Policy NB1: Protecting, enhancing and expanding natural assets

Comment

Representation ID: 4650

Received: 19/12/2022

Respondent: Woodland Trust

The local plan should
- stipulate a minimum 50m buffer for development from ancient woodland where developments exceed 10 dwellings
- protect ancient woodland sites using policy wording from the Planners' Manual for Ancient Woodland and Veteran Trees
- give weight to the relevant LNRS to ensure development is not allocated in close proximity to ancient woodland
- Encourage veteran trees to be recorded on the Ancient Tree inventory and to consider locations where it might be suitable to place a Tree Preservation Order and encourage a buffer zone to go beyond minimum distances stipulated in planning advice.

Object

Representation ID: 5058

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Green Infrastructure evidence being used by the Council is far too vague, provides a meaningless planning policy framework, is insufficiently robust, and fails to respond effectively to deliver requirements of green infrastructure guidance expected by paragraphs 174 (indent d), 175 and 179 of the Revised NPPF (2021). The Council is taking forward an unsound policy (based on highly questionable, vague, totally meaningless and insufficiently robust evidence) which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021).
position is perfectly clear, the Council is using insufficiently robust Nature Recovery Network Mapping or Open Space Strategy to inform critically important housing-led spatial planning policy considerations across the district. The Council is taking forward an unsound policy which conflicts with the tests of Soundness as reinforced in paragraphs 31 and 35 (indents b and d) of the Revised NPPF (2021).
By encouraging destruction to sensitive wildlife corridors by promoting huge levels of new housing development immediately alongside the sensitive South Staffordshire Railway walk natural green space corridor within the Lower Penn area of the district (and other wildlife corridors in other parts of the district), the Council is failing to promote the most sustainable patterns of development, in direct conflict with the ‘Sustainability’ tests of ‘Soundness’ as reinforced in paragraph 35 (indent d) of the Revised NPPF (2021).

Object

Representation ID: 5064

Received: 20/12/2022

Respondent: Goldfinch TPS

Agent: Goldfinch TPS

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council is proposing heavily urbanising, high density major residential development proposals immediately alongside the South Staffordshire Railway Walk dismantled railway line within the Lower Penn area of the district, which forms a critically important and highly sensitive landscape-scale connecting wildlife corridor, containing highly sensitive mature deciduous broadleaved woodland habitat. The Council’s land use spatial planning policy approach and huge levels of environmental destruction being proposed within the Publication Stage Report (November 2022) is failing to protect critically important wildlife corridors and is therefore failing to promote the most sustainable patterns of development.
The South Staffordshire Railway Walk dismantled railway line woodland located within the Lower Penn countryside extends across considerable areas of countryside, connecting across the rural landscape. These are highly sensitive wildlife habitats and form critically important landscape-scale linear wildlife corridor features, and should be protected from inappropriate forms of development which could harm their continued wildlife corridor function, consistent with wildlife corridor and green infrastructure focused national planning guidance as reinforced within paragraphs174 (indents a an d) and 179 of the Revised NPPF (2021).
We are aware of active bat roost within the South Staffordshire Railway Walk dismantled railway line broadleaved woodland at Lower Penn, which immediately borders proposed major housing site allocation site 582 Langley Road, Lower Penn.
The natural environment is a key Sustainability issue which has been completely overlooked and neglected, and has not been given sufficient consideration and sufficient material planning weight by the Council within both the Sustainability Appraisal (SA) supporting background evidence.

Object

Representation ID: 5269

Received: 22/12/2022

Respondent: Mr Paul Wilkinson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Change must take nature alongside it and adapt to climate change. No evidence that development can be sustainable and protect the natural environment.

Relying on already strained green infrastructure is not delivering policies on protecting the natural environment and adapting to climate change.

The NPPF has a requirement to protect biodiversity, but recent developments have resulted in a loss, degraded water courses/quality, and failed to protect green infrastructure including hedges and mature trees.

Biodiversity and green infrastructure degradation has occurred on the periphery of the [unidentified] site.

Biodiversity loss on biologically important sites damaged by increasing public pressures at Highgate, and Kinver SSIs, and Himley Plantation.

The plan must include new open spaces allocations (similar to housing and employment) to mitigate increasing number of residents, to protect existing allocations for nature conservation as biodiversity is negatively affected by anthropogenic disturbance.

Biodiversity net gain is not evidenced on previous developments.

The built infrastructure should be sustainable and not passed on to new home-owners to retrospectively fund green and clean energy. Solar panels, heart source pumps, and EV charging points should be included as standard.

Support

Representation ID: 5313

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Support policy.