Public Statement on NHDC local plan SSSI Mitigation


Public statement & email to councillors from the statutory managers of Therfield Heath and Greens.

7th November 2022

Dear Councillors

We are invested in NHDC having a Local Plan and seek to maximise the protection of public open green space. In the current year we have spent more than 12% of income and significant volunteer effort protecting from encroachment, trespass and unwelcome development across the spaces we manage.

As statutory managers of the majority of the publicly accessible parts of Therfield Heath SSSI the Conservators and our Head of Conservation welcomed being part of the process to develop the mitigations.

However, we do not feel that the strategy document, and the collection of disparate actions it outlines, is fit for purpose. What is missing is any sense of how the proposed mitigation actions (in the tables at the end) achieve the overall goal; mitigation of recreational impact caused by short term and future development. We believe that the effect of the proposals should be quantified and there are no measures of success or indicators of progress. This is fundamental to any strategy and funding should be set aside to monitor and evaluate progress (as is encouraged by National Lottery/Natural England funding). The need for appropriate monitoring is included Statement of Common Ground between NHDC and NE signed in November Microsoft Word – NHDC SoCG Nov 2017 – Natural England November 2017 (V7).docx (

As the Conservators and Natural England (NE) have consistently said the biggest single mitigation to increased recreational pressure caused by additional housing is to provide alternative recreation site(s) that can share the load. The Statement of Common Ground “acknowledged that there are likely to be significant negative effects on the SSSI due to recreational pressures”. A strategy that does not face this reality, but instead calls for “access management”, contrary to the Trust’s objective and the statutory purpose of the Conservators, both of which are focussed on the Heath being used by the neighbourhood, is fundamentally flawed. It is also contrary to NHDC policy which expects all residents of Royston and the neighbourhood to have access to a 100ha green space within 5km. Reducing recreational pressure on the SSSI contradicts the council’s policy unless another 100ha space is to become available?

The Heath is a very high-quality site for air, exercise and recreation as evidenced by daily visitor numbers and any alternative space needed to mitigate recreational impact will need to be of equal or greater amenity value to attract people away. Such space would necessarily provide very high-quality space for walking, dog walking, a parkrun, and pitch sports and other recreational pressures.

Perhaps most disappointing is that we feel so much is simply kicked down the road to the next local plan in 2031 or beyond. We appreciate the difficult fiscal climate but this strategy and indeed the council’s undertaking is not about future local plans, it is about measures that will quantifiably mitigate recreational pressures in this local plan, as new housing built between now and 2031. In the report you rule out Suitable Alternative Natural Green Space (SANG) and sport provision before 2031, preferring to suggest that a suite of reports will have a quantifiable effect to mitigate recreational pressure in the years to 2031. We do not feel reports alone will deliver mitigation and measures that do not deliver quantifiable mitigation in the lifetime of the current local plan should not be in the document.

Let me be clear, we do not wish to jeopardise the Adoption of the NHLP and remain ready to work collaboratively and constructively on the next phase.

Clare Swarbrick

Chair, Conservators Therfield Heath and Greens