Object

Representation ID: 11164

Received: 12/12/2020

Respondent: Natural England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

RECOMMENDATION
Notwithstanding the support shown for the policy above, NE would make the following recommendation:
Soils
Natural England could find no reference to the importance of soils in the SLP.
Soil is a finite resource, and fulfils many roles that are beneficial to society. As a component of the natural environment, it is important soils are protected and used sustainably.
The plan should recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process.
Soils of high environmental value (e.g. wetland and carbon stores such as peatland) should also be considered as part of ecological connectivity.
Advise that Plan policies refer to the Defra Code of practice for the sustainable use of soils on construction sites.
BMV land is Grades 1, 2 and 3a in the Agricultural Land Classification.
The plan should recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of BMV land. Avoiding loss of BMV land is the priority as mitigation is rarely possible. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services. In the longer term, protection of BMV land may also reduce pressure for intensification of other land.