Draft Local Plan - Supplementary Consultation

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Comment

Draft Local Plan - Supplementary Consultation

Site Selection Methodology

Representation ID: 8958

Received: 15/03/2019

Respondent: Natural England

Representation Summary:

Natural England welcomes the inclusion of landscape capacity in the factors against in the refinement criteria.

We advocate allocations on land of least environmental and amenity value.
In particular they avoid:
* designated sites/priority habitats
* Best and Most Versatile (BMV) Agricultural Land
* areas at risk of flooding
* brownfield sites of high environmental value

Full text:

Natural England welcomes the inclusion of landscape capacity in the factors against in the refinement criteria.

We advocate allocations on land of least environmental and amenity value.
In particular they avoid:
* designated sites/priority habitats
* Best and Most Versatile (BMV) Agricultural Land
* areas at risk of flooding
* brownfield sites of high environmental value

Comment

Draft Local Plan - Supplementary Consultation

Question 3 - Infrastructure Requirements at Balsall Common

Representation ID: 8967

Received: 15/03/2019

Respondent: Natural England

Representation Summary:

Natural England encourages the provision of green infrastructure to be included as a specific infrastructure requirement, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure.

Green infrastructure refers to the living network of green spaces, water and other environmental features in both urban and rural areas. It is often used in an urban context to provide multiple benefits including space for recreation, access to nature, flood storage and urban cooling to support climate change mitigation, food production, wildlife habitats and health & well-being improvements provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands, rivers and wetlands.

Green infrastructure is also relevant in a rural context, where it might additionally refer to the use of farmland, woodland, wetlands or other natural features to provide services such as flood protection, carbon storage or water purification.

A strategic approach for green infrastructure is required to ensure its protection and enhancement, as outlined in para 171 of the NPPF. We encourage the provision of green infrastructure to be included as a specific infrastructure requirement, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure.

Full text:

Green infrastructure refers to the living network of green spaces, water and other environmental features in both urban and rural areas. It is often used in an urban context to provide multiple benefits including space for recreation, access to nature, flood storage and urban cooling to support climate change mitigation, food production, wildlife habitats and health & well-being improvements provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands, rivers and wetlands.

Green infrastructure is also relevant in a rural context, where it might additionally refer to the use of farmland, woodland, wetlands or other natural features to provide services such as flood protection, carbon storage or water purification.

A strategic approach for green infrastructure is required to ensure its protection and enhancement, as outlined in para 171 of the NPPF. We encourage the provision of green infrastructure to be included as a specific infrastructure requirement, for example biodiversity, green space, flood risk, climate change, reflecting the multifunctional benefits of green infrastructure.

Comment

Draft Local Plan - Supplementary Consultation

Question 44 Are there any other comments

Representation ID: 9016

Received: 15/03/2019

Respondent: Natural England

Representation Summary:

Natural England comments apply to all of the sites and infrastructure requirements.

Green Infrastructure - Our comments to Q3 Balsall Common applies to all sites

SSSIs and Local Wildlife Sites (LWS) the following should be considered:
- does the site allocation make management of nearby SSSI/LWS less viable. e.g. via urbanisation, or lead to severance or isolation of that SSSI/LWS or preclude making future links between the SSSI/LWS and other sites, and whether there are likely to be any air or water related impacts.We encourage allocation of alternative sites if adverse effects cannot be overcome.

- Have impacts on protected species been considered? Appropriate mitigation measures should be identified to reduce impacts.

Does the allocation enhance biodiversity, delivering net gains where possible in particular:
* Enhancement of existing features, especially on-site hedges, wetlands, woods, aged and veteran trees, watercourses and any geological features.
* New habitat creation measures.
* Proportion of green roofs on commercial buildings.
* Bird and bat boxes.
* Biodiversity plan for site (or biodiversity incorporated into any scheme for GI/open spaces).
* Measures to protect/enhance/link neighbouring/nearby SSSIs or local sites.
* Maximise the biodiversity contribution of any SUDS.

Full text:

Natural England is not going to submit comments on each individual location as most of our comments are generic and apply to all sites and infrastructure requirements.

Green Infrastructure - Our comments to Q3 Balsall Common applies to all sites

Protected Sites (SSSIs) and Local Wildlife Sites (LWS) - We note that consideration is given to important sites such as SSSIs e.g. River Blythe. Factors to consider include whether the allocation will make management of nearby SSSI/LWS less viable e.g. via urbanisation, or lead to severance or isolation of that SSSI/LWS or preclude making future links between the SSSI/LWS and other sites, and whether there are likely to be any air or water related impacts. We encourage allocation of alternative sites if adverse effects cannot be overcome.

Protected Species - Have impacts on protected species been considered? Appropriate mitigation measures should be identified to reduce impacts.

Does the allocation enhance biodiversity, delivering net gains where possible? In particular consider:
* Enhancement of existing features, especially on-site hedges, wetlands, woods, aged and veteran trees, watercourses and any geological features.
* New habitat creation measures.
* Proportion of green roofs on commercial buildings.
* Bird and bat boxes.
* Biodiversity plan for site (or biodiversity incorporated into any scheme for GI/open spaces).
* Measures to protect/enhance/link neighbouring/nearby SSSIs or local sites.
* Maximise the biodiversity contribution of any SUDS.

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