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

Representation Summary:

Natural England broadly agrees with the challenges your authority has identified as facing Solihull Metropolitan Borough Council.

Full text:

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

Representation Summary:

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.

Full text:

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

Representation Summary:

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.

Full text:

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

Representation Summary:

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

Full text:

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

Representation Summary:

Natural England broadly agrees with Policy P1.

Full text:

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

Representation Summary:

Natural England broadly agrees with the key objectives which relates to the protecting and enhancing of natural assets and takes climate change into consideration.

Full text:

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

Representation Summary:

Natural England broadly supports Policy P2,in particularly where green infrastructure is a key consideration.

Full text:

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

Representation Summary:

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

Full text:

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

Representation Summary:

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.

Full text:

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

Representation Summary:

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.

Full text:

additional letter to supplement reps made online

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