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La03/Dps/0103 LA03/DPS/0103 Local Development Plan 2030 Draft Plan Strategy Response Form SECTION A – DATA PROTECTION AND CONSENT Antrim and Newtownabbey Borough Council complies with the General Data Protection Regulation (GDPR) by producing a specific Local Development Plan Privacy Notice, which lets you know how we manage any personal information we receive from you. It contains the standards you can expect when we ask for, or hold, your personal information and an explanation of our information management security policy. The Local Development Plan Privacy Notice can be found on our website at www.antrimandnewtownabbey.gov.uk/gdpr/planning-gdpr/. Please note that when you make a representation (or counter-representation) to the Local Development Plan your personal information (with the exception of personal telephone numbers, signatures, email addresses or sensitive personal data) will be made publicly available on the Council’s website. Copies of all representations will be provided to the DfI and an Independent Examiner (a third party) as part of the submission of the Local Development Plan for Independent Examination. A Programme Officer will also have access to this information during the IE stages of the Plan preparation DfI, the Programme Officer the Independent Examiner will, upon receipt, be responsible for the processing of your data in line with prevailing legislation. 1. Please tick to confirm that you have read and understood the Council’s Local Development Plan Privacy Notice. √I confirm that I have read and understood the Local Development Plan privacy notice and I give my consent for Antrim and Newtownabbey Borough Council to hold my personal data for the purposes outlined. You can contact the Council’s Data Protection Officer via: Post - Antrim Civic Centre, 50 Styles Way, Antrim BT41 2UB Email - [email protected] Phone - 028 9446 3113 Page 1 of 61 SECTION B – YOUR DETAILS 2. Please specify if you are responding as an individual, as an organisation, or as an agent acting on behalf of an individual, group or organisation? If you are responding as an agent or representing an organisation you will be the main point of contact for your client/organisation. (Please select only one item) □ Individual √Organisation □ Agent Personal Details Agent Details (If Applicable) Title MS First Name Michelle Last Name Hill Job Title (where Head of Nature Policy & relevant) Casework Organisation RSPB NI (where relevant) Client Name N/A (where relevant) Address RSPB NI NIHQ Belvoir Park Forest Belvoir Drive BELFAST Post Code BT8 7QT Telephone 028 90 491547 Number Email [email protected] Address Page 2 of 61 SECTION C – REPRESENTATION See comments over… Page 3 of 61 Antrim and Newtownabbey – Local Development Plan Draft Plan Strategy Representation A response from RSPB Northern Ireland, 20 September 2019 Introduction The RSPB is UK’s lead organisation in the BirdLife International network of conservation bodies. The RSPB is Europe’s largest voluntary nature conservation organisation with a membership over 1 million, around 13,000 of which live in Northern Ireland. Staff in Northern Ireland work on a wide range of issues, from education and public awareness to agriculture and land use planning. We believe that sustainability should be at the heart of decision-making. The RSPB’s policy and advocacy work covers a wide range of issues including planning and regional policy, climate change, energy, marine issues, water, trade and agriculture. As well as commenting on national planning policy issues. The RSPB’s professional conservation and planning specialists engage with over 1,000 cases each year throughout the UK, including development plans and individual planning applications and proposals. We thus have considerable planning experience. The RSPB also makes over 100 planning applications a year on its own reserves and estate. The RSPB firmly believes that planning, especially plan-making should seek to integrate the three pillars of sustainable development rather than balancing, as this could potentially result in environmental trade-offs. No plan, programme or project should result in a significant direct impact upon important birds or bird habitats. The full suite of Environmental Assessments (SEA, EIA, HRA) should be used as tools to minimise environmental impacts. The Government and planning authorities should ensure that full protection is afforded to both designated and non-designated sites important for wildlife and biodiversity. RSPB NI welcomes the opportunity to comment on the Antrim and Newtownabbey Borough Council (ANBC) Local Development Plan (LDP) Draft Plan Strategy (DPS). This submission comprises a number of responses, and as such they have been numbered for ease of reference. N.B. preference for representation to be dealt with is by way of Oral Hearing – see page 61 of this submission for further details. Page 4 of 61 Please also note that there are a number of RSPB NI consultation responses referred to throughout this dPS response. These were included with our POP response and are also included with this response email for convenience, and comprise the following: • RSPB NI’s response to ANBC POP (2017) (including 2 Maps) • RSPB NI’s response to the DOE’s call for evidence on Renewable Energy (2016) • RSPB NI’s response to the DfI’s call for evidence on Renewable Energy (2017) • RSPB NI’s response to the DOE’s Call for Evidence: Strategic planning policy for Development in the Countryside • RSPB NI’s response to the DOE’s Revised Draft Consultation on Planning Policy Statement 15 (PPS 15) Planning and Flood Risk • RSPB NI’s response to the DOE’s consultation on the draft Strategic Planning Policy Statement (SPPS) These documents should be read in conjunction with the contents of this response. General Comments RSPB NI welcomes the Council’s commitment at SP 1.8, page 66 to produce a range of supplementary planning guidance and advice notes as necessary to support the sustainable development of our Borough’. These notes should be produced in a timely fashion along side the publication of the Plan Strategy and should not only support sustainable development, but actively further it, consistent with the SPPS. In preparing LDPs, councils must take account of the Regional Development Strategy 2035 (RDS 2035), the Sustainable Development Strategy for Northern Ireland and any other policies or advice and guidance issued by the Department, such as the NI Biodiversity Strategy 2020. The latter document recognises that ‘Development is essential to growing the economy, but it has the potential also to play a part in decreasing biodiversity. It can be a major threat to biodiversity depending upon where it takes place, how it is conducted and the manner in which the site is used following development’(page 19). The SPPS requires local plans to: • take full account of the implications of proposed land use zonings, locations for development and settlement limits on natural heritage features and landscape character within or adjoining the plan area; • Natural heritage features and designated sites should be identified, and policies brought forward for their protection and / or enhancement; Page 5 of 61 • identify and promote the design of ecological networks throughout the plan area to help reduce the fragmentation and isolation of natural habitats through a strategic approach; • protect and integrate certain features of the natural heritage when zoning sites for development through ‘key site requirements’; • identify and promote green and blue infrastructure where this will add value to the provision, enhancement and connection of open space and habitats in and around settlements; • consider the natural and cultural components of the landscape and promote opportunities for the enhancement or restoration of degraded landscapes; • incorporate biodiversity into plans for regeneration - by planning for nature and green space in our neighbourhoods we can improve our health and quality of life. Including biodiversity features into schemes adds to the attractiveness and appeal of regenerated areas; and, • ensure that the potential effects on landscape and natural heritage, including the cumulative effect of development are considered. The SPPS recognises that the planning system plays an important role in conserving, protecting and enhancing the environment whilst ensuring it remains responsive and adaptive to the everyday needs of society (para. 4.38). While the planning system is an important delivery tool for biodiversity enhancement, its potential is not being realised in current practice. A Defra survey found that the protection of biodiversity through the prevention or mitigation of potential impacts from development was more common than positive measures to enhance biodiversity.1 However, in order to halt the loss of our habitats and species, Antrim and Newtownabbey Council (like all other councils in NI) will need to ‘work(ing) towards the restoration of and halting the loss of biodiversity’ as identified in paragraph 3.33 of the SPPS. The Defra survey also provided further evidence that investing time and efforts in shaping Local Plans and getting the right policy hooks brings a range of benefits: - Positive aspects of policy, such as habitat enhancement, are more likely to be achieved where plans are specific and relevant areas are spatially defined. 1 “Effectiveness of the application of current planning policy in the town and country planning system”, Project Code CK042, http://randd.defra.gov.uk/Document.aspx?Document=10054_PhaseIIFINALREPORTPDF.pdf
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