NE3 Biodiversity

Showing comments and forms 1 to 5 of 5

Support

Publication Draft

Representation ID: 65566

Received: 27/06/2014

Respondent: Keith Wellsted

Representation Summary:

Good idea

Full text:

Good idea

Object

Publication Draft

Representation ID: 65585

Received: 27/06/2014

Respondent: Warwickshire Wildlife Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Warwickshire Wildlife Trust recommends that the policy wording in NE3 is amended to require net gain for biodiversity in place of the current wording requiring no net loss.

Full text:

Warwickshire Wildlife Trust is broadly supportive of policy NE3 but believes that the current wording is not entirely compliant with the principles of the National Planning Policy Framework (NPPF).

Our principal concern is with the provisions of clause A, which requires development proposals to 'lead to no net loss of biodiversity, where appropriate'. This clause is inconsistent with paragraph 109 of the NPPF which requires the planning system to '[minimise] impacts on biodiversity and [provide] net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity'.

The principle of net gain for biodiversity is now firmly established in Government policy, though the Natural Environment White paper and Biodiversity 2020 - a Strategy for England's Wildlife and Ecosystem Services. The Government recognises that to halt the loss of biodiversity, there needs to be a shift towards creating more, bigger, better and joined places for nature and by establishing coherent ecological networks. We believe that the policy's current wording, which will in effect maintain the status quo in terms of biodiversity, will not be ambitious enough to achieve these ends.

Furthermore, we recognise that it was previously difficultly to demonstrate net gain in planning applications without substantial habitat enhancements which are difficult to justify as part of the planning application. However, the recent introduction of a biodiversity impact calculator from the Biodiversity Offsetting pilot scheme has now provided an alternative way of calculating relative loss and gains of biodiversity on site. This means that there is now a simplified, transparent and effective way of demonstrating biodiversity gain for all planning applications, whatever the size or scale.

As a reference to this 'approved ecological assessment' is already included in the policy wording, we see no reason as to why the principles of Government Policy and the NPPF cannot be upheld and that a net gain for biodiversity be firmly upheld as a policy requirement in NE3.

Object

Publication Draft

Representation ID: 65863

Received: 27/06/2014

Respondent: Warwickshire County Council Physical Assets Business Unit

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Questions whether the Warwick District Habitat Assessment is sufficiently recent to
reliably inform the preparation of the Local Plan, particularly given that the analysis for each site recommends that specific additional surveys will be required in the appropriate survey season. The Assessment was also undertaken between August and October, which was not the optimum time of year to
carry out comprehensive ecological assessments. WDC has had almost 6 years to address this deficiency and provide more up-to-date evidence. The assessment does not assess all the preferred allocations included within the Publication Draft. The HRA (March 2014) make reference to 10,800 homes rather than 12,860.

Full text:

See attachment

Object

Publication Draft

Representation ID: 66017

Received: 27/06/2014

Respondent: University of Warwick

Agent: Turley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The requirement within this policy for new developments to protect or enhance biodiversity assets and avoid negative impacts on existing biodiversity is considered to be contrary to the NPPF which at para. 118 requires development to be refused only when '"significant harm" to biodiversity cannot be avoided,
mitigated or compensated. Opportunities to incorporate biodiversity in and around developments should be "encouraged" but avoidance of impacts is not a requirement of the NPPF. This policy is considered to be unsound because it is not consistent with national policy.

Full text:

See attachment

Object

Publication Draft

Representation ID: 66429

Received: 23/06/2014

Respondent: Woodland Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Would like policy to specifically include a reference to EXPANDING biodiversity assets like native woodland. Tree planting can deliver a wide range of benefits and the Council has a statutory duty to protect trees and promote tree planting supported by national policy in the form of the NPPF. Would like to see the wide benefits of woodland creation covered by a dedicated Trees and Woodland SPD
Would like to see similar committment to policy CT5 in seeking green infrastructure like tree planting.
Identifies a good example of a positive woodland local plan policy in the solihull Local Plan.

Full text:

see attached

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