Local Plan 2011-2031 Proposed Submission Draft

As one of the badger co-ordinators for Stevenage and surrounding area and a member of HATBC, I would like to object to the proposed plan GA2 on behalf of HATBC and its Hertfordshire members and advise NHDC/planning inspector of the considerable concerns relating to this area and how they relate to the National Planning Policy Framework.

With regards to section 11 of the NPPF, Conserving and enhancing the natural environment;
109 The planning system should contribute to and enhance the natural and local environment by:
● minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
The GA2 area has actually been increased since the original proposed plan that was bought out for the first consultation. The area now spreads to the right, down towards the bridle path that runs along the bottom of Ryders HIll and Cleveland Way.
Throughout the newly incorporated area of now GA2 live an abundance of badgers which have lived in this area for decades. Main setts can be found in Nine Acre Wood, with satellite setts and outlying holes in Longdell Wood, Newberry Grove and the bank that runs along the edge of Cleveland Way. The fields to the right and below Nine Acre Wood have evidence of a huge presence and with well used runs, holes and latrines. Latrines have also been located In Longdell, Newberry Grove and in the field between Longdell and Brooches.
It is believed that the newly proposed GA2 plan contravenes 109 and would have a huge impact on the badgers living there as well as roe deer, muntjac deer, bats, owls and many other species.
We are aware that they do not require the same level of consideration in planning terms as NERC Act Priority Species but they are legally protected; therefore a full ecological survey would need to be carried out, investigations would need to be made in determining and distinguishing different family groups and the fact that this clan/s cover such an expansive area, a full plan would need to be devised on what is going to happen with these badgers. Obviously they cannot just be relocated anywhere due to territories of other family groups and we would therefore like to be kept in the loop with regards to any further discussions/plans relating to the badgers within GA2.

117 To minimise impacts on biodiversity and geodiversity, planning policies should:
● plan for biodiversity at a landscape-scale across local authority boundaries;
● identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;
● promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;
It is with great concern that it has been noted that within the proposed plan 2016-2031, the wood at GA1 has been mentioned but there is no mention of any of the woodland within GA2 in that particular section.
It also has also given us cause for concern that the local badger group, did in fact object to GA2 during the first consultation and it would seem that NHDC have not even taken into account the biodiversity and varied mammal species including the badger. We would be very interested in NHDC plans with regards to wildlife corridors between Longdell, Newberry Grove, Nine Acre, Brooches Wood and the strip of woodland that runs alongside Cleveland Way.
We would like to know how NHDC are thinking of promoting the preservation, restoration and re-creation of these priority habitats and ecological networks.
Obviously the impact of people on the connective habitat and the surrounding woodlands would have serious impact on this species and many other species within these woodlands.
There are substantial hedgerows/banks connecting the woodland within the GA2 area which is an important connectivity feature, whose value may easily be eroded by the pressure of work and people from the development.

118 When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:
● if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
The loss of the foraging area of a whole badger clan, which is the fields around Nine Acre Wood would be considered as significant harm and this impact should be avoided.

There are other areas which have been proposed by NHDC which would also have implications such as Ickleford and East of Luton; there are also badgers within the vicinity of NS1 but these are not within the immediate area. There are numerous other sites that NHDC have put forward which do not relate to the above points and would have no implications for badgers and other species such as; Clothall Common and Bygrave Common, Baldock, and smaller areas within town/village boundaries.

It is hoped that the above points and their relation to the NPPF will be taken into consideration. We believe that the proposed plan is not sound on the above points and we would like to participate and be kept advised with regards further processes/outcomes.