Preferred Options November 2021

Object

Representation ID: 814

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

There are a number of additional elements that would enable the plan to deliver the requirements of national policy, and better achieve environmental net gain.

Further ecological evidence base on particular ecological assets and accessible natural greenspace, a Local Nature Recovery Strategy, GI strategy and further evidence base to support measurable biodiversity net gain.

Object

Representation ID: 816

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

The IDP needs to deliver 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. It also needs to account for and facilitate the provision of 10% Biodiversity net gain

Object

Representation ID: 818

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

Yes, other infrastructure is needed. Flood management proposals need to consider catchment-based approaches that spread and slow water higher in the system, rather than just costly flood mitigation schemes. There is no mention of sustainable drainage, or retfo-fitting nature-based solutions to tackle flooding or the issue of combined sewer overflows

Object

Representation ID: 819

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

Strategic Objective 11- Protecting and enhancing the natural environment
This should also mention strengthening ecological networks and environmental capital/ ecosystem services.
A Local Nature Recovery Strategy and Green infrastructure Strategy would more clearly set out strategic aims.

Strategic Objective 12- Climate Change and sustainable development
This should also include measures to sequester carbon through nature-based solutions such as habitat restoration and increasing soil carbon.

Object

Representation ID: 821

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

Any decision to release a site from the green belt needs to be informed by environmental constraints and opportunities in that area, including any deficit or barriers existing currently with regards to access to nature.
The plan should consider selecting key nature recovery areas, ‘Wildbelts’, as part of a Local Nature Recovery Strategy, and should consider how acccess to nature can be facilitated.

Object

Representation ID: 824

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

The current policy approach is infrastructure lead, focussing new development in settlements with more ‘hard’ infrastructure and facilities. This does not consider environmental limits, such as landscape boundaries, flooding, water scarcity, best and most versatile agricultural soils, ecological sensitivity or other factors relevant to the capacity of the environment to cope with increased development.

Thought should be given to the sustainability of smaller settlements in terms of the ‘critical mass’ of residents required to sustain shops and services, and the potential opportunities for carefully designed development to improve facilities in rural areas, rather than overloading already large villages and towns.

Object

Representation ID: 826

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

This would depend where a new settlement were to be located within a nature recovery network and whether it would enhance it and contribute to biodiversity objectives. A new settlement could provide opportunities to create new habitats and achieve net gain, if located on less environmentally valuable land.

Potential sites should be checked against the NRN map to see whether they fall within critical habitat corridors, and whether this would be an issue, or opportunity, for the network. Appropriate survey of sites for ecological constraints should be carried out before decisions are made as to capacity and suitability for development.

Object

Representation ID: 830

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

The impacts to biodiversity are not currently known. It is not clear that all important wildlife habitats have been identified for avoidance, that 10% BNG would be achieveable, or that sites are appropriate in terms of protecting or enhancing key habitat corridors. It is not clear whether the green infrastructure allocations are sufficient to address any deficits in accessible natural greenspace or how they would interact with the nature recovery network.
We agree that any strategic allocation site should have its own policy. Sufficient information on ecology constraints and opportunities, is required to enable key assets to be protected.

Object

Representation ID: 835

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

We neither support nor object to the proposed housing allocations, as it is not currently possible to determine the impact to biodiversity, whether 10% net gain can be delivered, or whether the sites are appropriate in terms of protecting or enhancing key habitat corridors. We recommend that a further ‘layer’ of assessment is carried out, to identify sites that need additional more detailed targeted ‘Stage 2’ assessment of the ecology baseline, and that this is carried out before final allocations are made.

Object

Representation ID: 839

Received: 13/12/2021

Respondent: Staffordshire Wildlife Trust

Please see comments for Q8- more ecology evidence is needed to check sites are appropriate.