Housing Site Allocations Development Plan Document (DPD) Preferred Options Ref: (For official use only) Comments should be returned by Friday 12th September 2014: Via our consultation portal at the Council’s website: http://consult.westberks.gov.uk/portal By post to: Planning Policy, Planning and Countryside, West Berkshire Council, Council Offices, Market Street, Newbury, RG14 5LD By e-mail to: [email protected] By fax to: 01635 519408 This form has two parts – Part A – Personal details Part B – Comments on the Preferred Options of the Housing Site Allocations DPD Part A 1. Personal Details* 2. Agent’s Details (if applicable) *If an agent is appointed, please complete only the Title, Name and Organisation boxes below but complete the full contact details of the agent in 2. Title Ms. First Name Heather Last Name Lewis Senior Conservation Officer Job Title (where relevant) (Berkshire) Berks, Bucks and Oxon Wildlife Organisation (where relevant) Trust Address Line 1 Hasker House, Woolley Firs Line 2 Cherry Garden Lane Line 3 Maidenhead Line 4 Post Code SL6 3LJ Telephone Number E-mail Address Do you want to be kept informed on the progress of this DPD? Yes If so please make sure you provide an e-mail address above Part B - Please use a separate response sheet for each comment The DPD will be examined by an independent inspector whose role includes assessing whether the plan is sound. For the Housing Site Allocations DPD to be sound it should be:- Positively prepared – the plan should seek to meet the housing requirement for the District based on the policies set out in the adopted Core Strategy; Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; Effective – the plan should be deliverable over its period and based on effective working on cross- boundary strategic priorities; Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the NPPF. We are therefore seeking your views on the soundness of the DPD Preferred Options. Your comments will be published on our Local Plan Consultation Portal and should be planning related. The Council has a duty not to accept comments of a discriminatory nature. West Berkshire Council: Housing Site Allocations DPD Preferred Options Page 2 Response Form To which part of the document does this comment relate? Please specify the section, site or policy Section....Overarching comments.................... on which you are commenting. Do you consider the preferred approach/option to N/A be sound Please give your reasons and, if objecting, please indicate what changes you are seeking or what would be your preferred alternative approach or option for allocation. Overarching comments As a wildlife conservation charity, the Berks, Bucks and Oxon Wildlife Trust are concerned with ensuring the protection and enhancement of the natural environment on and adjacent to the housing allocation preferred option sites. The Trust is not currently able to provide detailed comments for each housing allocation site as further, more detailed environmental information is required given in order to evaluate the potential biodiversity impacts of development at each site. Comments provided below on specific preferred sites, is based on existing habitat and species data already available to the Trust through the Thames Valley Local Records Centre. A full evaluation of biodiversity impacts of each housing allocation site is only possible on provision of appropriately detailed up to date habitat and species survey reports. Such reporting would be expected to form a core part of any subsequent planning application. It is the Local Authority’s responsibility to ensure the provision and evaluation of this appropriate, up-to-date environmental information about each preferred housing allocation site. This data is required to enable objective decision-making for sustainable development, of which retention and enhancement of biodiversity is a key test. The National Planning Policy Framework is clear (paragraph 7) that the environmental role of sustainable development is “contributing to protecting and enhancing our natural environment; and as part of this helping to improve biodiversity” whereby improving biodiversity is further clarified (Paragraph 9) as “moving from a net loss of biodiversity to achieving net gains for nature”. In addition, section 40(1) of the Natural Environment and Rural Communities (NERC) Act 2006 creates a duty for every public authority to “have regard” to biodiversity whilst exercising its functions. The Trust therefore expects that where current levels of information are not sufficient to provide detailed comments for all preferred housing allocation sites, that the Council will have regard to biodiversity during the subsequent planning process to ensure that the aims of the National Planning Policy Framework are furthered by achieving net gains for nature. The Trust looks forward to being consulted further during the planning process for all preferred sites identified within this consultation document if / when planning permission (either full or outline) is submitted to the Council for consideration. Please continue on separate sheet West Berkshire Council: Housing Site Allocations DPD Preferred Options Page 3 Response Form Section................................................... To which part of the document does this comment relate? Please specify the section, site or policy on Site..................NEW012, NEW104, NEW045, NEW042, which you are commenting. NEW106, BUR105, WOOL001, EUA007, EUA033, GTTS9................... Policy........................................................ Do you consider the preferred approach/option to be Potentially unsound, subject to further clarification and sound submission of further supporting information The following preferred housing allocation sites are located either immediately adjacent or in close proximity to sites that have one of more of the following designations; - nationally important Ancient Woodlands, - Local Wildlife Sites - sites of County importance; NEW 012 NEW 104 NEW 045 NEW 042 NEW 106 BUR105 WOOL001 EUA007 EUA033 GTTS9 Ancient Woodland is considered an irreplaceable habitat due to the unique biodiversity associated with it’s longevity. Paragraph 118 of the National Planning Policy Framework is clear that “Planning permission should be refused for development resulting in loss or deterioration of irreplaceable habitats including ancient woodland”. The West Berkshire Cores Strategy (July 2012) Policy CS 17 ‘Biodiversity and Geodiversity’ states that “Development which may harm, either directly or indirectly, locally designated sites (Local Wildlife Sites)… will only be permitted if there are no reasonable alternatives and there are clear demonstrable social or economic benefits of regional or national importance that outweigh the need to safeguard the site or species and that adequate compensation and mitigation measures are provided when damage to biodiversity/geodiversity interests are unavoidable.” Adverse impacts on Ancient Woodland and Local Wildlife Sites resulting from a new housing development can obviously occur where the designated habitat suffers direct loss. However, damaging deterioration of habitat can also result from indirect impacts such as increased visitor pressure due to an increased local population. Indirect impacts can include trampling and disturbance. Where planning permission is sought for the above referenced preferred housing sites, we would expect to see consideration of how mitigation measures, such as provision and management of public open space, or management of the designated sites, are to be implemented and evidence of how these mitigation measures will effectively ensure that the development will proactively contribute to protecting and enhancing the local Ancient Woodland and Local Wildlife Sites as well as the wider natural environment. Implementation of effective measures to avoid or mitigate for indirect impacts on local Ancient Woodland and Local Wildlife Sites will help ensure that the policies of the National Planning Policy Framework and the West Berkshire Core Strategy are met. In absence of effective impact avoidance or mitigation measures being implemented, these proposed housing allocation sites may be unsound in that the site selection would fail to be positively prepared, justified or consistent with national policy. West Berkshire Council: Housing Site Allocations DPD Preferred Options Page 4 Response Form To which part of the document does this comment Section................................................... relate? Please specify the section, site or policy on which you are commenting. Site..................NEW047D Policy........................................................ Do you consider the preferred approach/option to Potentially unsound, subject to further clarification be sound and submission of further supporting information Housing allocation site NEW047D is located in close proximity to Greenham and Crookham Commons Site of Special Scientific Interest (SSSI). This site is also a nature reserve managed by this Trust. The current proposals are likely to represent a local population increase of approximately 300 people within easy walking distance of the SSSI. These residents are likely to visit the SSSI for recreational activities such as dog walking. It is likely that the development of