Issue and Options 2023

Yes

Issue V1: Vision for the Local Plan; Issue V3: Strategic Objectives: We broadly support this plans vision and strategic objectives. In addition, Natural England advises that the Plan’s vision should address impacts upon, and opportunities for, the natural environment as a high priority. ‘An economy is built upon the environment’ - Economic growth and the environment - GOV.UK (www.gov.uk) https://www.gov.uk/government/publications/economic-growth-and-the-environment. It needs to clearly set out the environmental ambition and linked opportunities for the plan area. The plan should take a strategic approach to the protection and enhancement of the natural environment, including providing a net gain for biodiversity, considering opportunities to enhance and improve the quality of connectivity. Where relevant there should be linkages with the Biodiversity Action Plan, Local Nature Partnership, National Park/Area of Outstanding Natural Beauty Management Plans, Rights of Way Improvement Plans and Green Infrastructure Strategies, Nature Recovery Network (amend as appropriate to the local area). We note that you make mention of the Climate emergency, however there is also a biodiversity emergency which must be held with equal status alongside climate change as it has the potential to contribute to addressing climate change. Biodiversity - our strongest natural defence against climate change | United Nations. The inclusion, interaction and nature connectedness of people must also be considered as a priority in especially in terms of their wellbeing and developing love for the natural world. There should be an overarching strategy in the plan for the natural environment covering: • natural capital assets and ecosystem services • nature recovery • landscape, including designated landscapes • designated sites and local sites • ecological networks • irreplaceable habitats, priority habitats and species • protected species • impacts on invertebrates • geodiversity • soils and best and most versatile land • green infrastructure • biodiversity and wider environmental net gains • environmental enhancement • climate change adaptation Issue V2: Vision for Places: We support the inclusion of visions for places being captured within neighbourhood plans in that the local context and community will have a more intimate connection/understanding of what makes their place special. In following this practice we urge you to ensure you identify and find innovative ways of reaching those voices within the community that are likely to be overlooked. Alongside this approach we welcome the recent NPPF reform of the term ‘Beauty’ in ensuring that designs of Green and Blue infrastructure reflect a ‘Natural Beauty’ as part of the built environment. Recently launched NE GI Framework guidance will help here as will NE landscape sensitivity assessment guidance. The Plan should set design standards for high quality placemaking. The plan should incorporate a policy on design (including landscape character and green infrastructure) and set out what further guidance is available. The NPPF encourages all local authorities to prepare local design codes or guides. National design guidance is set out in the National Model Design Code (https://www.gov.uk/government/publications/national-model-design-code) and the National design guide (https://www.gov.uk/government/publications/national-design-guide).

Preliminary HRA Scoping Report (November 2022) Natural England welcomes the production of the preliminary HRA scoping report at this early stage of the plan making process. We welcome this thorough and clearly presented report. We agree with the Habitats sites identified for consideration in section 5 and the assessment of the potential impact pathways described in section 6. Air quality We agree with the thought process described in Table 6.1 Atmospheric pollution pathways of impact to Habitats sites within 20km of the SWLP administrative area and conclusion that air quality likely significant effects can be screened out of the HRA process. Hydrology We agree with the scoping outcome in Table 6.2 Water resource, levels and quality pathways of impact to Habitats sites and fully support recommendations outlined in Table 6.3. Recreation We welcome the precautionary approach to scope in the Bredon Hills Special Area of Conservation for consideration of recreational disturbance pathway and fully support recommendations outlined in Table 6.5. In particular, the recommendation that the Councils ensure formal and informal recreation provision is sufficient to accommodate level of growth set out in the SWLP. Urbanisation effects We agree with the thought process described and conclusion that there are unlikely to be any urbanisation effects as a result of the SWLP. Functionally linked land We welcome the precautionary approach taken with regards to consideration of the potentially functionally linked lands associated with the Severn Estuary and Humber Estuary designations and fully support recommendations outlined in Table 6.6. We welcome the broad spectrum of plans included in Appendix A for in-combination assessment. We would be happy to provide further comments as the HRA progress. Sustainability Appraisal (November 2022) Natural England welcomes the SA report prepared for the Issues and Options stage of the SWLP. We generally agree with the SEA Topic methodologies and assumptions applied to the appraisal process for SA Objectives. We note the current limitations to the assessment process and assumptions. We support recommendations for further research recommended on the biodiversity assessment and landscape assessment of Broad Locations. We would be happy to provide detailed comments on SA of the SWLP once the preferred options have been selected.

Issue I2: Infrastructure Requirements and delivery: We acknowledge and support this approach around heritage and cultural assets, health and wellbeing, improving connectivity and biodiversity, creating well designed and beautiful spaces. It is likely that the Plan will need to explore creative far reaching Green Financing initiatives to support existing funding vehicles such as Biodiversity Net Gain, CIL, S106 etc. in order to create incredible green spaces that meet the aspirations of the plan in certain cases - Green Finance Institute (https://www.greenfinanceinstitute.co.uk/).

4.2 Development distribution strategy for South Warwickshire Issue S1: Green & Blue Corridors: Natural England supports the direction of travel taken by the Plan to create a Local Nature Recovery Strategy for the area as per national guidance that is still being readied for dissemination by Government. The options provided each have merits to be further explored within each of them. Issue S6: A review of Green Belt boundaries: Greenbelts often are degraded landscapes capable of delivering more ecosystem services (especially landscape services and access to nature). The plan should include policies or proposals to positively enhance land within the Green Belt for biodiversity and climate resilience while enabling deeper nature experiences that improves the wellbeing of people. If the plan proposes to remove land from the Green Belt, that may affect local protected sites, then it should set out compensatory improvements to the environmental quality (including air, water and recreation impacts) and accessibility of remaining Green Belt land while also seeking NE advice on later stages of the plan making process. In relation to the aspects of the Green Belt which are within Natural England’s remit, we support the recognition of opportunities to enhance the beneficial use of the green belt. The green belt has the potential to deliver more positive benefits for the natural environment and people’s enjoyment of it and to play a role in climate change adaptation. Opportunities should be taken to link into green infrastructure (guided by NE new GI Standards and Principles) and ecological networks, both within the urban areas and with the open countryside.

Issue C1: Solar and wind power: Solar PV should ensure proposals are appropriately sited, give proper weight to environmental considerations such as landscape, species and visual impacts, heritage and local amenity, and provide opportunities for local communities to influence decisions that affect them. NE would like to make it clear that any proposal for a solar farm involving the best and most versatile agricultural land would need to be justified by the most compelling evidence. Soil is a finite resource which plays an essential role within sustainable ecosystems, performing an array of functions supporting a range of ecosystem services, including storage of carbon, the infiltration and transport of water, nutrient cycling, and provision of food. It is recognised that a proportion of the agricultural land will experience temporary land loss. In order to both retain the long term potential of this land and to safeguard all soil resources as part of the overall sustainability of the whole development, it is important that the soil is able to retain as many of its many important functions and services (ecosystem services) as possible through careful soil management and appropriate soil use, with consideration on how any adverse impacts on soils can be avoided or minimised. The Plan should refer to the Defra Code of practice for the sustainable use of soils on construction sites (https://www.gov.uk/government/publications/code-of-practice-for-the-sustainable-use-of-soils-on-construction-sites).

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Issue C3: Carbon Sequestration: Carbon Offsetting schemes: In principle yes – but we would need to see more details and strategies for its use before committing. Renewable / low carbon energy: The plan should identify suitable areas for different forms of renewable / low carbon energy. As a part of this, the plan should take account of the capacity of the natural environment to accommodate energy infrastructure. These should avoid designated landscapes and sites. Development management policies should address biodiversity and landscape impacts, including cumulative landscape and visual impacts.

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Issue C4: New Buildings: NE encourages buildings designed to accommodate high environmental standards as described. We also encourage the Plan to move towards innovative building design that incorporates more opportunities for nature within the fabric of the building. This can be as diverse as designing in opportunities for Bat roosts, Swift and House-martin nests to wall hibernacula for Newts and crevices for invertebrates.

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Issue C7: Adapting to higher temperatures: The Local Plan should consider climate change adaption and recognise the role of the natural environment to deliver measures to reduce the effects of climate change, for example tree planting to moderate heat island effects. In addition factors which may lead to exacerbate climate change (through more greenhouse gases) should be avoided (e.g. pollution, habitat fragmentation, loss of biodiversity) and the natural environment’s resilience to change should be protected. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Our advice on adaptation focuses on measures to assist biodiversity to adapt, and green infrastructure measures to assist people to adapt (principally to extreme high temperature events, extreme high/low rainfall events, and for coastal areas, sea level rise and extreme storm surge events). For example, using tree planting to moderate heat island effects and SUDS to address flooding. Issue C9: Mitigating Biodiversity loss: Strategic/landscape scale approach to biodiversity: We acknowledge and support the direction of travel of this Policy. The plan should set out a strategic approach, planning positively for the creation, protection, enhancement and management of networks of biodiversity. The policies should consider biodiversity at a landscape-scale across local authority boundaries. Natural England recommends that the Local Plan should have close connections to the Local Nature Recovery Strategy (LNRS), with these plans ideally working towards a shared purpose. We recommend that the LPA approaches the LNRS lead to discuss how the plans can complement each other. Connections should also be made to the green infrastructure strategy.

Issue C11: Water management: Natural England expects the Plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should be based on an up to date evidence base on the water environment and as such the relevant River Basin Management Plans should inform the development proposed in the Local Plan. These Plans (River basin management plans: updated 2022 - GOV.UK (www.gov.uk)) [https://www.gov.uk/guidance/river-basin-management-plans-updated-2022] implement the EU Water Framework Directive and outline the main issues for the water environment and the actions needed to tackle them. Local Planning Authorities must in exercising their functions, have regard to these plans. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focussed on European sites, SSSIs and local sites which contribute to a wider ecological network. Plans should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this. Issue C12: Flood risk: The Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.