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
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. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being produced 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’. Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. 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. 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. 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 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.
Issue B5: Environmental Net Gain Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these The requirement for sites to provide a 10% Biodiversity Net Gain (BNG) will come into force in November 2023, as dictated by the Environment Act. Terra consider that there is no justification for an Environmental Net Gain Policy going above and beyond this. The delivery of a biodiversity net gain needs to be considered on a site-by-site basis, as the ability to deliver a net gain of greater than 10% will be dependent on the baseline habitat conditions. The Environment Act will ensure that every new site achieves a 10% minimum BNG, so there is no need to pursue any higher requirement than this.
Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these The requirement for sites to provide a 10% Biodiversity Net Gain (BNG) will come into force in November 2023, as dictated by the Environment Act. Terra consider that there is no justification for an Environmental Net Gain Policy going above and beyond this. The delivery of a biodiversity net gain needs to be considered on a site-by-site basis, as the ability to deliver a net gain of greater than 10% will be dependent on the baseline habitat conditions. The Environment Act will ensure that every new site achieves a 10% minimum BNG, so there is no need to pursue any higher requirement than this.
Q-B5: Please select the option which is most appropriatefor South Warwickshire. Option B5c: None of these. St Philips supports the movement towards achieving environmental sustainability and encouraging environmental net gain in regard to new development. However, it is important to note NPPF paragraph 31 which states that “The preparation and review of all policies should be underpinned by relevant and up-todate evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” 2.38 Without the support of evidence and an agreed method, a policy requirement is not considered to be justified and therefore would not be found to be legally compliant in accordance with the NPPF. Although St Philips supports the movement towards achieving an environmental net gain, it is considered that, at this moment in time, a policy requirement would be unjustified. In terms of an agreed method, the Issues and Options document states that: “Should this approach be taken, further work will be required to determine how environmental net gain will work in practice.” In consideration, St Philips considers that the environmental net gain concept and the method of application is currently not supported by sufficient evidence. Therefore, a policy requirement would not be justified in this moment in time unless further work is completed. 2.40 Overall, an environmental net gain policy requirement would provide developers with greater flexibility and the freedom to concentrate on the most relevant aspects that can be improved on-site. Importantly, and as already stated, St Philips urges South Warwickshire to compile sufficient evidence to ensure an appropriate method and requirement is adopted. Although an environmental net gain policy would provide greater flexibility, it is imperative that a negative ‘trade-off’ is prevented between ecosystem services. Therefore, until sufficient evidence is gathered, St Philips considers that an environmental net gain policy would be unjustified. Furthermore, a proposed policy approach would have to be assessed within a viability assessment before being adopted.
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.
Q-B3: Option B3b: Maintain Special landscape Areas within Stratford-on-Avon District but don’t introduce them within Warwick District There is no requirement on a national basis for Strategic Landscape Areas to be in place. Q-B6: No “Wildbelt” is not a recognised land use defined in the NPPF which Local Plans need to accommodate. Q-B8.1: Do you agree that the plan should include a policy avoiding a development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? No This policy does not need to be included in the SWLP given that the approach to development on agricultural land is already included in the NPPF.
Q-B5: Option B5c: None of these. St Philips supports the movement towards achieving environmental sustainability and encouraging environmental net gain in regard to new development. However, it is important to note NPPF paragraph 31 which states that “The preparation and review of all policies should be underpinned by relevant and up-todate evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” Without the support of evidence and an agreed method, a policy requirement is not considered to be justified and therefore would not be found to be legally compliant in accordance with the NPPF. Although St Philips supports the movement towards achieving an environmental net gain, it is considered that, at this moment in time, a policy requirement would be unjustified. In terms of an agreed method, the Issues and Options document states that: “Should this approach be taken, further work will be required to determine how environmental net gain will work in practice.” In consideration, St Philips considers that the environmental net gain concept and the method of application is currently not supported by sufficient evidence. Therefore, a policy requirement would not be justified in this moment in time unless further work is completed. Overall, an environmental net gain policy requirement would provide developers with greater flexibility and the freedom to concentrate on the most relevant aspects that can be improved on-site. Importantly, and as already stated, St Philips urges South Warwickshire to compile sufficient evidence to ensure an appropriate method and requirement is adopted. Although an environmental net gain policy would provide greater flexibility, it is imperative that a negative ‘trade-off’ is prevented between ecosystem services. Therefore, until sufficient evidence is gathered, St Philips considers that an environmental net gain policy would be unjustified. Furthermore, a proposed policy approach would have to be assessed within a viability assessment before being adopted.
Q-B3: We consider that Special Landscape Areas should not be introduced to Warwick District. This is consistent with national policy and Natural England’s approach. Option B3c: Discard Special Landscape Areas and bolster general landscape policy is considered the most appropriate. We consider that any landscape policy should be worded to consider the specific character of parcels of land and a blanket approach to areas is avoided whereby certain parcels are afforded greater weight by virtue of a generalised blanket approach instead of a detailed understanding of the specific characteristics and merits of parcels of land.
No answer given
Q-B8.1 Response: Whilst it is clearly demonstrably important to preserve some of the best and most versatile agricultural land, large swathes of South Warwickshire are covered by agricultural land which may be considered to be the best and most versatile. When added to the Green Belt constraint faced by the Local Plan area, it considerably narrows the opportunity to deliver new strategic development to capitalise on existing assets and attract new inward investment. In this context, any policy would need to be very carefully considered and balanced so that it does not stifle any development opportunity which is demonstrably beneficial.
Q-B5 Option B5c: None of these St Philips supports the movement towards achieving environmental sustainability and encouraging environmental net gain in regard to new development. However, it is important to note NPPF paragraph 31 which states that “The preparation and review of all policies should be underpinned by relevant and up-todate evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.” 2.49 Without the support of evidence and an agreed method, a policy requirement is not considered to be justified and therefore would not be found to be legally compliant in accordance with the NPPF. Although St Philips supports the movement towards achieving an environmental net gain, it is considered that, at this moment in time, a policy requirement would be unjustified. In terms of an agreed method, the Issues and Options document states that: “Should this approach be taken, further work will be required to determine how environmental net gain will work in practice.” 2.50 In consideration, St Philips considers that the environmental net gain concept and the method of application is currently not supported by sufficient evidence. Therefore, a policy requirement would not be justified in this moment in time unless further work is completed. 2.51 Overall, an environmental net gain policy requirement would provide developers with greater flexibility and the freedom to concentrate on the most relevant aspects that can be improved on-site. Importantly, and as already stated, St Philips urges South Warwickshire to compile sufficient evidence to ensure an appropriate method and requirement is adopted. Although an environmental net gain policy would provide greater flexibility, it is imperative that a negative ‘trade-off’ is prevented between ecosystem services. Therefore, until sufficient evidence is gathered, St Philips considers that an environmental net gain policy would be unjustified. Furthermore, a proposed policy approach would have to be assessed within a viability assessment before being adopted.
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.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q-B1: Please select the option which is most appropriate for South Warwickshire Option B1b: Remove Areas of Restraint designations 2.86. A disjointed approach between the two local authority areas should be avoided wherever possible. Of the options presented therefore, the Respondent would favour removal of existing areas of restraint, with open areas of land that serve to preserve the structure and character of settlements protected through more generic heritage and/or landscape policies. Q-B3: Please select the option which is most appropriate for South Warwickshire Option B3c: Discard Special Landscape Areas and bolster general landscape policy 2.87. A disjointed approach between the two local authority areas should be avoided wherever possible. Given that Special Landscape Areas are now a somewhat outdated concept the Respondent considers, in the interests of consistency across the plan area, that Special Landscape Areas should be discarded (rather than seek to establish such areas across the whole of South Warwickshire). Q-B4: Please select the option which is most appropriate for South Warwickshire Option B4a: Maintain the current policy approach, without the use of a buffer 2.88. Creating a buffer around the Cotswold AONB is superfluous to national planning policy that requires development within the setting of AONBs to be sensitively located and designed to avoid or minimise impacts. The Respondent therefore considers Option B4a, which seeks to maintain the current policy approach without use of a buffer to be sufficient in this case. Q-B5: Please select the option which is most appropriate for South Warwickshire Option B5c: None of these 2.89. Environmental Net Gain is an entirely new concept with no tried and tested approach to its delivery. It is therefore currently unknown how Environmental Net Gain would work in practice. The Respondent therefore reserves their right to make comment once more detailed information is available. Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? Y/N/ DK 2.90. No. Wildbelt is a highly aspirational concept with no statutory or national planning policy basis. Unlike other designations there is no tried and tested method for the identification or delivery of Wildbelt. It is therefore unclear upon what basis the Council would seek to justify such designations particularly in light of the absence of the Local Nature Recovery Strategy (LNRS), which is understood from the Consultation Document to be many years away. The Respondent therefore reserves their right to make comment once more detailed information is made available. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? Y/N/DK 2.91. No. Agricultural Land quality is only one of a number of factors that is taken into account when considering whether a site should be developed or not. While Paragraph 174b of the NPPF recognises the benefits of best and most versatile agricultural land this is expanded on in Footnote 58 on Page 50 of the NPPF which requires consideration of the issue only where ‘significant development’ of agricultural land is demonstrated to be necessary. In such instances, the Footnote considers that poorer quality land should be ‘preferred’ to that of a higher quality. However, this does not mean that it is mandatory to avoid the development of best and most versatile agricultural land. It is therefore highly inadvisable to promote a policy that looks to avoid the development of or seeks the retention of best agricultural land as suggested.
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.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
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. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B3. Special Landscape Areas. The accompanying text explains that national policy does not encourage Local Landscape designations – but Stratford on Avon DC pressed ahead with them anyway! In Stratford on Avon the existence of the SLA policy is being used (in my specific self-build example) to press for additional checks, further assessments and extra plans which is creating more expense and additional controls. This new Local Plan would seem to be the appropriate opportunity to drop the formal policy and simply refer to the nature of the landscape within the text, rather than conflict with national advice. The solution is therefore Option B3c. Issue B5. Environmental Net Gain. In an ideal world we might all wish to see net environmental gain as a result of new development, but this may be difficult to achieve. The BNG policy is an expensive DEFRA policy which effectively involves a subsidy from homebuyers and developers to rich landowners holding offset land. It a regressive policy to support the agricultural industry and replace EU subsidies. I would be concerned if the Local Plan set unachievable objectives which then stifled new development through lack of viability. The Councils need to mount a test bed to see whether environmental gain can be achieved before imposing any such policy.
Q-B1. Please select the option which is most appropriate for South Warwickshire Option B1a. The Cotswolds National Landscape Board supports the principle of helping to protect areas of land that help to preserve the structure and character of settlements. This principle is an important consideration in the Cotswolds National Landscape. For example, the Board’s ‘Cotswolds AONB Landscape Strategy and Guidelines’ identify the following ‘landscape implication’ relating to the development, expansion and infilling of settlements:43 . Interruption, weakening or loss of the historic character of settlements and the historic context in how they have expanded, especially the importance of the relationship between the historic core of the settlement and surviving historic features such as churchyards, manor houses, burgage plots, historic farms, pre-enclosure paddocks and closes. One of the guidelines for addressing this issue is to: . Avoid proposals that result in the loss of archaeological and historical features or that impact on the relationship of the settlement and its links with surviving historical features. The Area of Restraint policy would potentially help to address this issue. Q-B3. Please select the option which is most appropriate for South Warwickshire The Cotswolds National Landscape Board supports the Special Landscape Areas (SLA) policy as it helps to protect these high-quality landscapes, including their associated historic and cultural features, by resisting development proposals that would have a harmful effect on their distinctive character and appearance. In the context of the Cotswolds National Landscape, SLAs are a useful as a mechanism for helping to protect the setting of the National Landscape (where the SLAs are adjacent to the National Landscape). To ensure that a consistent approach is taken across the whole of the Plan area, it would make sense to introduce SLAs within Warwick District, assuming that there are landscapes in Warwick District that merit SLA status. Q-B4. Please select the option which is most appropriate for South Warwickshire Option B4b. We agree with the following statement in the Issues and Options consultation document: . When considering development in and around the Cotswold National Landscape, regard should be given to conserving and enhancing the natural beauty of the area. In particular, great weight should be given to conserving and enhancing the landscape and scenic beauty, including its ‘special qualities’. Case law has clarified that great weight should be given to the impacts that development outside an Area of Outstanding Natural Beaty (AONB) might have on the natural beauty of the AONB. This includes visual impacts (i.e., impacts on views from the AONB) as well as impacts on dark skies (e.g., increases in light pollution resulting in ‘sky glow’) and tranquillity (e.g., increases in traffic flows through – and along the boundary of the AONB). Further information on this issue is provided in the Board’s position statement on ‘Development in the Setting of the Cotswolds AONB’.44 In addition, national planning policy requires that development within the setting of an AONB should be sensitively located and designed to avoid or minimise adverse impacts on the AONB.45 The inclusion of a buffer zone around the periphery of the Cotswolds National Landscape, within the Local Plan, would help to ensure that this issue is adequately addressed. For example, for particular types and / or scales of development within this buffer zone, the local planning authority (LPA) development management system should be set up to automatically: (i) identify that potential impacts on the National Landscape should be taken into consideration; and (ii) consult the Cotswolds National Landscape Board. Appendix 2 of this document provides the Board’s suggested consultation thresholds within: (i) the Cotswolds National Landscape; (ii) the setting of the Cotswolds National Landscape. For development management purposes, we would suggest applying a 3km buffer zone. It is important to note that, for individual development management proposals, the case officer should be at liberty to take account of AONB considerations and to consult the Cotswolds National Landscape Board for proposals that are further than 3km from the Cotswolds National Landscape boundary. This would potentially be the case for large urban extensions, new settlements or large-scale wind turbines, for example. However, the benefit of applying a buffer zone is that this would be a more automated process within the buffer zone. It probably wouldn’t be appropriate to automatically class the buffer zone a Special Landscape Area (SLA). This is because the landscape within the buffer zone might not meet the SLA criteria / thresholds. The buffer zone would primarily be a development management tool for taking AONB considerations into account – it would not automatically infer that the landscape within buffer zone was of a particularly high quality. 44 Cotswolds National Landscape Board (2016) Development in the Setting of the Cotswolds AONB. 45 Ministry of Housing Communities & Local Government (2021) National Planning Policy Framework. Q-B5. Please select the option which is most appropriate for South Warwickshire Option B5b. The Cotswolds National Landscape Board supports the principle that development should deliver environmental net gain. However, we are not convinced that an integrated approach is appropriate at this stage, especially given that the practical application of environmental net gain is still in its infancy (except for biodiversity net gain). One of the risks of an integrated environmental net gain approach is that it could be used a means of trading off a gain in one ecosystem service against a deficit in a different ecosystem service. A more appropriate way forward may be to explore environmental net gain through separate policies. By utilising appropriate ‘indicators’ for each of these policies in the Local Plan it may be possible to assess the state of each ecosystem service. If these indicators are reviewed collectively this would provide an overall indication of the extent to which environmental net-gain has been delivered in the Local Plan area over the lifetime of the Local Plan period (reviewed on an annual basis, or other appropriate timescale). When considering the issue of environmental net gain, it is vitally important to follow the mitigation hierarchy, doing everything possible to first avoid harm and then minimise adverse impacts. Compensation for losses should only come into play as a last resort. As with biodiversity net gain (in relation to international and national nature conservation designations and irreplaceable habitat), there may be some ecosystem service features that are too important to be included within an environmental net gain methodology. Q-B6. Should the South Warwickshire Local Plan introduce Wildbelt designations? Don’t know. The aspiration of the Wildbelt designation concept is to aid nature recovery. However, there are already mandatory processes in place to facilitate nature recovery. For example, the Environment Act 2021 established a new mandatory system of spatial strategies for nature recovery – Local Nature Recovery Strategies (LNRS). LNRS are designed as tools to encourage more coordinated practical and focused action and investment in nature. They are intended to help map a nature recovery network, locally and nationally. Rather than creating any additional designation ‘layer’ of Wildbelts, we consider that it would probably be more appropriate for the Local Plan to explicitly focus on delivering the aspirations of the LNRS and to focus nature recovery in the areas that would form the nature recovery network. We recommend that the LNRS and any resulting nature recovery plan / map should become part of the Local Plan / development plan. The Government has identified that protected landscapes, including Areas of Outstanding Natural Beauty (AONBs) such as the Cotswolds National Landscape, are an important component of its aspirations to ensure that 30% of land is managed for nature by 2030.46 In addition, the Government-commissioned Landscapes Review has proposed that protected landscapes should form the backbone of nature recovery networks.47 Therefore, we recommend that the Local Plan should explicitly identify the Cotswolds National Landscape as a priority area of nature recovery. The Local Plan should also explicitly have regard to the Cotswolds Nature Recovery Plan 48 46 https://www.gov.uk/government/publications/landscapes-review-national-parks-and-aonbs-government-response/landscapes-review-national-parks-and-aonbs-government-response 47 Defra (2019) Landscapes Review Final Report. Proposal 4. 48 Cotswolds National Landscape Board (2021) Cotswolds Nature Recovery Plan. 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 proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites. Yes. The Local Plan could avoid simply duplicating national policy by identifying the relevant sites, habitats and species. National planning policy states that plans should distinguish between the hierarchy of international, national and locally designated sites.49 As such, the Local Plan policy should have different policy wording for each level of designation as the level of protection afforded to each level will be different. However, the importance of locally designated sites should not be underestimated. They constitute a vitally important component of our current ecological network and will play a vitally important role in delivering nature recovery. The Local Plan policy should address irreplaceable habitats. National planning policy lists several habitats that are considered to be irreplaceable.50 However, this list is not exhaustive. We recommend that, in addition to the irreplaceable habitats listed in the National Planning Policy Framework (NPPF), the Local Plan should also explicitly identify the following habitats as being irreplaceable: . Unimproved grassland that has been in-situ since before 1945. . Hedgerows that have been in-situ since before the Enclosure Acts. 49 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework. Paragraph 175. 50 Ministry of Housing, Communities and Local Government (2021) National Planning Policy Framework. Annex 2: Glossary. Q-B10: Please add any comments you wish to make about a biodiverse and environmentally resilient South Warwickshire. In addition to our responses to questions Q-B1 to QB-10, please also have regard to our response to questions Q-C9.1, relating to biodiversity net gain.
Q-B5 – Please select the option which is most appropriate for South Warwickshire The approach of adopting an ‘Environmental Net Gain’ to provide a flexible approach to other environmental matters such as Air Quality, Water Quality and Carbon capture is supported in principle. Further work however, will need to be undertaken as to how a quantifiable ‘environmental gain’ will be assessed against factors such as Air Quality.
RE Wildbelts: A balanced assessment will need to be made against the need for development, especially housing. Adding Wildbelt to the area which already contains other designations including Green Belt and AONB will reduced the areas that can be developed. It may be that areas that have low biodiversity value would be relatively attractive sites for development rather designation.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
It is very disappointing that the SWLP will be produced BEFORE the Local Nature Recovery Strategy. Why can't the SWLP be delayed until the LNRS is completed? Is this an indicator that development carries a greater weight of importance with the council than Biodiversity Net Gain?