From: John Edwards EI

To: Laura Howard

Cc: "Claire Gibbs"; Stuart Harrison; "Alistair Kirk"; "Isobel Girvan"
Subject: RE: Wisley SNCI
Date: 07 August 2018 15:01:00

Laura,
I am well thanks and hope you are too. Thanks for your email and I understand the
difficulty you face together with the very tight timescale. I would like to discuss this with
Alistair before I respond but I will ensure I meet your timescale of early next week or
before.
Kind regards,
John
John Edwards, C.Env, MCIEEM
Natural Environment & Assessment Team Manager
Surrey County Council

From: Laura Howard

Sent: 07 August 2018 10:50
To: John Edwards EI
Cc: 'Claire Gibbs' Stuart Harrison
'Alistair Kirk' Isobel
Girvan'
Subject: RE: Wisley SNCI
Importance: High
Dear John,
I hope you are well.
Just to update you on the below – we went back to the Inspector with the attached note trying
to argue what you had stated below. However he has come back with the following:
I have considered the comments of the Council and the Surrey Wildlife Trust,
but it is illogical to retain such a designation over the developable area of
the allocation. Such a designation would have the effect of applying the
need test contained within Policy ID4(6) to development proposals at the
planning application stage, which would be inappropriate for a site allocated
for development in a local plan. The SNCI area will therefore have to be
removed from the developable part of the site, and references to it will have
to be taken out of the “Description”. Instead, I recommend that the Council
consider a main modification to Policy A35 to deal with biodiversity
mitigation and compensation on the site.
He is therefore not accepted the argument and wishes to see the developable area of the
allocation not designated as SNCI. We understand the rationale for recommending the whole
area albeit the survey report itself did acknowledge that the SNCI value was concentrated in a
smaller number of areas. We do not wish to lose the whole area and would wish to see these
higher value areas protected. Whilst you did not agree with EPM’s approach, in light of the
Inspector’s direction – could you reconsider the area that they recommended? If these are
indeed the higher value areas (or indeed you wish to expand these slightly so that they more
accurately reflect the area that should not be developed) then this appears to be the best
solution. Clearly the area of land protected as SNCI cannot be so great as to preclude the overall
development of the site for 2000 units.
We are unfortunately under very tight time restrictions given our committee process and
consultation in September so would need to have a revised area by early next week. We are of
course happy to meet if that helps.
Kind regards, Laura
From: John Edwards EI
July 2018 13:15
To: Laura Howard
Cc: 'Claire Gibbs'; Stuart Harrison; 'Alistair Kirk'; 'Isobel Girvan'
Subject: RE: Wisley SNCI
Laura,
I hope all is well with you.
I apologise for not responding sooner as I was away and Alistair and I have only just
had a chance to speak this afternoon. In view of our conversation I don’t think there is a
need to involve the other members of the Surrey Local Sites Partnership at this stage.
Forgive me if I have missed anything in the emails I have worked through but from my
understanding the issues revolves around the SNCI Boundary, incidentally it is Site of
Nature Conservation Importance not Interest,( see attached map) and the Housing
Allocation Boundary and the view of the inspector that these are incompatible where
they coincide. When the Surrey Local Sites Partnership (SLSP) met on March 29th
2017, they considered all the ecological information put before them including the
surveys by EPM. EPM presented evidence that supported a smaller SNCI from the
SLSP to support their client and on this point the SLSP does not agree with EPM. I am
not aware of any new ecological evidence that suggests that the SNCI boundary needs
to be reconsidered but I am mindful that you have to consider the inspector’s views
about the ‘incompatibility of the SNCI as recommended by the SLSP and the Housing
Allocation boundary.
One option may be for you as the planning authority to draw the boundaries which you
consider would satisfy the inspector’s concern and we would respect your view. The
role of the SLSP is to provide recommendations based on ecological evidence for you
to take forward as appropriate. The SLSP has agreed a site boundary and
recommended it to you. Personally, I would be in breach of my profession’s code of
conduct to under value an identified ecological resource because there was a potential
conflicting land use and I do not consider it appropriate for the SLSP to redraw the
boundary.
The other option may be for you to retain the two boundaries as there are now and
accept that most or part of the SNCI within the Housing Allocation boundary will be
impacted by a future development but by retaining the SNCI status it flags up there are
still features and species ecological importance that could be addressed as part of the
development through mitigation or compensation measures. Removing the SNCI status
would suggest these species and features are either no longer present or important
which is not the case.
For completeness, I have attached the minutes of the meeting of 29th March 2017
where Wisley SNCI was selected together with a map showing the recommended SNCI
boundary.
I would be grateful if you could let me know what you ultimately decide so that we can
record what you consider to be your preferred approach. I and my colleagues will
respect your decision but please let me know if I can help further.
Kind regards,
John
John Edwards, C.Env, MCIEEM
Natural Environment & Assessment Team Manager
Surrey County Council

From: Laura Howard

Sent: 19 July 2018 08:57
To: 'Alistair Kirk' ; 'Isobel Girvan'
John Edwards EI
Cc: 'Claire Gibbs' Stuart Harrison

Subject: RE: Wisley SNCI

Dear Alistair and John,
I wonder whether you could update me on whether you have had the chance to catch up on this
yet? Unfortunately our timescales for reverting mods to the plan to the inspector is quite tight.
Kind regards, Laura
From: Alistair Kirk
Sent: 11 July 2018 15:36
To: Laura Howard; Isobel Girvan; 'John Edwards EI'
Cc: Claire Gibbs; Stuart Harrison
Subject: RE: Wisley SNCI
Hi Laura
Ah, I see. Do you have a map which show the SNCI as reselected by the LSP and land allocation in
context (or if not, the allocation as obviously we have the SNCI here)?
Regards
Alistair
***********************************************************************
Alistair Kirk
Manager
Surrey Biodiversity Information Centre

Twitter:- @surreybic
Report your wildlife sightings through our online recording pages: www.surreybic.org.uk
From: Laura Howard
Sent: 11 July 2018 15:32
To: Alistair Kirk; Isobel Girvan; 'John Edwards EI'
Cc: Claire Gibbs; Stuart Harrison
Subject: RE: Wisley SNCI
Dear Alistair,
Thank you for your quick reply. If you could catch up with John when he gets back that would be
great. I will await contact from one of you – I note from John’s out of office he is back on
Monday.
I’m afraid there is no written comment – it was given to us verbally during the session. There is
likely to be some to-ing and fro-ing between ourselves and him in relation to the mods as he will
undoubtedly have comments on the draft mods we prepare. His rationale was that it is not
possible to reconcile the wider SNCI with the allocation.
Kind regards, Laura
From: Alistair Kirk
Sent: 11 July 2018 15:10
To: Laura Howard; Isobel Girvan; 'John Edwards EI'
Cc: Claire Gibbs; Stuart Harrison
Subject: RE: Wisley SNCI
Importance: High
Hi Laura
Thanks for this. In terms of timescale, I know John is currently away on annual leave and as Chair
of the Local Sites Partnership he will need to be involved. Whether we also need to run this
decision past the full LSP (which technically as per the LSPs Terms of Reference we should do),
I’m not sure however I will hope to talk to him on his return at which point either he or I will get
back to you with either a decision or a timescale in which we’ll be able to get back to you.
Would it be possible to see a copy of the Inspectors comments, particularly with regards to the
SNCI and its boundaries and his reasons for recommending a change.
Regards
Alistair
***********************************************************************
Alistair Kirk
Manager
Surrey Biodiversity Information Centre

Twitter:- @surreybic
Report your wildlife sightings through our online recording pages: www.surreybic.org.uk
From: Laura Howard
Sent: 11 July 2018 14:58
To: Isobel Girvan; Alistair Kirk; 'John Edwards EI'
Cc: Claire Gibbs; Stuart Harrison
Subject: Wisley SNCI
Importance: High
Dear all,
I hope you are all well. We have just completed 4 weeks of hearing sessions examining the
soundness of our new Local Plan. As part of this process the Inspector has found our plan to be
sound subject to a number of main modifications which we will need to draft and consult upon
in September prior to being hopefully in a position to adopt the new plan.
The Inspector held a hearing session on the Wisley Airfield allocation. In case you have not heard
the appeal was dismissed however our Inspector found that the site allocation was sound and
that the reasons for refusal did not undermine the principle of development in this location. As
you are aware their ecological consultants EPR did not consider it appropriate to designate the
whole site as SNCI given that the areas of ecological value were located in a smaller number of
specific locations. Whilst we do not consider that the allocation and SNCI designation are
incompatible, the Inspector has agreed with them and said the SNCI should be amended. I can
however see the merits of it as it provides greater clarity regarding which parts of the site have
ecological value and should therefore be protected versus those parts of the site which have
limited value.
I’m reattaching the EPR report which, at Map 1, sets out those areas which they recommend
form an SNCI.
We need to amend the current SNCI and, if these areas do represent the areas which warrant
protection, I am inclined to propose a smaller area rather than delete the entire designation.
I’m afraid our timescales are very tight and we would like to finalise our draft modifications to
send to him quite soon. Would you be able to review the attached and provide your comments
by early next week?
Kind regards, Laura
Laura Howard
Principal Planning Officer (Policy)
Planning Services

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