“ SANG ”

The acronym SANG stands for Suitable Alternative Natural Green Space. But what is this “natural green space” an “alternative” to? and what does “suitable” mean? There are many different ways of designating land, ordinary sounding words have legal definitions and it all seems rather complicated.

“The UK supports a wide variety of species and habitats, ranging from cold water coral reefs to saltmarshes and mountain summits. A key policy tool for conserving them all is the designation and management of protected sites - areas of land, inland water and the sea that have special legal protection to conserve important habitats and species.” (i) So, there are SPAs (Special Protection Areas) and SPCs (Special Areas of Conservation) The areas themselves are conserved and protected from development. Surrounding these Areas there are buffer zones in which development is constrained to prevent damage to the SPA/SPC itself.

In Woking, we are concerned with the Thames Basin Heaths Special Protection Areas. (ii) JNCC (iii) SWT The designated SPA areas will be conserved, eg Horsell Common. Note that SPA’s adjacent to Woking must also be taken into account, eg Wisley and Chobham Commons. Around the SPA sites there is a 400 metre buffer zone in which no development can take place. There is a further 5 kilometre buffer zone in which development may be approved, but only if the impact on the SPA can be “mitigated”. The impact being too many people, their activities, & domestic pets, disturbing/damaging the sensitive home of the Nightjar, Woodlark & Dartford Warbler in particular (iv) Map of Woking SPAs (v) WBC

Establishing a SANG is one method of mitigating damage to the SPA. A SANG has the objective of ensuring that an approved development “does not increase the pressure for public recreation on the sensitive SPA.” (xi) OSSNatural England has published standards for Accessible Natural Greenspace Standard (ANGSt) and guidelines for SANGS (vi) In Woking, 8 hectares (19.75 acres) of SANG per 1000 additional residents in the 5km buffer zone is to be provided. That’s not very much, about 10 football pitches. An alternative, arguably illogical, “mitigation” is that money is levied from the developer by the Council. This is called the Avoidance Strategy Tarriff (vii) The Woking Council Core Strategy Policy CS8 (page 58) (viii) contains the relevant detail on establishing SANG in the Borough, and states that “The Council will take a precautionary approach to the protection and conservation of the SPA”

Defining a SANG: Natural England, the UK government public body responsible for caring for England’s natural environment, defines a SANG in a twofold manner (vi). Firstly it must be “accessible greenspace”

“places that are available for the general public to use free of charge and without time restrictions (although some sites may be closed to the public overnight and there may be fees for parking a vehicle). The places are available to all, meaning that every reasonable effort is made to comply with the requirements under the Disability Discrimination Act (DDA 1995).” and... “An accessible place will also be known to the target users, including potential users who live within the site catchment area.”

Secondly it must be “natural greenspace”“Places where human control and activities are not intensive so that a feeling of naturalness is allowed to predominate”

What land can or can’t be designated SANG?To be “suitable” it is understood that the land must be “accessible greenspace” and “natural greenspace” by which it is understood it must be nearby the proposed development and fit Natural England’s definitions (see above)The SANG can either be new or improved existing greenspaces. This begs the question of what is considered as being an improvement - and for whom? or what? An improvement for humans may not be an improvement for the existing ecosystem of the proposed SANG. It is believed (check with the lawyers!) that land within the Green Belt can be designated SANG. Some places can not be designated SANG: The Open Spaces Society state (v) that Common Land, where people have existing access rights can not be designated as SANG. Similarly, land which itself is of importance for nature conservation can not be designated as SANG (eg SNCIs (Sites of Nature Conservation Importance).

It is hoped that readers will find this of interest and that it may at least provide a guide to further reading.

References:(i) http://jncc.defra.gov.uk/page-4 (ii) http://jncc.defra.gov.uk/page-2050(iii) http://www.surreywildlifetrust.org/what-we-do/sustainable-land-management/managing-heathland (iv)A map of Woking Special Protection Areas (SPA’s) was published as Figure 4 in the Woking Green Belt Review:http://www.woking.gov.uk/planning/policy/ldfresearch/greenbeltreview/greenbeltfigures/greenbeltfigure4(v) WBC: http://www.woking.gov.uk/planning/policy/ldf/tbhspa(vi) Natural England: “Nature Nearby”: http://publications.naturalengland.org.uk/file/95015(vii) Woking Borough Council: http://www.woking.gov.uk/planning/policy/ldf/tbhspa#avoidance_strategy_tariff_april_2015_update (viii) WBC: http://www.woking2027.info/corestrategy/adoptedcorestrategy(ix) Open Spaces Society: http://www.oss.org.uk/we-fight-threat-to-guildfords-unique-commons/