Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the
The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
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The biodiversity of the English countryside is a function of traditional land management strategies of the last thousand years. Changes in the last 100 years have eroded biodiversity and if it is to stand a chance of recovery, the importance of brownfield first as a policy adoption is self-evident. If green fields are developed, they will never again make a positive contribution to the true return of biodiversity. This is one of the core functions of Green Belt as a concept to prevent urban sprawl.
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The ELMS scheme - and its success or failure - will be very important here. The Councils should make sure farmers are supported in understanding and making use of this scheme. The Councils should also make sure that river pollution is prevented: the two biggest sources of river pollution are run-off of fertiliser (manure and artificial) from agricultural land and sewage dumping. The Councils need to do all they can to tackle these.
- Q-B5: We support option B5c. We do not think the Local Plan is the right place for such policies which are being set at a national level already. - Q-B6: No, we don’t see the need further level of designation beyond the current suite of Local, Regional and National Wildlife designations. - Q-B7: Yes, policies from the Minerals Plan should not be replicated. - Q-B8.1: Policies should simply cross reference with national policy. There is no need for additional guidance. - Q-B9: No, national guidance and law already exists to protect such areas and should not be duplicated.
Policy option B5 looks to introduce an ‘Environmental Net Gain’ policy. This appears to build on the Biodiversity Net gain requirements and incorporate other areas of the environment such air and water quality and carbon capture. The Council should not set a higher environmental target than those already set out by government, the Building Regulations and those set out in the Environment Act 2021. This includes ensuring that the Council does not require BNG above 10%. Any environmental target beyond the current legislation would need to be fully evidenced and justified and ensure it meets the requirements of paragraph 57 of the NPPF and in particular ensure that any requirement is ‘fairly and reasonably related in scale and kind to the development’ (para 57, NPPF).
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South Warwickshire will be more biodiverse and environmentally resilient if the Local Plan avoids developing the Green Belt and instead seeks to preserve and protect this important natural asset. Changes in the last 100 years have eroded biodiversity and if it is to stand a chance of recovery, the importance of "brownfield first" as a policy adoption is self evident. The Green Belt north of Leamington comprises high quality farmland alongside wildlife refuges which support biodiversity. If these green fields are developed they will never again make a positive contribution to the true return of biodiversity.
- Issue B5: Environmental Net Gain - We support option B5c. Any requirements should be set at the national level unless there are very specific reasons and a sound reasoning for needing a different requirement to meet local circumstances. Issue B6: Wildbelt designations - QB6 - We don’t see the need further level of designation beyond the current suite of local, regional and national environmental designations. - Issue B7: Minerals - QB7 - Policies from the Minerals Plan should not be replicated. - Issue B8: Agricultural Land - Q-B8.1 - Policies should simply cross reference with national policy. There is no need for additional guidance. - Issue B9: Protecting Biodiversity and Geodiversity assets - Q-B9. National policies, guidance and legislation already exists to protect such areas and should not be duplicated as appropriate.
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It is imperative that we maintain green corridors. There has been a great deal of environmental degradation as a result of HS2. Biodiversity continues to fall. We must improve in this area.
Bolster any plan that protects our natural Environmen. We have this biodiversity once. When it’s gone it’s gone.
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how could a proposal outweigh beneifts suggested in B9 once greenfields are gone, they are gone forever
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B1: B1a – Give consideration to areas of restraint to protect settlements in WDC area – e.g. as suggested to protect Barford from the advance of Warwick and Leamington by having a RED LINE at the level of the M40 or A4100. Also along Barford Bypass to protect land to the west. B6: Yes - 30% may be very ambitious, but if we don’t try… B8.1: YES, protect BMV land.
• There should be 20% Biodiversity Net Gain through new development, currently, only 10% is included in the plan. • The Green Infrastructure study used is now 10 years old and needs to be reviewed early on to inform growth options and to include joined-up wildlife corridors.
Some areas around Long Itchington have been suggested as potential development sites. Some of which (e.g. to the north of Long Itchington are designated as "special Landscape Area" which should be retained to maintain the character of the area.
Issue B9: Protecting Biodiversity and Geodiversity assets 8.1 Sites of national importance are protected by national planning policy. Duplication of that policy is not strictly necessary in the SWLP. However, L&Q Estates are supportive of a policy which seeks to require the safeguarding of such sites, unless the benefits of the proposal clearly outweigh the need to protect the site. 8.2 As noted in the Vision Document accompanying these written representations, an extended Phase 1 habitat survey and further desk and field-based surveys have been undertaken on land east of Banbury Road, Southam. These ecological surveys have identified that the majority of the Site is of limited ecological value. However, the Site does support: • Two small fields of semi-improved neutral grassland; • Two ponds; and • A series of hedgerows and treelines, that are all considered to be of local level value for nature conservation 8.3 These ecological features have previously been confirmed to support relatively common and widespread populations of breeding birds, bats and a small grass snake population. In addition, one of the ponds designated as a Local Wildlife Site (‘Southam Ponds Ecosite’), lies partially within the site boundary and immediately to the north east of the site, and has been found to support a small to medium population of great crested newts. 8.4 The retention of these valuable ecological habitats, protection of the species they support, and maintenance of wildlife corridors between them and the wider landscape, would be integral to the design evolution of the promotion site. In particular, retention and enhancement or restoration of the onsite hedgerow network, ponds, and semiimproved grassland fields will greatly assist in achieving net gains in biodiversity.
Q-B.1: Areas of Restraint 75. In the context of planning for major urban extensions, the Councils may wish to consider whether the areas it considers should remain open should be designated as Green Belt in accordance with paragraph 139 of the Framework.
A clear detailed policy to protect the environment, enhancing and restoring wildlife sites needs to be established. Lack of a scientific approach means there is no detailed plan to achieve specific outcomes. The National Planning Policy Framework (NPPF) must be satisfied, requiring ‘conservation and enhancement of the natural...environment, including landscapes and green infrastructure’ Q-B6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, but not conditional on the removal of other protections. Wildbelt in addition to green belt and don’t use existing green belt areas to deliver expectations, they must be incremental.
Q B 9 Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes, and again the benefits of development cannot outweigh the erosion of greenbelt once all considerations and alternative options for development have been considered. BQ. 10. Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire The biodiversity and environmental assessments for Henley are inadequate to support a fully informed decision making process. The current consultation documents do not demonstrate proper understanding of the area habitat and infrastructure capacity.
Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity.
South Warwickshire Councils need a clear policy to protect important environmental assets, designated and non designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Governments commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural…environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. QS1a Yes this should study be produced in advance of the Nature Recovery Network, as it is a very important bit of local work and needs to inform ‘Sound’ locations of growth. This is also a legal requirement in the NPPF. The 2013 Green Infrastructure study is also now 10 years out of date, and considered very outdated. This needs to be reviewed early on and in detail, in order to deliver joined up habitats and influence the spatial options. This should be produced based on Natural England’s new GI Framework Green Infrastructure Home (naturalengland.org.uk) The Nature Recovery Strategy will also take some time to produce, so we need a policy in the interim. Q-E7.1: Please select the employment option which is most appropriate for South Warwickshire We are concerned that the plan hasn’t considered local biodiversity in enough detail in their growth strategies, with a number of growth areas directly adjacent to the important River Avon and River Leam and their tributaries. As well as a number of key Local Wildlife Sites. The Councils also urgently need to assess their ‘Potential Local Wildlife Sites’ to give them more weight, especially in the south as these should have full LWS status, and should be informing the growth strategy. We are particularly concerned that the ‘Dispersal option’ includes a number of large settlement actually in the Area of Outstanding Natural Beauty (AONB), this isn’t considered a legally sound Option in line with the Sustainability Appraisal. The NPPF states ANOB should only be considered in exceptional circumstance and Para 76. States ‘the scale and extent of development within all these designated areas should be limited’. We are concerned that a number of important Local Wildlife Sites and Potential LWSs are located in the proposed growth areas, including a number of key SSSIs and the Nature Improvement Area: Leamington- Warwick Racecourse Nursery Wood and Newbold Comyn LWS’s and the Grand Union Canal LWS. Southam- Long Itchington quarry, Bishops Hill and Bishops Bowl LWS, Ufton Hill Farm Fields PLWS NE- Thickthorn wood stoneypark wood NW- Hays wood River Alne, Coughton Park LWS South- River Stowe LWS West - River Arrow, Springs, Three Oakhill, The Belts Wood and Old Pack Woo LWS SW- Long Marston Disused Airfield and Doctors Farm LWS SE- DM Kineton, Bomb crater pool North- Henley Meadows LWS Dispersed method -includes Oversley Wood LWS amongst others Q-S5.2: Do you think New Settlements should be part of the overall strategy? WWT is very concerned regarding the proposed locations of a whole new settlement, due to the proximity of a number of important SSSIs, river habitats, the Nature Improvement Area, Local Wildlife Sites and Potential LWS which don’t seem to have been considered at all in the assessment. To the north, Crackley wood LNR, Kenilworth common LNR, Parliment piece and knowle hill LNR, River Sowe, Hill woottton farm meadows PLWS, Stoneleigh park, Wainbody and Kenilworth Road Woods LWS, Wootton spinneys PLWS, Grand Union Canal PLWS, NW- Bannams wood SSSI, Ullenhall meadows SSSI, River Alne LWS, Wedgnock Rifle Range PLWS, Palefield Coppice and Inchford Brook Woods to NW, Rough Hill woods SSSI, Ipleys Alders SSSI, Redditch woods LNR, North Brook Spinney PLWS and Hatton Jct PLWS, SW- Cleeve Prior bank LNR, River Avon and tributaries LWS, The Greenway, Dismantled Railway, Lower Gorse and Sheepleys Covert and Charlecote Park. West -Snitterfield and bearley bushes SSSI, Comill Hill SSSI, Sherbourne meadows SSSI South east- Long Itchington and Ufton woods SSSI, and Ufton Fields SSSI and Harbury Railway SSSI, Ufton Hill Farm PLWS and fields and Bishops Hill and Bishops Bowl LWS, Land adjacent to SSSI, whitnash brook LNR, amongst others. Option B3a: Introduce Special Landscape Areas across all of South Warwickshire. Option B4b: Include a buffer around the periphery of the Cotswold AONB. Yes WWT supports the designation of more Special Landscape Areas in key areas and B4 a separate ‘Area of Outstanding Natural Beauty’ and buffer policy, which is a particularly important area for protection in Warwickshire. We also need detailed worded policies fully protecting and enhancing the areas key wildlife habitats from unnecessary growth. Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5a: Explore and pursue an integrated or separate Environment net gain policy? WWT is disappointed to see that over 10%, 20% Biodiversity Net Gain which we proposed isn’t even being explored as an option, at this scale of joint plan making. A plan of this scale should be being a lot more ambitious, as other Councils have been such as Greater Cambridgeshire which requires 20% BNG. Risk with integrated ‘Environment’ net gain policy of watering down the 10% biodiversity net gain, and allowing the development industry to wriggle out of the legal biodiversity requirements set in the Environment Act. Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes very pleased to see our designation that we advocated for included, the Wildlife Trusts new Wildlbelt policy to protect key land for nature recovery. As there needs to be a clear evidence of how the Councils will achieve the Governments targets of ‘30% of land in environmentally sensitive management by 2030’ and in the ‘Pledge for Nature’ with the United Nations and UN Sustainable Development Goals, as well as the commitments in the 25 year Environment Plan. The plan need a clear policy for how the councils will achieve this legal requirement and plan making Is a key opportunity to achieving this. Q-B8.2: When considering climate change, biodiversity and economic wellbeing, are there any rural land uses or locations that should be prioritised over others? Yes need additional protection and buffers on the river Avon, Leam and their tributaries, Local Wildlife Sites and PLWS’s, Local Nature Reserves, SSSIs, Ancient woodland, Local Green Spaces, Ecosites etc. Councils need to reassess their Potential Local Wildlife Sites as a matter of urgency, as particularly in the south there are huge gaps in this very important evidence base. Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes in order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets.