Publication: Pre-Submission Gloucester City Plan

Pre-Submission City Plan

Policy E8: Development affecting Cotswold Beechwoods Special Area of Conservation


Development will not be permitted where it would be likely to lead directly or indirectly to an adverse effect upon the integrity of the Cotswold Beechwoods Special Area of Conservation (SAC) (alone or in combination), and the effects cannot be mitigated.

In order to retain the integrity of the SAC, and to provide protection from recreational pressure, all development that results in a net increase in dwellings will be subject to Habitats Regulations Assessment for likely significant effects. Any development that has the potential to lead to an increase in recreational pressure on the SAC will be required to identify any potential adverse effects and provide appropriate mitigation. This will be in accordance with the SAC mitigation and implementation strategy or through a Habitats Regulations Assessment.

Development which is likely to generate road traffic emissions to air, which are capable of affecting the SAC, will be screened against the Habitats Regulations Assessment Framework in line with Natural England's guidance 'Natural England's approach to advising competent authorities on the assessment of road traffic emissions under the Habitats Regulations (NEA001)', or any future iteration.

3.5.49 There is planned growth in housing development in districts surrounding the Cotswold Beechwoods Special Area of Conservation (SAC), which could lead to an increased level of recreational pressure resulting from people visiting the site. Due to the extent of the Beechwoods and the fact that visitors travel a significant distance to visit the site, a Gloucestershire wide approach is required in order to successfully mitigate and likely adverse impacts.

3.5.50 The Gloucestershire planning authorities commissioned a visitor survey, carried out over the summer of 2019, in order to better understand the recreational pressures on the SAC. The survey results will form part of the evidence base leading to the production of a mitigation strategy. This will identify what measures need to be put in place to mitigate the impact of new development and ensure the protection of the site. The evidence may also assist in determining when a development may be likely to have an adverse impact depending on factors such as distance from the SAC. The mitigation strategy is expected to be available in early 2020.

3.5.51 In order to comply with the Habitats Regulations 2017, and specifically to address uncertainties regarding the effects of recreation pressure from new housing in Gloucester City, it is important to provide a policy approach to ensure effective mitigation. The above policy ensures this by requiring that, where residential development is likely to have an adverse impact on the SAC through increased recreational pressure, these impacts are mitigated. Mitigation should be undertaken as per the SAC mitigation strategy or through a bespoke Habitats Regulations Assessment for the development.

3.5.52 Appropriate mitigation measures may include:

  • On-site measures, including for example the provision of open and green space where this can be accommodated.
  • Where this is not possible, financial contributions towards off-site measures such as green infrastructure, habitat management, access management, residential travel plans, visitor infrastructure and publicity and awareness raising.

3.5.53 Any mitigation measures should take account of and integrate with:

  • Adopted JCS Policy INF3: Green Infrastructure and the associated JCS Green Infrastructure Strategy.
  • City Plan Policies E2: Biodiversity & Geodiversity, E3: Nature Recovery Areas and E5: Green Infrastructure / Buildings with Nature.    

3.5.54 The Cotswold Beechwoods SAC lies within 200m of the A46. The 'air pollution information service' (APIS) website ( indicates that the SAC currently exceeds its critical loads and levels for nutrient nitrogen. Natural England have therefore advised that development proposals that may generate additional traffic along this route should take account of Guidance Note NEA001. This will ensure that the most up-to-date information in line with the Habitats Regulations 2017 are referenced and that the information is consistent with the Wealden case law dealing with in combination effects.