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Habitats Regulations Assessment (HRA)

Mitigation Strategies

Habitats Regulations Assessment (HRA) refers to the several distinct stages of Assessment which must be undertaken in accordance with the Conservation of Habitats and Species Regulations 2017 (as amended) and the Conservation of Offshore Marine Habitats and Species Regulations 2017 (as amended) to determine if a plan or project may affect the protected features of a habitats site before deciding whether to undertake, permit or authorise it. European Sites and European Offshore Marine Sites identified under these regulations are now referred to as ‘habitats sites’ in the National Planning Policy Framework and accompanying planning policy guidance.

'Habitats Sites' consist of Special Areas of Conservation (SACs), Special Protection Areas (SPAs) as well as the globally important wetlands known as Ramsar sites. The network of these internationally recognised sites are of exceptional importance in respect of rare, endangered or vulnerable natural habitats and species within Europe and beyond.

Current Identified Special Area of Conservation (SAC) Mitigation Rates:


*£100.00 administration fee to be introduced to applications submitted after 1 January 2024



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Habitats site in Stroud District and within 15km of Gloucestershire


  • Rodborough Common SAC - (Stroud)
  • Dixton Wood SAC - (Tewkesbury)
  • Wye Valley and Forest of Dean Bat Sites SAC - (Forest of Dean, Monmouthshire)
  • River Wye SAC - (Forest of Dean, Monmouthshire, Herefordshire, Powys)
  • Wye Valley Woodlands SAC - (Forest of Dean, Monmouthshire, Herefordshire)
  • North Meadow and Clattinger Farm SAC - (Wiltshire)
  • Cotswold Beechwoods SAC - (Cotswold)
  • Bredon Hill SAC - (Worcestershire)
  • Walmore Common SPA - (Tewkesbury)
  • Severn Estuary SPA - (Stroud, Forest of Dean)

All plans and projects (including planning applications) require consideration of whether the plan or project is likely to have significant effects on habitats sites. This consideration –referred to as the ‘Habitats Regulations Assessment screening’ – should take into account the potential effects both of the plan/project itself and in combination with other plans or projects. Where the potential for likely significant effects cannot be excluded, the Council must make an appropriate assessment of the implications of the plan or project for that site, in view the site’s conservation objectives. The Council may agree to the plan or project only after having ruled out adverse effects on the integrity of the habitats site. Where it cannot be concluded that there will be no adverse effects on a site’s integrity, there is a need to consider mitigation. The Local Plan Review Habitats Regulations Assessment (HRA) 2021 identified where significant effects could not be excluded and the potential impact pathways.

As a consequence of HRA work including visitor surveys, mitigation measures were identified. The following strategies are intended to avoid or reduce any direct adverse effects that may be caused by a plan or project and seeks to ensure no adverse effect on the integrity of habitats site(s).

Guidance on the use of and completion of a s.106 agreement are provided in the habitats site(s) overview that follow below. In addition template agreements to be completed by the site developer are provided. Larger strategic scale developments will usually be expected to address any mitigation matters within their proposed development site.


Rodborough Common Special Area of Conservation (SAC)


Rodborough Common SAC 3.9km Zone of Influence Map 2022


Rodborough Common Special Area of Conservation (SAC) is a 109ha site just south of Stroud Town. The Habitats Regulations Assessment (HRA) of the emerging Stroud District Local Plan (Footprint Ecology, 2021), identified that recreational pressure has the potential to impact upon the qualifying features for which the Rodborough was designated.  A visitor survey was completed in 2019 which identified visitors are on site for a relatively short time, but they visit frequently and live very locally to the site. The data would suggest an average visitor makes 180 visits to the site per year, visiting for 60 minutes and lives within 3.9 km (75% of all interviewees, across all visitor types), most of whom are dog walking.

The 2022 mitigation strategy sets out a strategic approach to mitigate recreation impacts, associated with new housing growth, on Rodborough Common Special Area of Conservation (SAC). The overall objective is to provide a framework under which applications for development likely to have a significant effect because of an increase in recreational use can be permitted, with measures in place to ensure that adverse effects on the integrity of the SAC, alone or in-combination can be ruled out. This enables development, while ensuring sufficient protection in place for the SAC.

The zone of influence from this habitat site is 3.9km and in-line with visitor data (Panter & Caals, 2019).

The Council will welcome applications for funding specific projects from relevant partners that fit with the aims of the strategy.  This provides the potential for parish and Town Councils, other organisations/bodies or community groups with an interest in the Common to promote projects to give the strategy flexibility and ability to adapt to changing circumstances or new opportunities. A S106  proforma templates are available from the Council for any such applications and the oversight group would have the task of recommending to the Council funding for any such projects.  There is an administrative fee for s106 agreements.

Housing growth within the Commons catchment is anticipated to be around 600 new dwellings over the life of the Plan.  This gives a mitigation cost per dwelling of £994. This figure is prior to the application of any administration fee. Per dwelling costs are likely to be adjusted annually in line with inflation.

The Mitigation Strategy was adopted by Environment Committee on 4th October 2022


Cotswolds Beechwoods Special Area of Conservation (SAC)

Cotswold Beechwoods Zone of Influence 2022 (Cross Boundary)

Cotswold Beechwoods SAC Zone of Influence Map 2022 (Cross Boundary)


The Cotswold Beechwoods Special Area of Conservation (SAC) is a 590ha site located between the settlements of Gloucester, Cheltenham, Cirencester and Stroud, Gloucestershire. The site is designated for the internationally important beech woodlands, and to a lesser extent for calcareous grassland communities.  The Cotswold Beechwoods represent one of the most westerly extensive blocks of beech forest that are floristically rich compared to other similar sites. The Beechwoods are mostly high forest, and some areas of remnant beech coppice. Wetter parts of the site are also of interest, with abundant mosses and liverworts which are important conditions for several nationally rare terrestrial snails - all species of ancient woodlands. Furthermore, open areas and woodland margins are important areas for butterflies such as the Silver-washed Fritillary, White Admiral and White-letter Hairstreak. The unimproved limestone grassland of the SAC consists of areas of glades and rides within the woodland, the largest area being the cheese-rolling slope at Coopers Hill.

The Council has worked in partnership with relevant Councils in Gloucestershire to provide a framework under which applications for development likely to have a significant effect on the Cotswold Beechwoods SAC can be permitted, with measures in place to ensure that adverse effects on the integrity of the SAC can be ruled out. This enables development, while ensuring sufficient protection in place for the SAC. The strategy applies to larger developments, which may affect the integrity of these sites alone, and smaller developments where the cumulative effects may be the critical factor.

Within the zone of influence shown on the map, all new residential growth will be expected to provide mitigation for recreational pressure. Mitigation will involve Strategic Access Management and Monitoring (‘SAMM’), which relate to managing access and engaging with visitors at the SAC.  These measures involve increased staffing, signage, interpretation etc.  Alongside SAMM, there is a need to deflect access away from the SAC and provide alternative countryside destinations for people to visit for recreation. Suitable Natural Alternative Greenspace (‘SANG’) or other infrastructure projects, such as improvements to existing greenspace sites are therefore necessary.  These can be provided directly by developers (according to guidelines set out in the adopted strategy) as part of a development or alternatively, where such bespoke SANG is not possible, through contributions. 

The strategy applies to a zone of influence of 15.4km from the Cotswold Beechwoods, drawn from visitor survey (2019) information, with the boundary of the zone adjusted slightly to reflect the local geography, accessibility, and local authority boundaries.  The zone therefore encompasses all of Cheltenham and Gloucester administrative boundaries and part of Cotswold, Stroud and Tewkesbury. Counts recorded 770 people (including 201 minors and 43 cyclists) and  213 dogs – with an average group size was 2.1 people per group, of which 0.5 were minors, 0.1 on a bicycle and with 0.6 dogs per group; Roughly 4.3 times people were seen on weekends, than on weekdays. A total of 139 interviews were conducted, with 13% on holiday, 2% staying with friends or family locally and 85% of interviewees on a short visit directly from home. The main activities were walking (without a dog) (45% of interviewees) and dog walking (40%). Most interviewees (67%) had arrived at the survey location by car or on foot (28%).

Impacts from recreation take a wide range of forms, including:

  • Damage: encompassing trampling and vegetation wear, soil compaction and erosion, trampling can also cause direct mortality for some fauna;
  • Contamination: including nutrient enrichment (e.g. dog fouling), litter, invasive species;
  • Fire: increased incidence and risk;
  • Other: all other impacts, including activities associated with site management, such as achieving appropriate grazing or harvesting regimes for example.

Other effects of human trampling include the widening of paths and path erosion. Horses, vehicles and bikes are likely to be more damaging than people on foot. There has been growing awareness of the threats to the Beechwoods from increased recreational use.  The combination of activities can also create tensions between different users and Stroud District Council have received complaints relating to off-road vehicles and other recreational users.  It was as a result of these growing concerns that Stroud District Council commissioned visitor survey work. LINK

Mitigation will consist of SAMM (Strategic Access Management and Monitoring) and SANG infrastructure projects.  These two approaches would be complementary to each other. SAMM measures at the Beechwoods are required to address recreation impacts and make the SAC more resilient to increased recreation.  SAMM would comprise: Dedicated staff; Signs and interpretation; Education & awareness raising; Measures to address contamination;  Parking and travel related measures; Monitoring.  Suitable Alternative Natural Greenspace (SANG) comprises greenspaces that are created or enhanced with the specific purpose of absorbing recreation pressure that would otherwise occur at European wildlife sites. SANG  projects will be secured through planning obligations (S106) Some projects will be expected to be delivered directly by developers through on-site provision. Where a contribution is collected, this will be at a standard rate of £673.00 per dwelling, (£193.00 SAMM and £480.00 SANG)

Flexibility is accommodated within the governance structure through the potential for relevant stakeholders and organisations to apply for funding for specific projects, allowing the potential for different mitigation measures to come forward.  A proforma for project bids, not explicitly set out in the mitigation strategy, will be made available for consideration and recommendation to the Director of Place by the Oversight Group.

The Mitigation Strategy was adopted by Environment Committee on 4th October 2022.


Severn Estuary Special Area of Conservation (SAC)

Severn Estuary SAC Zone of Influence 7.7km

Severn Estuary SAC Zone of Influence Map 2017


The Severn Estuary is one of the largest estuaries in Europe and is internationally important for the habitat and species the estuary supports. Saltmarsh fringes the coast backed by grazing marsh with freshwater ditches and occasional brackish ditches. The subtidal seabed is rock and gravel with subtidal sandbanks. The site also supports reefs of the tube forming worm Sabellaria alveolata.  The estuary's classic funnel shape, unique in the UK, is a factor causing the Severn to have one of the highest tidal ranges in the world. A consequence of the large tidal range is an extensive intertidal zone, one of the largest in the UK. The site qualifies as a Special Area of Conservation (SAC) for a range of coastal habitats and for three fish species. The Severn Estuary Special Protection Area (SPA) is classified for its waterbird assemblage and for a range of species that occur on passage/over winter including a range of both wildfowl and wader species. The Ramsar interest overlaps with the SAC and SPA features and includes the bird interest.

The bird populations associated with the estuary move widely and make use of a range of sites away from the estuary during the course of the winter. Waterbodies, wetlands and low-lying farmland within the can provide important feeding and roost sites which may vary in importance within a season and across years, depending on water-levels, food availability and a range of other factors. While such sites lie outside the SPA they are functionally linked in that they play a role in supporting the relevant bird interest. Key locations within the Vales are described by Palmer and Smart (2021) who identified 21 sites that held more than the equivalent of 1% of the SPA population of one or more species for 50% or more of months within one or more of three WeBS counting seasons. 

A new visitor survey report was therefore commissioned in 2022. It was recognised that while baseline levels of recreational pressure on the Estuary are relatively low, disturbance would still have a high impact and recreational use was likely to increase with new housing, employment and tourism. A likely significant effect on the conservation status of the SPA’s qualifying features could not be ruled out in the 2021 HRA. Whilst there is an established a mitigation strategy (Stroud District Council, 2017)  the Council recognise a review and update would be required. The Council are currently using 2022 visitor survey results to help inform the production of an updated mitigation strategy anticipated this winter. The new strategy will seek to address the cumulative effects of housing growth across a wide area, spanning multiple authorities in Gloucestershire.

Payment of this obligation is secured through agreed planning obligation S106.

The new Severn Estuary Mitigation Strategy is anticipated to be adopted early in 2024. At this time, this section of the website will be updated and new information published.

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