Draft Development Contributions SPD - September 2022
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Draft Development Contributions SPD - September 2022
8 NATURAL ENVIRONMENT
Representation ID: 10274
Received: 16/11/2022
Respondent: Mr Michael McCarrick
My comments are in regards to Section 8, Natural Environment and are as follows:
I am greatly concerned by the wording of 8.2.4 in regards to buffers. I am well aware that developers will push for the minimal amount of buffers in any development. I think the wording should include non-designated sites that are biodiversity rich or contain important habitats/species as not all sites that have a large amount of species including protected species have been designated. As someone who has experience as a mammal recorder and been involved with protected species for a number of years, I believe it is important to be clear in regards to policies so that there are no loopholes.
Non-designated sites could be clarified by local groups, such as badger groups, bat groups as well as Herts Environmental Record Centre.
In regards to the buffers, wording should surely also include all connective features as this would cover treebelts that link one woodland habitat to another or an important wildlife habitat to the open countryside. Another concern that I have is in regards to the unclear wording around the 12m buffers. Again, I am more than aware that a developer will aim for as little as possible. Stating 12m around a hedgerow or woodland could be argued that this is a total, but where a site has a large number of species and wildlife corridors are of paramount importance, surely wording should state that in these cases a 12m buffer must be on each side of a hedgeline and on each side of a connective feature, so that everyone is clear as to the policy.
Our biodiversity is in serious decline and we need to give it all the help we can. It is important that North Herts removes any possible loopholes and makes clear on all policies that will benefit our wildlife and result in a net gain, in line with the NPPF. As the new environment bill is not yet in place, I would strongly recommend that North Herts includes in its wording that a minimum 10% net gain is necessary with all development sites in accordance with the NPPF and future bill.
My comments are in regards to Section 8, Natural Environment and are as follows:
I am greatly concerned by the wording of 8.2.4 in regards to buffers. I am well aware that developers will push for the minimal amount of buffers in any development. I think the wording should include non-designated sites that are biodiversity rich or contain important habitats/species as not all sites that have a large amount of species including protected species have been designated. As someone who has experience as a mammal recorder and been involved with protected species for a number of years, I believe it is important to be clear in regards to policies so that there are no loopholes.
Non-designated sites could be clarified by local groups, such as badger groups, bat groups as well as Herts Environmental Record Centre.
In regards to the buffers, wording should surely also include all connective features as this would cover treebelts that link one woodland habitat to another or an important wildlife habitat to the open countryside. Another concern that I have is in regards to the unclear wording around the 12m buffers. Again, I am more than aware that a developer will aim for as little as possible. Stating 12m around a hedgerow or woodland could be argued that this is a total, but where a site has a large number of species and wildlife corridors are of paramount importance, surely wording should state that in these cases a 12m buffer must be on each side of a hedgeline and on each side of a connective feature, so that everyone is clear as to the policy.
Our biodiversity is in serious decline and we need to give it all the help we can. It is important that North Herts removes any possible loopholes and makes clear on all policies that will benefit our wildlife and result in a net gain, in line with the NPPF. As the new environment bill is not yet in place, I would strongly recommend that North Herts includes in its wording that a minimum 10% net gain is necessary with all development sites in accordance with the NPPF and future bill.
