ for the Thames Basin Heaths SPA since their original publication in 2008.
Around that time the 13 Local Planning Authorities surrounding the SPA, together with the South East England Partnership Board and Natural England, established the Thames Basin Heaths Joint Strategic Partnership (JSP). The JSP agreed a Delivery Framework to enable the development of housing in the vicinity of the SPA without resulting damaging levels of recreational pressure at the SPA. The Delivery Framework is based on (a) the provision of SANG and (b) funding of Strategic Access Management and Monitoring (SAMM). The Delivery Framework, including Natural England’s guidelines for SANG creation, has since been transposed into Supplementary Planning Documents and reflected in adopted development plan policies.
The updated guidelines bring some useful clarifications and subtle updates to the SANG quality design criteria, based on the experiences amassed over the last decade or so. However perhaps of greater pertinence is confirmation on Natural England’s position with regard to the relationship between Biodiversity Net Gain (BNG) and the creation of SANG. Net gains on SANG are only attributable to habitat creation or enhancement that is demonstrably additional, over and above the minimum requirements of the SANG. For the purposes of the BNG calculation, the baseline value of the proposed SANG is to be the site with all requirements to achieve a functional SANG already incorporated. Only further enhancements, which would not have taken place in the absence of the BNG funding, then count towards BNG. While these new guidelines relate specifically to the Thames Basin Heaths, Natural England will almost certainly mirror this stance when it comes to BNG and other mitigation projects.