Solihull Local Plan (Draft Submission) 2020

Support

Representation ID: 11147

Received: 12/12/2020

Respondent: Natural England

Welcome inclusion of both strategic and local sets of measures including of soft measures to assist such as GI (4iii)

Support

Representation ID: 11163

Received: 12/12/2020

Respondent: Natural England

Structured approach to policy acceptable.
1. Welcome ref to ecosystems services delivery and natural capital
2. Supported – welcome inclusion of ‘measureable’ net gains
3. Buffers explicitly mentioned
4. Broad enough but explicit enough to ensure emerging Nature Recovery evidence is taken into account.
5. National policy explicitly mentioned as a clear requirement for developers
6. Need for up to date ecological assessments
7. Welcome reference to NE’s GI Standards which is considering revision of ANGST. Current timescale 2022.
BNG
8. Minimum requirement of 10% BNG acceptable
9. Supporting of ‘in situ’ provision as preference
10. Alternative assessment required
11. Mitigation and compensation appropriate
12. Alternative strategic provision of enhancements appropriate
13. Metrics specified are appropriate. Confirmation of measured approach. Welcome support of emerging SPD
Arden landscape
14, 15 and 16 – welcomed. No further comments
SSSI
17 – supported
Local sites
18. Welcome recognition of value of wider nature recovery connections for local sites
Ancient woodland
19. Welcome ref. to NE SA.

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.

Support

Representation ID: 11165

Received: 12/12/2020

Respondent: Natural England

Policy P10 Supporting Text:
Welcome reference to ongoing partnership work and nature recovery and natural capital evidence. Confirm up to date account.

Support

Representation ID: 11166

Received: 12/12/2020

Respondent: Natural England

Comment:
Seek to not only mitigate effects of development but seek to enhance water quality of River Blythe SSSI.

Supporting of SuDS and naturalisation of river corridors.

Support

Representation ID: 11167

Received: 12/12/2020

Respondent: Natural England

Welcome reference to importance of safeguarding important trees

Support

Representation ID: 11168

Received: 12/12/2020

Respondent: Natural England

NE welcomes the strong underpinning of natural environment needs, including biodiversity and climate change measures. Useful cross reference to P10 and P11 embedded in policy.

Support

Representation ID: 11169

Received: 12/12/2020

Respondent: Natural England

Policy P15 - Supporting text
NE welcomes the strong underpinning of natural environment needs, including biodiversity and climate change measures. Useful cross reference to P10 and P11 embedded in policy.

Support

Representation ID: 11170

Received: 12/12/2020

Respondent: Natural England

NE supports inclusion of ref to environmental improvements as part of the Council’s Green Infrastructure Opportunity Mapping.

Support

Representation ID: 11171

Received: 12/12/2020

Respondent: Natural England

Particularly support sub criterion 2x - Retaining, increasing and enhancing green infrastructure within developments including green spaces, planting, trees, open spaces and soft surfaces, in order to secure a variety of spaces for residents, visitors or employees to use and observe.