Cheltenham Plan Pre-Submission consultation

Pre-Submission Cheltenham Plan

10 Biodiversity and Geodiversity


10.1 Although often perceived as an essentially man-made environment, the town of Cheltenham contains many habitats that harbour a rich array of wildlife. Ponds, railway cuttings, hedges and verges, small copses, parks, cemeteries, school playing fields, allotments and even old buildings all host a wealth of species ranging from larger mammals like foxes and badgers to wild flowers and butterflies.

10.2 The rural areas of the Borough also contain some very significant habitats; the limestone grassland flora of Leckhampton Hill, which is rich in plant and insect species, and the ancient woodlands of the Cotswold escarpment being the most prominent features. Most areas of natural vegetation in the countryside support a great diversity of wildlife.

10.3 Many wildlife habitats are under severe threat from development and agricultural pressures; even a minor environmental change not requiring planning permission may radically alter the ecological balance and lead to the loss of valuable species. At the same time, wildlife areas need to be managed to ensure that certain invasive species do not destroy more sensitive flora and fauna; for example sycamores and gorse can rapidly overrun a habitat and destroy the ecosystem’s ability to support a diversity of wildlife.

10.4 Part 3 of the Countryside and Rights of Way Act 2000 (the CROW Act) gives protection to wildlife and natural features by making provision for the conservation of biological diversity, and by improving protection for Sites of Special Scientific Interest (SSSIs) in England and Wales together with the enforcement of wildlife legislation.

10.5 The Joint Core Strategy (JCS) recognises the need to protect and conserve wildlife and habitats. JCS Policy SD9 highlights the importance of protecting sites from development that would have a harmful effect on their nature conservation and biodiversity interests. This policy takes into account all sites with conservation interest, including international, national, and locally-designated sites as well as non-designated sites and assets.

10.6 One of the essential tools in helping to inform planning decisions on biodiversity is the Gloucestershire Nature Map. This is a comprehensive resource compiled by the Gloucestershire Biodiversity Partnership as part of the UK Biodiversity Framework (2012) and represents an assessment of biodiversity opportunities for the county. The identified tracts of land, called Strategic Nature Areas (SNAs), show the prioritised areas for the maintenance and expansion (through restoration and/or re-creation) of Priority Habitat (Section 41 of the NERC Act 2006) at a landscape scale across Gloucestershire. This biodiversity enhancement map is a spatial representation of the county’s targets for Priority Habitat and embodies a 50-year vision which will allow biodiversity to adapt to climate change and help secure healthy functioning ecosystems.

10.7 The Gloucestershire Nature Map points to the areas of greatest potential for restoration and creation of Priority Habitat with a view to establishing ecological networks that support healthy functioning ecosystems. The Map is based on the inclusion of existing areas of identified wildlife value but does not include all designated or local sites of importance for wildlife, or landscape or built features of importance for flora and fauna, or priority habitat in the county. SNA’s also do not include all the areas where priority habitat could exist. They simply identify where there is the best opportunity to build coherent and resilient ecological networks without implying that areas outside these designations have no biodiversity or that biodiversity should not be conserved and enhanced there.


10.8 The following features comprise the most significant elements of Cheltenham’s biodiversity resource:



10.9 SSSIs are designated by Natural England because of their flora, fauna, geological or physiographical features, and are regarded by the National Planning Policy Framework (NPPF) as being of national importance. There is one such site within the Borough at Charlton Kings Common and Leckhampton Hill. Natural England must be consulted over any planning applications for development within or which may indirectly affect the SSSI.

10.10 The Council, as landowner, is committed to the protection of this area and will give priority in its management to nature conservation interests. This is specifically addressed within the management plan for Charlton Kings Common and Leckhampton Hill.


10.11 The Countryside and Rights of Way Act 2000 and the Conservation (Natural Habitats &c.) Regulations 1994 legally protect certain species and their habitats. Other species are protected under their own legislation, for example the protection of Badgers Act 1992. Of particular relevance to Cheltenham are the habitats of the barn owl, badger and bat. This list is not exhaustive and other habitats may also be relevant.

10.12 It is recognised that many legally protected species may be found outside designated sites and consequently require special attention wherever they exist. Where protected species are known or suspected to exist the applicant will be expected to supply information detailing how the development will affect the protected species and what measures will be undertaken to mitigate the impact of the development on the species.

10.13 In accordance with JCS Policy SD9, the presence of a protected species is a material consideration in the determination of a planning application. Where protected species are known or suspected to exist, applicants will be required, at the time of the application, to provide appropriate survey/mitigation information to determine the likely effect of the proposed development. The Borough Council will seek the advice of Natural England and Gloucestershire Wildlife Trust (GWT) to determine whether the requirements of legally protected species and their habitat have been adequately taken into account.



10.14 In 1990 the RIGS programme was established following recognition of the need to record and conserve important geological/geomorphological sites. RIGS in Gloucestershire were identified and researched by Gloucestershire Geoconservation and are now overseen by the Gloucester Geology Trust. RIGS sites have limited legal status, but are treated in much the same way as Key Wildlife Sites, and are considered important for their aesthetic, cultural, amenity, historical and wildlife value, as well as providing opportunities for education and research. There are two RIGS in Cheltenham Borough, at Little Herberts Railway Cutting and at Charlton Kings Common.

10.15 Though there is currently no Geodiversity Action Plan for Gloucestershire, it is likely that one will be prepared during of the lifetime of the Plan and that this will help inform decision-making in these areas.


10.16 GWT has compiled a schedule of 850 key wildlife sites. These sites are designated for their nature conservation value, which is of countywide significance. Cheltenham Borough contains six of these. Such sites are considered to contain features of countywide importance, either through their rarity or the fact that they are typical to Gloucestershire and seldom found elsewhere.

10.17 Key wildlife sites in Cheltenham Borough are:

  • Gloucestershire Wildlife Trust Reserve at the Kingham Line
  • Ravensgate Hill (Wistley Hill) - consisting of steep unimproved, limestone grassland and scree
  • 5.5 ha of ancient woodland at Timbercombe
  • 3.6 ha of species-rich ridge and furrow meadow at Ashgrove Farm
  • 5 ha of ancient woodland at Glenfall Wood
  • unimproved grassland at Fiddlers Green Lane


10.18 Local Nature Reserves (LNR) are designated and managed by local authorities. They are places with wildlife or geological features that are of special interest locally and which provide opportunities for study in natural surroundings. Any site may qualify for LNR designation, providing that it is capable of being managed by the local authority, i.e. is in their ownership, leased from the landowner or managed under agreement. Prior to declaration, Natural England must be consulted and can offer discretionary grant aid and expert advice. Local interest groups such as the GWT should also be brought into the designation process. There are currently two designated LNRs at Griffiths Avenue and Pilley Bridge; the Council, in conjunction with Natural England and local interest groups will consider identifying and designating further local nature reserves during the course of the plan period.


10.19 Important wildlife areas, which are not necessarily capable of being managed by local authorities, can also be largely safeguarded from future development. Local authorities can designate non-statutory nature reserves with the agreement of the land owners as evidence of their intent to maintain the wildlife importance of the area, particularly in urban areas, where small, undeveloped plots of land or large gardens provide a haven for wildlife and are often more accessible to the people who live in these areas than is much of the countryside.

10.20 Provided there is sufficient local interest, non-statutory designation can ensure protection of sites at minimal cost. The Council will, in conjunction with local interest groups, consider identifying and designating non-statutory nature reserves with the agreement of landowners during the course of the plan period.

10.21 In addition to designating land as non-statutory nature reserves, the Council may also apply for Green Flag and Green Pennant recognition. Both these schemes recognise the importance of accessible green spaces and green heritage managed for recreation and nature conservation purposes. Cheltenham has been entering parks into the Green Flag Awards since 2005 and has consistently won flags for Naunton Park, Hatherley Park, Montpellier Gardens, Springfields Park and Pittville Park.


10.22 In addition to the protection and enhancement of areas of particular wildlife and geological significance, the Council is concerned to ensure that other habitats and features are conserved and improved. The Council recognises the contribution that small landscape features, such as shrubs and thickets, ponds, meadows and copses can make to the ecology and biodiversity of an area, especially where such features are linked.

10.23 Continuous green areas, such as large linear open spaces, hedgerows, tree-lined roadside verges or banks, disused railway lines or watercourses, and green lanes have greater ecological value than isolated spaces. Such ‘green corridors’ provide connected linkages for wildlife through the developed areas of the town or the countryside, as well as being important sites in their own right.


10.24 The water-based environment comprises rivers, streams, lakes, ponds and groundwater. Protecting and enhancing the quality of the water environment is important for amenity, recreation and wildlife and is the responsibility of the Environment Agency. The Agency has particular responsibilities for the conservation of landscape, flora, fauna and geological features which are dependent on the aquatic environment and also has a duty to prevent pollution of the water-based environment.

10.25 The Borough Council will continue to work alongside the Environment Agency in meeting its conservation objectives and will require consideration of the impact of development upon the ecology and wildlife potential of the water-based environment.

10.26 It will also seek to promote and enhance the natural water system in the Borough by making decisions that:

  • conserve existing areas of value within river corridors;
  • assist in the restoration and enhancement of watercourses for the purposes of conservation and amenity;
  • encourage developers to fully integrate watercourses into their developments;
  • encourage developers to apply sustainable drainage principles when designing land drainage systems.


10.27 The Council will seek to protect all species and habitats listed in the UK Biodiversity Framework and Gloucestershire Nature Map from development that would harm those features in accord with legislative requirements and Policy SD9 of the JCS. The Council will normally require a survey of biodiversity features to be submitted with planning applications which will need to be accompanied by an account of appropriate measures to help safeguard such features during construction and thereafter.

10.28 Where there is conflict between the development proposal and the need to protect those natural features identified, the Council will weigh the relative merits of the development proposal and the value of the natural feature or habitat under threat and, in any case, will seek advice from Natural England, the Gloucestershire Wildlife Trust, or other professional bodies as necessary and appropriate.

10.29 A holistic approach will be adopted in the assessment of proposals, which takes into account not only the natural characteristics of each individual site but also the wider context of that site and how it relates to surrounding biodiversity networks and ecosystems. A key consideration will be the cumulative effect of allowing one development after another and the potential damage that can arise through piecemeal erosion of biodiversity interests.