Regulation 18 draft Local Plan

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Object

Regulation 18 draft Local Plan

Policy SS7 – Re-use of redundant military bases and prisons

Representation ID: 5098

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Natural England notes that this policy aims to minimise any built development on undeveloped land within the curtilage of these sites. We therefore suggest that these sites may be appropriate locations for the provision for Biodiversity Net Gain off-setting.


Our response:

Comments noted. Agree that sites may be appropriate for application of biodiversity net-gain for major development. This would be covered by Local Plan Policy EN3 and criteria c) of the policy refers to the enhancement of the natural heritage. As the introductory chapter makes clear the policies of the Plan should not be read in isolation from each other and, for this reason, the Plan does not normally include cross referencing between policies.

Object

Regulation 18 draft Local Plan

Policy H2 – Cross-boundary development opportunity – Stamford North

Representation ID: 5099

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Bullet point (c) requires a country park incorporating the appropriate mitigation of potential harm to biodiversity and wildlife assets, including the appropriate translocation of notable species and would wish to ensure that the BNG requirements can be fully met on this site.
We welcome bullet point (h) which requires 15% Green Infrastructure on the site and emphasise the importance that GI is incorporated throughout the site, so all residents have equal access to high quality green space. We would also advise that GI design follows advice in both the Melton GBI Strategy (2023) and Natural England’s GI Framework.


Our response:

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Support

Regulation 18 draft Local Plan

Policy SC1 – Landscape character

Representation ID: 5100

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Natural England welcomes this policy.


Our response:

Support noted

Object

Regulation 18 draft Local Plan

Policy SC3 – Promoting good quality design

Representation ID: 5101

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Reference should be made within this policy of the Natural England's GI Planning and Design Guide which complements the National Model Design Code and National Design Guide and will help to inspire the creation of healthier, nature-rich, climate resilient and thriving places to live, learn, work and play. We suggest that the GI design guide should be included in the list of supporting evidence.
In section 2a we support the provision for walking and cycling but suggest there is a strong link to Green Infrastructure.


Our response:

Comments noted. Changes to Policy text required.

Support

Regulation 18 draft Local Plan

Policy SC4– Pollution control

Representation ID: 5102

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Natural England supports this policy.


Our response:

support noted

Object

Regulation 18 draft Local Plan

Policy SC5 - Designing safer and healthier communities

Representation ID: 5104

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

NE suggest the policy be expanded to include the health benefits of GI. Green and blue spaces can have a positive impact on preventing health issues through providing opportunities for more active and healthy lives. GI can supply other health benefits by helping to address some of the environmental causes of poor health, such as poor air quality, by filtering particulates, and reducing urban summer temperatures by cooling the air. A range of considerations have been listed including the green in 15 target: everyone has access to a variety of good quality GI within fifteen minutes’ walk of their home


Our response:

Agree. Add reference to Green and blue infrastructure in criterion c

Support

Regulation 18 draft Local Plan

Policy SC7 - Creation of New Open Space

Representation ID: 5106

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Natural England welcomes this policy particularly bullet point e which aims to maximise green infrastructure benefits and link to the wider GBI network.
We suggest you may want to refer to Natural England’s Accessible Greenspace Standards to determine open space needs based on size, proximity capacity and quality. The Environmental Improvement Plan has highlighted an initial focus on access to green and blue spaces within 15 minutes’ walk from home.


Our response:

Support welcomed

Object

Regulation 18 draft Local Plan

Policy EN1 - Protection of Sites, Habitats and Species

Representation ID: 5107

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

NE suggests that the wording in points 1 and 2 regarding the hierarchy of designations could be clearer. The policy should reflect a hierarchy of protection related to their international, national or local sites status. For point 1 it may be clearer to refer to Habitat Sites to reflect the term used in the NPPF when describing areas previously known as European sites.
Point 2 should refer only to SSSIs and National Nature Reserves – it is not necessary to include internationally Important sites again as these are included in point 1.
Natural England welcomes the Biodiversity Assessment May 2023.


Our response:

Comments noted. Agree. Add in ‘habitat' after ‘designated’ in part 1. Delete ‘and Internationally Important Sites’ in part 2 to reflect the hierarchical approach taken in the NPPF.

Support

Regulation 18 draft Local Plan

Policy EN2 - Local Nature Recovery Strategy

Representation ID: 5108

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

Natural England welcomes the inclusion of this policy and suggests further additional explanation should be included within the explanatory text of the policy.


Our response:

Support noted. Agree additional text accompanying Policy EN2 to explain background and role of LNRSs.
Under Why is this policy needed?
The Environment Act 2021 establishes a new mandatory system of spatial strategies ensuring that opportunities to recover nature are joined-up. Local Nature Recovery Strategies (LNRS), part of the Government’s 25-year Environment Plan, are aimed at improving, expanding and connecting habitats to address wildlife decline and provide wider environmental benefits for people. They will map the most valuable existing areas for nature, establish priorities, and map proposals for specific actions to drive nature’s recovery and wider environmental benefits.
A Local Nature Recovery Strategy for Leicestershire, Leicester and Rutland is currently being prepared. Across this area, less than 1% of the area has a high biodiversity score and only approximately 6% is covered by woodland, compared to the national average of 13%. The LNRS is needed because Rutland Council has declared a Climate Crisis and Ecological Emergency and there is a need to work together as communities to deal with the problems and impacts of climate change and the loss of species and habitats. It will help to guide nature-based approaches to carbon removal and storage, and flood prevention. The LNRS will be used to inform the preparation of the Local Plan and will guide policy requirements, such as in relation to Biodiversity Net Gain under Policy EN3, by informing the delivery of biodiversity offsetting. Policy EN2 is also aimed at ensuring that development proposals not subject to the mandatory BNG requirements will still be expected to make a positive contribution towards the LNRS. Statutory guidance on alignment between Local Plans and LNRS is anticipated as part of the Government’s work on planning reform.

Support

Regulation 18 draft Local Plan

Policy EN3 - Biodiversity Net Gain

Representation ID: 5110

Received: 03/01/2024

Respondent: Natural England

Representation Summary:

NE welcomes this policy and the comprehensive guidance it includes. We welcome the target of 15% BNG and also note that 20% BNG has shown to be viable within Rutland. We advise that any target should be achievable and evidence based. We welcome links and reference to Local Nature Recovery Strategy, the Rutland County Biodiversity Assessment, and the Green Infrastructure policy. There should be a clear strategy for BNG delivery within allocated sites for development.


Our response:

Support noted. Since the Reg 18 Plan was published Government guidance set out in the PPG on BNG has been updated. As a result, the BNG is to be changed from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.

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