Object

Preferred Options November 2021

Representation ID: 923

Received: 22/12/2021

Respondent: Natural England

Representation Summary:

HC13 - reference the positive impacts on health from the natural environment.
HC17 - Are designated sites/local wildlife sites affected by recreation or water quality impacts. Can these be mitigated through creation/enhancement of green/blue infrastructure. Avoid building on open space of public value. Make provision for appropriate quantity and quality of Green Space to meet identified need. Ensure protection and enhancement of PRoW & national trails - seek to provide linkages. Reference contribution to health and well-being.
HC19 - set out clear strategy for delivery of Green Infrastructure - targets, standards, requirements, opportunity areas. Plan should identify deficiencies and opportunities for new green infrastructure.
EC8 - HRA has noted growth could lead to potential likely significant air quality impacts.
EC11 - Assessment of potential air quality impacts on European designated sites is needed.
NB1 - Include European designated sites and reference to green/blue infrastructure. Include within the policy the hierarchy of designated sites in line with NPPF. Soils & Agricultural land not adequately in lie with NPPF; should be valued as a finite resource. Decisions should take full account of impact on soils
NB2 - Approach should be compliant with mitigation hierarchy (NPPF 175). Biodiversity net gain not to be applied to irreplaceable assets. Net gain should be additional to mitigation/compensation habitat creation. Need to highlight how losses and gains will be measured and how net gain will be delivered and managed. On-site provision preferred. Possible linkages with other objectives such as Green Infrastructure.
NB3 - Mitigation must be fully secured. Consider a separate policy for air quality impacts on European designated sites.
NB4 - Reference AONB and the aim of conserving and enhancing character. Reference AONB Design Guide & Management Plan. New Development to minimise and mitigate visual impacts in character areas & landscape setting. Visual should include light pollution. Noise pollution should be included. Areas of tranquility should be identified and protected.
NB5/NB6 - Recognise the role of natural environment to deliver measures to reduce climate change effects. Avoid exacerbating climate change and protect resilience of the natural environment. Promote the role of Green Infrastructure and ecological networks in aiding climate change adaptation - expand tree cover; restore/create priority habitats; retrofit green/blue infrastructure. Suggest set ambitious target for reducing emissions; protect and restore peatland; increase tree and woodland cover; identify nature based solutions and protect sites vulnerable to climate change. Actions should be integrated into strategic approach alongside Green Infrastructure, health and well being, biodiversity net gain, natural flood management, air and water quality.
NB7 - Consider the strategic impacts on water quality and resources (NPPF 170), address flood risk management (155-165). River Basin Management Plans should inform development proposals. Policy should protect habitats from water related impacts and seeks enhancements. Positively contribute to reducing flood risk using natural processes, Green Infrastructure and SUDs.

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