Draft Development Contributions SPD - September 2022

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Comment

Draft Development Contributions SPD - September 2022

8 NATURAL ENVIRONMENT

Representation ID: 10273

Received: 16/11/2022

Respondent: Ms Nikki Hamilton

Representation Summary:

Incorporate 'non-designated' sites that include important habitats and species and connective features into wording of 8.2.4. Also include 12m complimentary habitat should be incorporated on either side of hedgerows and connective features in all wildlife rich sites to ensure a minimum of 10% net gain.

Amend wording to state in accordance with the Environment Act 2021, the council requires all developments to achieve 10% biodiversity net gain.

Utilise domestic features such as swift bricks, hedgehog holes and bat boxes.

Full text:

SPD wording 8.2.4: 12 metres of complimentary habitat should be provided around wildlife sites (locally designated sites and above), trees and hedgerows.

During the local plan process and subsequent hearings, NHDC made an amendment to SP12 to state 'non-designated sites that include important habitats and species'. This should be re-iterated in the SPD as there are sites of significant importance regarding biodiversity that are not currently designated sites. The policy within the local plan also included 'for all connective features' - this should also be incorporated into the SPD wording.

Suggested change 8.2.4: 12 metres of complimentary habitat should be provided around wildlife sites (both locally designated sites and above and non-designated sites that include important habitats and species), connective features, trees and hedgerows.

Our other concern regarding 8.2.4 is the word 'around'. This gives developers scope for including as minimal buffers as possible. It is imperative that where there are mature hedgerows which are of huge value to biodiversity, a 12m buffer is incorporated on either side. Likewise, in any site rich in wildlife - it is also imperative that 12m buffers are implemented on each side of a hedgerow and on each side of a wildlife corridor, such as a thin strip of woodland that joins one habitat to another or one woodland to another. This will help to ensure the 10% net gain. Therefore, this should be incorporated into the wording.

Suggested change 8.2.4: 12 metres of complimentary habitat should be provided around wildlife sites (locally designated sites and above and non-designated sites that include important habitats and species), connective features, trees and hedgerows. In wildlife rich areas, 12 metres of complimentary habitat should be provided on either side of hedgerows and all connective features.

Obviously Natural England state all ancient woodlands and ancient trees should have a minimum of 15 metres of complimentary habitat.

SPD wording 8.2.7: Whilst the Local Plan does not specify a target for BNG, the Council are taking a pro-active and masterplan led approach to encouraging new developments to achieve a net gain for biodiversity of at least 10%.

NPPF 174 states that net gain is a requirement of planning. The new environment bills sets this level at a 10% uplift; but under the NPPF, each local planning authority can set the net gain bar as high as it wants. By stating you are encouraging 10%, this again will give developers scope to totally ignore this and revert back to the minimum until the new bill is in place.

Suggested change 8.2.7: The NPPF state that net gain is a requirement of planning which must be determined by utilising the Natural England Biodiversity Metric. In accordance with the Environment Act 2021, the council requires all developments to reach a minimum 10% uplift to achieve biodiversity net gain.

Utilise domestic scale features to support biodiversity, such as integrated bat and bird boxes and swift bricks. Likewise, incorporate hedgehog holes within fencing.

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