Draft Local Plan Review
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Draft Local Plan Review
Q1. Do you agree that we've identified the right challenges facing the Borough? If not why not? Are there any additional challenges that should be addressed?
Representation ID: 1734
Received: 17/02/2017
Respondent: Natural England
Natural England broadly agrees with the challenges your authority has identified as facing Solihull Metropolitan Borough Council.
Natural England broadly agrees with the challenges your authority has identified as facing Solihull Metropolitan Borough Council.
No
Draft Local Plan Review
Q3. Do you agree with the spatial strategy we have set out? If not why not, and what alternative would you suggest?
Representation ID: 1744
Received: 17/02/2017
Respondent: Natural England
The spatial strategy should take a strategic approach, identifying all natural environment objectives as well as opportunities and areas for enhancement or strategic projects. Ideally there should be linkages with BAPS, NIAs, LNPs, NCAs, and Green infrastructure strategies The strategy should be additional to positive policies on, landscape, biodiversity (including geodiversity), green infrastructure and access to nature.
Growth opportunities should avoid:
designated sites/priority habitats
protected landscapes
Best and Most Versatile (BMV) Agricultural Land
areas at risk of flooding
brownfield sites of high environmental value
Plans should allocate land with the least environmental or amenity value.
The spatial strategy should take a strategic approach, identifying all natural environment objectives as well as opportunities and areas for enhancement or strategic projects. Ideally there should be linkages with BAPS, NIAs, LNPs, NCAs, and Green infrastructure strategies The strategy should be additional to positive policies on, landscape, biodiversity (including geodiversity), green infrastructure and access to nature.
Growth opportunities should avoid:
designated sites/priority habitats
protected landscapes
Best and Most Versatile (BMV) Agricultural Land
areas at risk of flooding
brownfield sites of high environmental value
Plans should allocate land with the least environmental or amenity value.
Yes
Draft Local Plan Review
Q9. Do you agree with Policy P3? If not why not, and what alternative would you suggest?
Representation ID: 1745
Received: 17/02/2017
Respondent: Natural England
Natural England broadly supports Policy P3, in particularly when considering the criteria that there is no significant harm to the local environment, including landscape quality and character.
Your authority should consider policy wording to add that where possible enhancement of the local environment should be taken into consideration.
Natural England broadly supports Policy P3, in particularly when considering the criteria that there is no significant harm to the local environment, including landscape quality and character.
Your authority should consider policy wording to add that where possible enhancement of the local environment should be taken into consideration.
Yes
Draft Local Plan Review
Q10. Do you believe the right scale and location of development has been identified? If not why not?
Representation ID: 1746
Received: 17/02/2017
Respondent: Natural England
In considering the location of development your authority should utilise our SSSI Impact Risk Zones which are a GIS dataset designed to be used during the planning application validation process to help local planning authorities decide when to consult Natural England on developments likely to affect a SSSI. The dataset and user guidance can be accessed from the data.gov.uk website.
Other considerations include environmental constraints such as:
Do they avoid:
designated sites/priority habitats
protected landscapes
Best and Most Versatile (BMV) Agricultural Land
areas at risk of flooding
brownfield sites of high environmental value
In considering the location of development your authority should utilise our SSSI Impact Risk Zones which are a GIS dataset designed to be used during the planning application validation process to help local planning authorities decide when to consult Natural England on developments likely to affect a SSSI. The dataset and user guidance can be accessed from the data.gov.uk website.
Other considerations include environmental constraints such as:
Do they avoid:
designated sites/priority habitats
protected landscapes
Best and Most Versatile (BMV) Agricultural Land
areas at risk of flooding
brownfield sites of high environmental value
Yes
Draft Local Plan Review
Q4. Do you agree with Policy P1? If not why not, and what alternative would you suggest?
Representation ID: 1747
Received: 17/02/2017
Respondent: Natural England
Natural England broadly agrees with Policy P1.
Natural England broadly agrees with Policy P1.
Yes
Draft Local Plan Review
Q5. Do you agree with the key objectives that development is expected to meet as identified in Policy P1 are appropriate? If not why not? Are there any others you think should be included?
Representation ID: 1748
Received: 17/02/2017
Respondent: Natural England
Natural England broadly agrees with the key objectives which relates to the protecting and enhancing of natural assets and takes climate change into consideration.
Natural England broadly agrees with the key objectives which relates to the protecting and enhancing of natural assets and takes climate change into consideration.
Yes
Draft Local Plan Review
Q7. Do you agree with Policy P2? If not why not, and what alternative would you suggest?
Representation ID: 1749
Received: 17/02/2017
Respondent: Natural England
Natural England broadly supports Policy P2,in particularly where green infrastructure is a key consideration.
Natural England broadly supports Policy P2,in particularly where green infrastructure is a key consideration.
No
Draft Local Plan Review
Q15. Do you believe we are planning to build new homes in the right locations? If not why not, and which locations do you believe shouldn't be included? Are there any other locations that you think
Representation ID: 1752
Received: 17/02/2017
Respondent: Natural England
The plan allocations should set out criteria for selecting sites with the least environmental value e.g. avoid designated sites/landscapes, BMV land, areas at risk of flooding.
The policy does not identify land where development would be inappropriate, this should be addressed and clear criteria should be set out for development allocations.
Your authority should utilise the SSSI Impact Risk Zones which has been designed to be used during the planning application validation process to help decide when to consult Natural England on developments likely to affect a SSSI. The dataset and user guidance can be accessed from the data.gov.uk website
The plan allocations should set out criteria for selecting sites with the least environmental value e.g. avoid designated sites/landscapes, BMV land, areas at risk of flooding.
The policy does not identify land where development would be inappropriate, this should be addressed and clear criteria should be set out for development allocations.
Your authority should utilise the SSSI Impact Risk Zones which has been designed to be used during the planning application validation process to help decide when to consult Natural England on developments likely to affect a SSSI. The dataset and user guidance can be accessed from the data.gov.uk website
No
Draft Local Plan Review
Q17. Do you agree with Policy P6? If not why not, and what alternative would you suggest?
Representation ID: 1754
Received: 17/02/2017
Respondent: Natural England
Natural England recommends that
"Any unacceptable adverse impact on landscape or local nature conservation designations, ecology, biodiversity or the historic environment can be mitigated" also notes national designations such as SSSIs.
Natural England recommends that
"Any unacceptable adverse impact on landscape or local nature conservation designations, ecology, biodiversity or the historic environment can be mitigated" also notes national designations such as SSSIs.
Yes
Draft Local Plan Review
Q19. Do you agree with the policies for protecting the environment? If not why not, and what alternatives would you suggest?
Representation ID: 4162
Received: 21/02/2017
Respondent: Natural England
Support policy P9
Object to Policy P10. Amendments are recommended so that the Mitigation Hierarchy heading comes ahead of the Site headings, to show that SSSIs have significantly increased levels of protection than LNRs and sites outside statutory designations.
No evidence that an HRA report has been undertaken.
Policy P11 should refer to the river Blythe SSSI, to reflect its status. The Policy should recognise the need to protect habitats from water related impacts and seek enhancement, especially SSSIs, but also local sites.
Recommends changes to Policy P13 and separate policies on Soils and Agricultural Land Quality and Ancient Woodland.
additional letter to supplement reps made online